I would like what was in place during and also what is in place now

Freedom of Information Request Reference No: I note you seek access to the following information: Any and all policies, operating procedures and rela...
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Freedom of Information Request Reference No: I note you seek access to the following information:

Any and all policies, operating procedures and related documents relating to officers working hours, the monitoring of working hours, the safeguarding of officers welfare in relation to the effects of working excessive hours and in relation to the European Working Time Directive. In particular in relation to the monitoring of officers who have agreed to "opt out" of the Working Time regulations and the policies and procedures surrounding officers making the choice to opt out. I would like what was in place during 2005-2006 and also what is in place now.

DECISION I have today decided to disclose the located information to you in full. Please find below and attached information pursuant to your request above. 1a. Any and all policies, operating procedures and related documents relating to officers working hours, the monitoring of working hours, the safeguarding of officers welfare in relation to the effects of working excessive hours and in relation to the European Working Time Directive. 1b. In particular in relation to the monitoring of officers who have agreed to "opt out" of the Working Time regulations and the policies and procedures surrounding officers making the choice to opt out. Please see attached document 'WTR Guidance July 2013' and Questionnaire

1c. I would like what was in place during 2005-2006 and also what is in place now Please see attached documents 'Inspector hours - guidance on hours worked' and 'inspector ranks - working hours protocol memo'

Directorate of Human Resources

Working Time Regulations (WTR) Guidance All members of the MPS must adhere to the Working Time Regulations (WTR) 1998. The following procedures aim to ensure that the MPS as an organisation operates within the provisions of the Working Time Regulations 1998 (as amended). It also aims to improve the health and safety of workers by outlining entitlements for:     

Weekly working time; Night work, Daily/Weekly rest periods; In-work rest breaks; and Annual leave.

Under the Working Time Regulations, some police activities may be exempt (under Reg 18), for instance when dealing with civil unrest and terrorism. Police officers of the rank of Commander and above and senior police staff roles may also be exempt (under Reg 20) from the weekly working time limit. Such exemptions need to be looked at on an individual basis.

Introduction The Working Time Regulations 1998 (WTR), the Working Time (Amendment) Regulations 2006 and 2007 provide rights for workers, including police officers and police staff, to regulate the hours worked. The regulations aim to improve health and safety at work by introducing entitlements for workers relating to:     

hours of work; daily and weekly rest periods; rest breaks; night work; and Annual leave

Most of the requirements of the regulations around hours, rest breaks and leave entitlements are already provided for within existing police regulations and police staff conditions of service. Putting the procedures into practice The WTR came into force on 1 October 1998. Operational Command Unit Commanders, Heads of Branches and HR Professionals have specific responsibilities. Additionally, all line managers have responsibilities under the Regulations for monitoring and managing the working time of their officers and staff. The Regulations apply to all police officers, special constables, police staff (including PCSOs/Traffic Wardens) and casual staff in Catering. The purpose of this document is to ensure effective implementation.

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Working Time Regulations – Instructions for Managers (SOP) The Working Time Regulations 1998 (WTR) and the Working Time (Amendment) Regulations 2006 and 2007 aim to improve health and safety at work by introducing entitlements for workers relating to hours of work, daily and weekly rest periods, rest breaks, night work and annual leave. Whilst the Regulations bring some changes to the way the MPS currently works, most of the requirements of the Working Time Regulations, around hours, rest breaks and leave entitlements are already provided for within existing Police Regulations and police staff conditions of service.

Duty of care The common law ' duty of care' and legislative provisions including the Health and Safety at Work Act 1974 states that the employer owes a duty of care to anyone whom we can reasonably foresee would be likely to be injured by the things we do or omit to do. The duty of care must always be borne in mind when reading these Regulations and especially if dealing with any of the exemptions.

What is Working Time? Regulation 2 to the WTR defines “working time'” in relation to a worker as meaning: (a) any period during which they are working, at their employer's disposal and carrying out their activity or duties, and/or (b) any period during which they are receiving relevant training. The Working Time (Amendment) Regulations 2006 removed the 'partly unmeasured working time' exemption in Regulation 20 of the WTR. Therefore, working time includes any period when the worker is performing certain voluntary activity (Reservist/Youth & Community/Charity Work etc) or is a “vocational driver” outside their normal working or duty time. Further advice is given about this in Annex E.

Weekly Working Time The weekly working time limit The Regulations impose a limit of an average of 48 hours working time a week. The average is measured over a reference period of 17 weeks or 26 weeks where the exception in regulation 21 applies (see further advice below). The definition of working time and the method of calculation are set out, in detail, in Annex A. An individual may be asked to sign an opt-out of the 48-hour average limit if they wish to exceed the 48 hour weekly maximum, particularly if they undertake other employment which, when added to the cumulative hours of their employment with the MPS, might lead to working longer than the 48 hour average. Managers must consult the Business Interests, Secondary Employment and Political Activities SOP when a member of the MPS has, or is considering undertaking, a Business Interest. Generally a condition should be imposed to any business interest requiring that the individual will not work in excess of the 48-hour average limit unless they have signed the opt-out. Similarly, MSC officers should be asked to complete the opt-out agreement as the combination of their MSC duties and their other employment may cause them to exceed the 48-hour average limit. Members of police staff, who are also members of the Metropolitan Special Constabulary (MSC), should refer to Section 5 of the Metropolitan Special Constabulary - Standard Operating Procedures (SOP) published under Item 6 of Notice

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25/2009. This SOP provides guidance about the WTR opt-out in respect of duty performed as a Special Constable in conjunction with duty performed as a member of police staff. It also provides for a standard letter for use in these circumstances. Further advice about this may be obtained from Tim Reason (TP - MSC Co-ordinator). Officers and staff who are "vocational drivers" (exclusively drivers of vehicles that require tachographs) for the MPS and who are engaged on any weekly voluntary activity (whether driving or not) may not be achieving the required daily or weekly rest under the WTR. Further details can be found in Annex E. Exemptions The following exemptions to the weekly working time limit apply: Regulation 5. An individual may choose to agree to work more than the 48-hour average weekly limit. This exemption remains under discussion between the Government and the EU and could be withdrawn at some future date. Regulation 20 - The time limit does not apply to individuals who have complete control over the hours they work and whose time is not monitored or determined by their employer. Police officers from the ranks of Commander and above may fall into this category but each role must be considered individually. Some senior police staff roles may also fall within this exemption. Regulation 21 - The reference period of 17 weeks, for the purpose of measuring the 48-hour weekly maximum, may be extended to 26 weeks in a range of circumstances including:  

Where an individual is engaged in security or surveillance activities; Where there is a need for continuity of service; Where there is a foreseeable surge in activity or where the individual's activities are affected by unusual or unforeseen circumstances, exceptional events or an accident or imminent risk of one.

Categories such as Custody Officers, CAD/Communications Officer-CCC officers, PCSOs, officers engaged on 24-hour protection or surveillance duties and generally those engaged in providing a response to calls for assistance from the public, would be covered by Regulation 21. This exemption would also apply to duties occasioned by the need to respond to major emergencies (Force Majeure), or significant public events requiring exceptional policing. Regulation 18 - Regulation 18 will only be used in exceptional circumstances. Certain activities within the police service, which inevitably conflict with the Regulations, may mean that individuals engaged in these activities will be exempt from this time limit. These activities have not been defined by the Regulations but HSE have provided examples that are likely to fall within the scope of this regulation as dealing with widespread civil disturbance or terrorism. Action to be taken 

OCU Commanders or Heads of Branches must have arrangements in place whereby they are able to identify from local records all workers within their OCU/Branch who are not exempted, or those who only perform potentially exempt activities, as outlined above, for part of their time. Working time must be monitored by line managers and/or Duties Offices (as appropriate) in all cases and, where any officer or member of staff exceeds an average of 48 hours working time a week are identified, the OCU Commander or Head of Branch should be notified. An immediate review of that individual’s working time should be undertaken and, where necessary, compensatory rest applied. Measures should also be taken to ensure that no further breach of the Regulations occurs. Since

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the 9th October 2012, each individual can be offered the option of completing an optout agreement on HR Employee SelfService. The details within the opt-out form include the reason for opting out, the number of additional hours, the pattern of these additional hours and the duration of the opt-out (unless it is indefinite). To terminate the agreement if no end date was originally specified, the individual must review the agreement on Employee SelfService and enter the end date, including the relevant notice period. 

Once an individual has submitted or revised an opt-out on Employee SelfService, the line manager will be sent an electronic notification to review and complete their section.



This is a genuinely voluntary arrangement and there is legal protection from victimisation for a refusal to opt-out. If an individual is unwilling to opt-out, arrangements must be made to manage the working hours so as not to exceed the permitted average. There is still a duty of care under the Health and Safety at Work Act owed to individuals that have opted out, their colleagues and the public, to ensure that the additional hours worked do not compromise the ability to work safely. A report identifying individuals that have current opt-out agreements is available to senior managers using Manager SelfService, to facilitate monitoring arrangements.



Records of work (a record of the duty performed/hours worked - including any relevant outside hours/activity) need to be kept in every instance. Officers and staff who have signed an opt-out are not exempted from this provision. If an individual is working excessive hours, there remains a duty of care towards them and such steps as referring them for a risk assessment is recommended. Advice may be sought either from local risk assessment experts or from the PeopleStrategy Health & Safety Team at ESB.



Managers are responsible for ensuring that a "long hours culture" does not become the norm. This should be constantly monitored. As the 'opt- out clause' could be withdrawn in future, local managers should review the work patterns of individuals on a regular basis, to ensure the working limit is not exceeded. Individuals are entitled to terminate the opt-out agreement by giving the notice, which was contracted to when first signing the agreement. This will normally be one month. Managers should also be aware of the additional guidance published on PeoplePages around the hours worked for Inspecting ranks, which has been agreed with the MPS Inspector’s Branch Board.

Night work limits A night worker is defined as a person who works at least three hours of their daily working time between 2300 and 0600 hours as a normal course. This includes periods of night work undertaken as part of a shift system. Night work should be limited to no more than 8 hours in a 24-hour period for those workers whose duties involve special hazards or heavy physical or mental strain as identified in a risk assessment of a particular role or activity. For other workers, the calculation is based upon average normal working hours, not actual hours, over a 17-week reference period. Advice in respect of risk assessments may be directed to the PeopleStrategy Health & Safety Team where necessary. The Police Negotiating Board definition of a night worker is a police officer who regularly works shifts which include nights, irrespective of the shift pattern actually worked, should be a 'night worker' for the purposes of the Working Time Regulations.' This definition will apply also to police staff. Exemptions The above limits do not apply to workers exempted under Regulations 18, 20 or 21. Where a shift pattern has been agreed through the Joint Branch Board or through a collective

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agreement with one or more of the trade unions, restrictions on night working for police officers and police staff do not apply. Action to be taken 

OCU Commanders or Heads of Branches should identify any night workers not exempted from the night work limits whose working arrangements exceed the limits. In any such cases the OCU Commander/Head of Branch must consider adjustments to the working arrangements to ensure that the limits are not breached. In order to comply with the Management of Health and Safety at Work Regulations 1999, risk assessments should be done on any night work involving particularly long hours. Advice on hazardous working conditions may be obtained from the PeopleStrategy Health & Safety Team at ESB.

Health assessments for night workers The Regulations provide that individuals becoming night workers should be offered health assessments and that these should be offered annually thereafter. The health assessment will take the form of a questionnaire. Completed questionnaires will be scrutinised by PeopleSupport Occupational Health (OH) and managers will only have the right to know if an individual is able to do night work. A copy of Form 6030 can be found on the Forms Unit website. Workers must be transferred from night work where medical opinion advises that they have health problems associated with performing night work. Any action that may be taken will depend on a thorough OH assessment, which may require a referral and consent to access the GP for a report. If OH advises that an individual should be taken off night duty, this may only be temporary, for example, until they are used to new medication/treatment. Where an individual is permanently removed from night work, due to a significant health condition, this will have been verified and advised by a Medical Officer or OH practitioner. When the health questionnaire (Form 6030) is offered, Line Managers should make and retain a record of this locally. To protect the MPS, an audit trail is needed to provide evidence that the assessment was at least offered. If an individual chooses to complete the form this should be sent to PeopleSupport Occupational Health - preferably by e-mail. This will be retained on the computerised HR system. A response will be provided back to managers about fitness to continue - a copy of this will also be retained on the system. If the individual does not choose to complete it, no further action will be taken. Exemptions (in respect of night-work limits and health assessments) None of the exemptions affects the obligation to offer health assessments. New recruits, and police staff recruited for night work, are covered under the medical at the time of joining. All night workers (including new night workers) should then be offered questionnaires on an annual basis, the timing of this being governed by the OH Team Manager. Occupational Health will retain completed questionnaires and will contact OCU Commanders/Heads of Branches where an individual should be temporarily transferred from night work. The only information that can be disclosed without the individual's consent is that the individual is fit to take up or continue night work. This means the issue of night work adversely affecting the health of an individual can only come to management's attention by self-reporting or as a result of direct observation by the manager. Managers should encourage those officers or staff working regularly at night to raise any concerns that they may have about the effect of the night work on their health. As stated above, a health assessment to determine a worker's fitness to be a night worker or to work during the restricted period should not be disclosed to any other person other than the worker to whom it relates. This is unless: 

The worker has given their consent in writing to the disclosure.

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The disclosure is confined to a statement that the assessment shows the worker is fit to be a night worker, or continue to be a night worker, or to work during the restricted period, or to continue to work during the restricted period.

Annual Leave The Regulations provide for a minimum of 5.6 weeks (28 days) paid leave a year but Public Holidays & Bank Holidays, where appropriate, may be counted against this entitlement. Annual Leave, Bank/Public Holiday provisions, and shift rostering arrangements, for officers and staff are already compliant with these forthcoming changes. The Regulations also provide for the relevant notice periods in respect of requesting or the cancellation of leave. Full details may be found in the SOP covering Police Staff Annual Leave and, in respect of police officers, Regulation 33 should be consulted (see the Compensation and Benefits website on PeoplePages). The Regulations also provide for payment for untaken leave on termination of employment. For full details on this subject, please refer to the Leaving the Service Standard Operating Procedures which appear on PeoplePages. Action to be taken 

The carrying forward of annual leave is limited to 5 days for police officers, as defined in Police Regulations, and 9 days for police staff (or up to one third of their annual entitlement in hours if part-time), pursuant to their contractual terms and conditions. These limits apply unless there are exceptional circumstances and it is in the interests of efficiency to do otherwise. Local line management will find specific advice within individual Standard Operating Procedures (SOPs) in respect of advice about annual leave. In particular, the Annual Leave and Public/Bank Holiday Leave for Police Staff – Standard Operating Procedures (SOP) and the Reg 33 Guidance for police officers should be consulted. In cases involving long-term sickness and/or maternity leave, the Attendance Management Standard Operating Procedures and/or the Maternity Standard Operating Procedures (as appropriate to the circumstances) must be consulted for advice about the accrual and taking of annual leave.



Line managers should also ensure that, so far as is possible, all police officers and police staff take any outstanding leave prior to termination of employment. Full details around annual leave upon termination of service can be found in the Leaving the Service Policy on PeoplePages.

Rest Periods Daily and weekly rest periods The Regulations provide for the following entitlements: a worker is entitled to a rest period of 11 consecutive hours between each working day (12 hours if they are under 18 years of age)  a worker is entitled additionally to an uninterrupted rest period of not less than 24 hours in each 7 day period although this may be averaged over a two week period allowing for two days' rest a fortnight (in the case of workers under 18 years of age, the rest period should be 2 days in each 7 day period and this cannot be averaged) 

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The right to rest periods and breaks is an entitlement. Those who take their entitlements must not be subjected to any detriment for doing so. Exemptions Regulations 18, 20 and 21 are relevant. Where Regulation 21 applies, there is an entitlement to "an equivalent period of compensatory rest" where the normal rest periods have not been made available. Police Regulations and police staff conditions of service already set out entitlements to rest periods. Where they provide individuals with additional entitlements these will take precedence over Working Time Regulations. The entitlement to an 11-hour daily rest period is disapplied where a shift pattern is employed which entails "quick changeovers" between shifts, as a result of Regulation 22. However, as a matter of good practice, the rostering of shifts should, where possible, be arranged to avoid breaks between consecutive shifts of less than 11 hours. Under Police Regulations, breaks of less than 11 hours between shifts need to be agreed by the Federation's Joint Executive Committee in the case of police officers. Action to be taken 

Managers should ensure that the entitlements to daily and weekly rest should, so far as is consistent with operational requirements of the Service, be complied with irrespective of whether or not an exemption from the statutory entitlements may apply.

In work rest breaks The Regulations provide that a worker is entitled to an uninterrupted break of 20 minutes when daily working time is more than 6 hours. Legal advice is that this break of 20 minutes should be applied in respect of each 6 hours worked. Therefore, in instances where workers are working for a period of 12 hours, an uninterrupted break of 40 minutes is required. This rationale should be applied on a pro-rata basis so that if a worker works for 9 hours, they should take a break of 30 minutes. In the case of workers who are under 18 years of age, the rest period should be 30 minutes when daily working time is more than 4 and ½ hours. Therefore, the break would be 1 hour where the working time is 9 hours. An in work rest break must be a break in working time rather than be taken at the start or end of a working day (which is not permitted under the Regulations). The Break should also not overlap with the daily rest period. In other words, workers may not forego breaks in order to leave work early. Lunch breaks count as in-work rest breaks for the purposes of the Regulations. Managers must be aware that breaks provided for under a contract of employment or Police Regulations may be more generous than the minimum quoted under the WTR. Exemptions Regulations 18, 20 and 21 are relevant. Police Regulations and police staff conditions of service already set out entitlements to rest periods. Where they provide individuals with additional entitlements these will take precedence over Working Time Regulations. Action to be taken 

Managers are reminded that individuals are entitled to take their breaks and should not be disadvantaged in consequence. The consent of the individuals concerned must be obtained if it is intended to hold meetings or conduct work-related discussions during refreshment/meal breaks.

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It is the responsibility of individual members of staff and their line management to ensure that they take rest breaks. In exceptional circumstances, for instance where there is an emergency or the need to ensure continuity of service, staff may work during a period, which would otherwise be a rest break. In these circumstances, the member of staff and his/her line management should, wherever possible, allow him/her to take an equivalent period of compensatory rest.



The provisions of the WTR are a minimum requirement intended to ensure the protection of health & safety. A failure by an individual to take an in-work rest break (or by a line manager in not permitting a break or being aware that a break is not being taken) is likely to be relevant in a stress at work claim. Line managers can require an individual to take a break by way of an instruction to the individual. Individuals themselves cannot opt-out of rest breaks. A risk assessment may assist when considering individuals who regularly fail to take appropriate “in-work” rest breaks. Equally, an individual with a disclosed medical condition may need to be referred to the local OHA for advice around suitable breaks for the specific condition. Workers must be allowed any breaks they need as a result of any health condition or disability, or the MPS could be in breach of the Equality Act. Managers should consult OH for further advice.



A record of an in-work rest break must be kept as part of the overall record of hours worked. Breaks are not working time and therefore are relevant when calculating the daily/weekly hours worked.

Record keeping The Regulations require employers to keep records of work and retain those records for two years (from the date the record was made) to show that the limits relating to working time, night work and hazardous duties performed at night and the requirements for health assessments are being complied with. An up-to-date record of workers who have agreed to work more than 48 hours a week (the opt-out) needs to be kept locally, in Duties Offices, for two (from the date the record was made) years. The central records created around the opt-out will be kept for six years. Records of work need to be kept in every instance. Officers and Staff who have signed an opt-out are not exempted from this provision. If an individual is working excessive hours, there remains a duty of care towards them and such steps as referring them for a risk assessment is recommended. Advice may be obtained either from local risk assessment experts or from the PeopleStrategy - Health & Safety at ESB. An individual may be expected to sign an opt-out of the 48-hour average limit if they wish to undertake other employment which, when combined with their employment in the MPS, might lead to working longer than the 48 hour average. An opt-out may also be considered where an individual engages in a Business Interest, certain outside activity or voluntary work on a regular basis outside their usual duty/work time – see Annex E. Action to be taken 

Hours of duty must be recorded. For police officers working time must be shown on CARM. CARM managers with access to the 'Average Hours' report can use this to provide an indication if any officers have worked excessive hours. For police staff, local records must be kept to ensure that accurate times of work are recorded. All records of work should reflect the lunch and rest breaks actually taken. If no break is taken, the record of work should reflect that. In other words, the record of work should be a record of exactly what has taken place on any given day.

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Enforcement of the Regulations The Health and Safety Executive is responsible for the enforcement of the limits set out in the Regulations and fines may be imposed on organisations in breach of the Regulations. Where the Regulations confer entitlements and a detriment is suffered i.e. for insisting on taking entitlements to rest breaks and rest periods, disputes regarding annual leave and pay for or in lieu of leave, the remedy is by way of individual complaint to an Employment Tribunal. However, there is no direct Employment Tribunal remedy for infractions of the 48-hour week or restrictions on night work, or failure to offer health assessments. Complaint Individuals who wish to complain about a possible breach of the Working Time Regulations are encouraged to deal with this via the Fairness at Work Policy and Standard Operating Procedures. Monitoring The monitoring of all the provisions of the WTR resides with local managers. Benefits A motivated and alert workforce operates more effectively. Those officers and staff who regularly work long hours may become tired, which could affect their performance and service to the public. We recognise our duty to take all reasonable steps to protect the health and safety of our staff, and the health and safety of the public who may be affected by police activities. At the same time, there is a duty to provide a 24-hour emergency response service to the people of London, which may depend on police officers and police staff working longer than their conditioned hours of employment. We will always be expected to respond without question to emergencies and unpredictable operational demand. However, the Working Time Regulations give managers the opportunity to make sure that where there is a need for staff to work regular long hours, these are continuously and rigorously reviewed. The regulations allow for individuals to sign an “optout” agreement to exclude the 48-hour maximum weekly working limit. This should not, however, become normal practice nor is it an abrogation of responsibility that a line manager has under their duty of care. In other words, an opt-out will not protect managers where the Health & Safety of an individual officer or member of staff has been compromised. Responsibilities This document is owned by HR Board and was developed jointly by PeopleStrategy Employment Relations and PeopleServices Compensation and Benefits. Enquiries can be made to the PeopleSupport Advisory Centre in the first instance.

Associated documents and policies The Working Time Regulations 1998 (as amended) – Instructions for Managers contain important parts of the Regulations and detail actions that need to be taken. The WTR are complicated and open to interpretation. HR Directorate will inform the Service about further changes because of emerging case law, good practice from boroughs or branches, or as a result of further discussions with staff representative organisations. Police Regulations. Guidance on Hours Worked – Inspectors & Chief Inspectors (see Health, Safety and Wellbeing section of PeoplePages)

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Police Staff conditions of service. Health & Safety at Work Act 1974, the Police (Health and Safety) Act 1997 and all other relevant statutory provisions and recognised codes of practice. Health & Wellbeing Policy, associated SOPs and FAQs (see PeoplePages). Notices 14/12, 4 April 2012 - Mayor's Office for Policing and Crime and Metropolitan Police Service Health and Safety Policy. Safety, Health and Wellbeing pages on PeoplePages (including advice about Risk Assessments)

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Annex A Definition of Working Time and its method of calculation Reference periods The 17-week (or 26 week) reference period for police staff started from 27th March 2000 as per the collective agreement. th

In the case of police officers, it is a rolling 17 (or 26) week period from the 15 February 2006. Definition Working time is defined as any period during which a worker is working at his/her employer's disposal and carrying out his/her activity or duties. This will include any period during which a worker is receiving relevant training. The following circumstances will normally count as working time: 

On the exceptional occasions where staff are at the disposal of, and actively engaged on, the Service's business during their meal breaks and rest breaks;



Where staff are on call and actively working at the Service's disposal and performing their activities or duties, including travelling time when called out or where an officer or member of staff is required to be in attendance at a particular location for the purpose of performing duty;



Where staff are travelling in the exercise of their work duties, excluding time spent travelling between home and the normal place of work. An example would be travelling to a business meeting, court or such occasions as an individual may be required to work at, or report to, a location other than his or her normal place of work e.g. training courses.



Where work is performed away from the normal place of work on a basis agreed with the individual's manager and the time is properly recorded, e.g. welfare visits to staff at home, drafting a document at home;



Where staff are required to attend work-related functions as part of their duties; or



Where staff are spending agreed time carrying out staff association, trade union or health and safety responsibilities.

Calculating average weekly working time In order to establish whether an individual is exceeding or may exceed the permitted 48 hour average of working time, it is necessary to calculate the total working time over the reference period (see “weekly working time” for advice) or the period since the individual commenced work - if it is shorter in either case. The calculation is complicated by the necessity to take out of the total account any time spent on annual leave and sick leave etc. However, because the Regulations only provide for 5.6 weeks (28 days) paid annual leave, it is only the first 28 days of a worker's annual leave that will be "added on " to any calculation of average weekly working time. The definition of annual leave includes Bank Holidays and public holidays where they are given as paid leave. Any additional contractual annual leave over and above the first 5.6 weeks paid annual leave does not have to be added back to the reference period and therefore each day of additional holiday is effectively a credit against the maximum working time. The average weekly hours can be calculated as (A+B) divided by C: A+B

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C Where  



A is the total number of hours worked during the reference period B is the total number of hours worked, immediately after the reference period. In other words, you extend the reference period by the number of working days equal to the number of days missed due to  (i) the first 5.6 weeks (or 28 days) of annual leave in any year provided for in the Regulations; or  (ii) sick leave; or  (iii) maternity leave; maternity support leave, adoption or parental leave. C is the number of weeks in the reference period.

Worked example A worker has a standard working week of 36 hours net and does overtime of 20 hours per week for the first 10 weeks of the 17-week period. The first five days of his 28 days annual leave entitlement is also taken during the reference period. The total hours worked in the reference period is 16 weeks (of 36 hours per week) and 20 hours overtime for 10 weeks: (16 x 36) + (10 x 20) = 776 hours To this must be added the five days of his annual leave entitlement (i.e. by adding the first five working days after the reference period). If the worker does no overtime, 36 hours must be added to the total, making a grand total of 812 hours. Therefore the average is the total number of hours divided by the number of weeks: 812 divided by 17 = 47.77 hours. The average of 48 hours has not been exceeded. If the first five days annual leave did not have to be added because the individual's statutory annual leave entitlement (including Bank Holidays) was exhausted, the calculation would have been: 776 divided by 17 = 45.65 hours. The average of 48 hours has not been exceeded.

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Annex B Annual leave entitlement-(termination of employment) Leave entitlement due should be calculated using the following formula: (the formula for calculating pro rata annual leave in the "Planned Retirement SOP" under the Leaving the Service Policy on PeoplePages should give the same result). (AxB) –C where; A is the amount of leave, which the worker is entitled to in a leave year (see the Planned Retirement (Officer or Staff)SOP for further advice); * B is the proportion of the worker's leave year which expired before their employment ended; and C is the amount of leave taken by the worker between the start of the leave year and the effective date of termination. The leave year for police officers will be the MPS leave year (April to March). The leave year for police staff will also be from April to March. Managers and relevant HR staff must follow the procedures outlined in the above SOP. Logica will pay out on the following formula: Calculation of a day's pay for untaken annual leave for full time police officers will be as follows: Annual pensionable salary (basic pay plus London Weighting) divided by 52.166 divided by 5 The calculation for part time police officers will be: Annual pensionable salary divided by 52.166 multiplied by the appropriate factor divided by 5. (The appropriate factor is the proportion of the full time hours worked). The calculation for full time police staff will be: Annual salary

x number of days untaken annual leave 261

(261 represents the number of working days in a year. There are 52.2 weeks in a year and five days in each week - 52.2 x 5 = 261). Payment for part time police staff is calculated using their hourly rate. Detailed advice about these calculations should be directed to Logica.

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Annex C Dear RE: WORKING TIME REGULATIONS 1998 –The weekly working time limit The Working Time Regulations came into force on 1st October 1998. Regulation 4 provides that "a worker's working time, including overtime, in any reference period, which is applicable in his case, shall not exceed an average of 48 hours for each 7 days". This average is normally taken over a rolling 17 week period (or 26 weeks where Regulation 21 applies) and excludes any period of annual leave provided for within the Regulations, sick leave or maternity leave, maternity support leave, adoption or parental leave. The Regulations provide that the maximum working week requirement will not apply to any worker who agrees in writing with his or her employer that the limit will not apply in his or her case. There is no obligation to agree to work more than the average 48 hours a week and you will suffer no detriment if you do not wish to do so. It is therefore entirely a matter for each individual whether to complete the opt out agreement on HR Self Service to work more than an average of 48 hours a week. However, if you have not signed such an agreement you must not exceed this limit. If you are currently working more than the 48-hour average over the specified period and wish to continue to do so, you are advised to sign the attached agreement. You will appreciate that if you have not signed such an agreement, you will not be permitted to work overtime that would take you above the permitted maximum average working week. However, you should also appreciate that the opt out agreement gives you no entitlement to any particular level of overtime, or indeed any overtime. The opt-out agreement must be completed via Employee Self Service. If you complete the agreement, you will be expected to give one month's notice should you wish to terminate it, the termination date should be entered on the original opt out agreement using Employee Self Service. If you wish to substitute a shorter notice period you are legally entitled to do so, subject to this period being at least 7 days. However, for reasons of efficient administration, the full one-month's notice is preferred. Finally, you should note that the Commissioner has a legal duty as an employer to take all reasonable steps to protect the health and safety of all his staff. In accordance with this general principle, it is the view of the Service that individuals should not ordinarily be exceeding the average maximum working week of 48 hours on a regular basis, even voluntarily. Yours sincerely

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Annex D

Health Assessment Questionnaire for Night Workers Form 6030 can be found on the Forms Unit website.

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Annex E VOLUNTARY WORK OUTSIDE WORKING HOURS OR DUTY TIME The Working Time (Amendment) Regulations 2006 removed the 'partly unmeasured working time' exemption in Regulation 20 of the WTR. As a result, legal advice indicates that voluntary work outside (and in addition to) working hours or duty time may now come under the auspices of the Working Time Regulations (WTR) in respect of the maximum 48 hour working week. Voluntary activities would include regular time given to the Reserve Forces, charities, school governors, youth work etc. It does not include hobbies or activities that are occasional or of limited duration. The maximum 48-hour working week is measured over a 17-week reference period. This period can be extended to 26-weeks in certain circumstances (see “weekly working time limit” earlier in this document). Some police activity is exempted altogether from the calculation of the maximum working week. Advice in respect of reference periods and exemptions can be found earlier in this document. No significant extra work should be required as a result of this legal development. Arrangements should already be in place to ensure that working hours are monitored to ensure compliance under the WTR. However, those directly involved in this process (including line managers) should make arrangements to ensure that relevant voluntary activities are now included in any calculation towards the maximum working week. Managers should be aware that it is a requirement, under Regulation 9 the WTR, to keep records of work in every instance. This would include officers and police staff that have signed an opt-out agreement. In other words, this development also affects this group of individuals. Voluntary hours must not be entered into CARM, or any other time management system, but kept separately as a manual record. Action: Police Officers and Police Staff must notify Duties Offices/line managers (as appropriate) in instances where they are likely to exceed the maximum working week as a result of the combined time spent on voluntary work and duty time/working hours. For those where the combined weekly hours of duty/working time and voluntary work exceed 48 hours in the averaging period, such individuals should be asked to opt out via Employee Self Service. In addition to the above, officers and staff who are "vocational drivers" for the MPS (exclusively drivers of vehicles that require tachographs), and who are engaged on any weekly voluntary activity (whether driving or not) may not be achieving the required daily or weekly rest under the WTR. Affected police officers and police staff must notify their Duties Offices/line managers (as appropriate) if they fall into this category. Line management should monitor the position in case the cumulative hours performed by the individual are excessive or should they become unfit to perform their duties. If the officer or member of police staff drives for the MPS but is not a vocational driver, as defined above, this change does not affect them.

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Protective Marking

NOT PROTECTIVELY MARKED

Publication Scheme Y/N Title

N

Version Summary Branch / OCU Author Date created

Guidance on hours worked – Inspectors and Chief Inspectors 1.0 Guidance notes HR Pay and Allowances Policy Tim Bamforth-White, HR Pay & Allowances Branch st

1 August 2005

Guidance On Hours Worked – Inspectors & Chief Inspectors HR Pay & Allowances Policy Branch

Version: 1.0 st

Date Last Reviewed: 1 August 2005

Table of contents 1. 2. 3. 4.

Introduction ....................................................................................................................... 3 Application of Working Time Regulations........................................................................... 3 Guidance on number of hours worked ............................................................................... 4 Frequently Asked Questions.............................................................................................. 5 Question 1...................................................................................................................... 5 Answer........................................................................................................................... 5 Question 2...................................................................................................................... 5 Answer........................................................................................................................... 5 Question 3...................................................................................................................... 5 Answer........................................................................................................................... 5 Question 4...................................................................................................................... 5 Answer........................................................................................................................... 5 Question 5...................................................................................................................... 6 Answer........................................................................................................................... 6 Question 6...................................................................................................................... 6 Answer........................................................................................................................... 6 Question 7...................................................................................................................... 6 Answer........................................................................................................................... 6 Question 8...................................................................................................................... 6 Answer........................................................................................................................... 6 Question 9...................................................................................................................... 6 Answer........................................................................................................................... 7 5. Further information and advice .......................................................................................... 7

1. Introduction 1.1 Concern has frequently been expressed about the number of hours officers in Inspecting ranks are expected to work. This guidance is intended to assist those concerned and provide practical examples of how to mitigate against long hours. 1.2 Line managers should assume that the normal working week for Inspecting ranks is 40 hours. A higher limit of an average of 48 hours per week is however provided by the Working Time Regulations (WTR), when averaged over a reference period – see below. Unless agreement has been reached on a variable shift arrangement (VSA) or flexible roster, this would normally be comprised of 5 working days and 2 rest days. 1.3 Managers should recognise the need for Inspecting ranks to be able to plan, with a degree of certainty, both for their work commitments and for their personal commitments. Without overlooking urgent operational requirements of duty, managers should take into account these factors when considering hours worked, on call arrangements and rest day cancellations. 1.4 Long hours worked, as a matter of course might be contrary to the intention and the spirit of the agreement reached in Police Negotiating Board at the time that changes to Inspecting ranks’ hours and conditions of working were introduced. 2. Application of Working Time Regulations 2.1 The WTR apply to police officers. They limit the number of hours an individual should be working to 48 per week averaged over a reference period. It would not be a breach of the WTR for an officer to work 50 hours in one week, provided that, over the reference period, he or she averaged no more than 48 hours. 2.2 In normal circumstances, the reference period is 17 weeks, but can be extended to any period up to 52 weeks provided it is agreed in advance. For a VSA and a flexible roster, the reference period would normally be the cycle of the roster. Extensions should not be agreed merely to ensure a longer period over which to calculate average hours worked. 2.3 The WTR also provide for rest breaks of at least 11 hours between tours of duty, subject to later compensatory rest periods if on specific occasions such a break cannot be taken. WTR also provide for the taking of one non-working day per week averaged over the reference period ie if the reference period is 17 weeks then 17 non-working days must be recorded within that period. A non-working day could be a rest day, Annual Leave or Special Leave. 2.4 Managers must keep records of hours worked by all staff. Likewise, Inspectors and Chief Inspectors are required to record their hours of duty, either electronically (e.g. MetDuties, PDA’s, etc), or on manual duty state systems. 2.5 Hours of duty should also be recorded in CARM, Computer Aided Resource Management, which is currently the corporate resource management system for the MPS. CARM provides managers with access to the “Average Hours” report to provide an indication if any officers have worked excessive hours under the WTR limits. 2.6 Individual officers may presently seek, prior to the reference period, to opt out of the 48hour weekly average set by the WTR and management may seek individuals’ agreement to an opt-out. Management though cannot impose opt-out agreements on individuals. Opt-out agreements must be in writing and can be of indefinite duration. In general, however, the MPS would not wish to have significant numbers of opt-out agreements of indefinite duration; they should be used to cover specific circumstances affecting particular officers.

3. Guidance on number of hours worked 3.1 As specified earlier, line managers should consider the normal working week to be 40 hours. Whilst officers can be required to work beyond those hours, the requirement to work should not become the norm, be abused or become regular and expected. 3.2 Where it is necessary for additional hours to be worked, officers should be limited to the average of 48 hours per week over the appropriate reference period as provided for by the WTR. It could be a criminal / disciplinary offence for a manager to permit hours above the WTR limit. 3.3 Officers who are aware that they have reached the 48 hours prescribed by the WTR th cannot decline to continue working into the 49 hour. In such circumstances, officers should bring the number of hours worked to the attention of their managers who should ensure that compensatory arrangements are made to reduce the average to the 48-hour limit. 3.4 In practice, therefore, it would not be appropriate for an officer to claim that he or she cannot work beyond 48 hours in a single week. Any additional hours should be compensated for over the reference period by fewer hours in other weeks. 3.5 Similarly, an officer who works 40 hours in four days cannot automatically expect to have the fifth day off, particularly if that day is a normal duty day. However, with line manager’s authority, if an officer works, or anticipates working a longer shift, they may be granted, subject to the exigencies of duty, permission to work a shorter day subsequently in the working week or take an outstanding rest day, to ensure the average hours stay below the prescribed WTR limit.

4. Frequently Asked Questions Question 1 Are Inspecting ranks required to work five 8hr days? Answer Unless other arrangements exist, e.g. Inspecting ranks working a variable shift arrangement (VSA) or flexible roster, line managers should assume, as per item 3 above, that the working week is 40hrs, comprised of 5 working days and 2 rest days and the hours worked each working day can be subject of negotiation between the individual and line manager. Question 2 What happens if an Inspecting rank works (or plans to work) 4 long shift days (40hrs or more), can they have the fifth day off? Answer No. They are expected to work 5 days in a week. The options of leave or a compensatory rest day are available however, as would be the option of special leave, if line managers consider it is a welfare or health & safety issue. Question 3 Can the hours in one week be balanced into the next week? Answer For the purposes of the WTR, hours worked would need to be monitored as a matter of routine and would be taken as an average over the reference period, so an element of balancing hours already exists which could be applied to the normal working week. In not monitoring hours worked, it would increase the risk of officers working in excess of the 48hr week average imposed by the WTR. Question 4 An Inspector is asked, with 3 weeks notice, to cover Night Duty Inspector on Friday, Saturday and Sunday evening. The officer had planned to work Monday-Friday of that week. Answer The officer could negotiate, if it is practical for them and the OCU to do so, to take rest days on the Monday and Tuesday, work the remainder of the week as night duty and then have rest days again on the following Monday and Tuesday. Alternatively, the officer could agree to work on Monday – Thursday and then the night duty from Friday-Sunday, with compensatory rest days on the following Monday and Tuesday. A variation on the above would be to work on Monday-Wednesday, take a rest day on Thursday; work night duty Friday-Sunday, with compensatory rest days on the following Monday and Tuesday. The aim should be to maintain the requirement of 5 working days and 2 rest days in each week. Where this is not possible, line managers should arrange for appropriate compensatory rest days as soon as practically possible.

Question 5 A Chief Inspector, who on average has worked just over the 48hr threshold for a period of 16 weeks (48.25hrs), has in the 17th week, worked 44hrs in 4 days and is rostered to work an 8hr tour of duty on the fifth day. Answer At this point the Chief Inspector has reached the limit provided by WTR (816 hours). Unless the Chief Inspector agreed to voluntarily taking the option of either leave or a compensatory rest day the only option open to the line manager to remain within the WTR limit would be to grant Special Leave for the fifth day. Question 6 An Inspector, having already worked 40hrs from Monday-Thursday in a week, is required (at short notice) to cover 12hr night duty shifts on Saturday and Sunday. Answer The Inspector has, subject to agreement with the line manager, a number of options available. The Inspector could take the Friday off as one of the 2 rest days in that week and work the th Saturday as the 5 working day. The Sunday would be a cancelled rest day to be taken within the following 12 months. The hours worked would then be balanced within the reference period by reduced hours in other weeks. The Inspector could work the Friday as the 5th working day then both Saturday and Sunday would be cancelled rest days to be taken within the following 12 months. The hours worked would then be balanced within the reference period by reduced hours in other weeks. Question 7 Within what period should any outstanding rest day be taken by Inspecting ranks? Answer Inspecting ranks outstanding rest days must be taken within 12 months of the date of cancellation of the original rest day. If they are not taken within this period, they are lost (and should be shown as such in CARM). Question 8 What happens to outstanding rest days when an officer transfers to another OCU? Answer Normally officers should not be allowed to accumulate rest days (see item 2.3) The existing OCU and individual officer should make every practical effort to take outstanding rest days before transferring, but this may not always be possible. (Officers could consider “backfilling” leave applications to clear outstanding rest days, assuming there is sufficient time to take the remaining leave entitlement – or carry over additional days). In cases where it may not be possible to take all outstanding rest days, it is advisable to inform the new “owning” OCU and make the necessary arrangements to take outstanding days as soon as practicable. Question 9 When a rest day is cancelled for an Inspecting rank, do they have to work for at least 8hrs?

Answer No. Earlier answers provide the requirement for Inspecting ranks to work a minimum of 40hrs in a week, usually over 5 working days. Working on a rest day would be an additional requirement and could potentially take an officer over the 48hr weekly limit prescribed by the working time regulations. Receipt of a compensatory rest day, on a day on which the officer would otherwise have worked would help to ensure the average hours remain below the WTR limit. 5. Further information and advice Information about the implications of and requirements arising from the WTR can be found on the AskHR website. Managers who seek further advice should contact Simon Hockley, HR Policy Development, on extn 780420. Further information about the content of this document can be obtained from Tim BamforthWhite, HR Pay & Allowances Policy Branch, on extn 780530.

Form 143A

METROPOLITAN POLICE SERVICE MEMORANDUM To:

Borough and HQ OCU Commanders

Cc:

HR Managers

Date: 07 September 2005 From:

Martin Tiplady Director of HR

Telephone Extn. No.: (Police Network) 63004 INSPECTING RANKS – WORKING HOURS There have been a number of meetings in recent months between HR Directorate and the Federation’s Inspectors’ Branch Board (IBB) about the number of hours worked by Inspectors and Chief Inspectors. The IBB expressed its concerns that many officers are working hours in excess of the expected 40 per week and, more importantly, in excess of the 48 per week laid down by the Working Time Regulations (WTR). It was not intended by the Police Negotiating Board that the changes to Inspecting ranks’ terms and conditions introduced in 1994 should result in these officers having to work long hours. The attached guidance therefore, which the IBB will also be circulating to their members, is intended to present a protocol for managing more effectively the work/life balance for Inspecting ranks, specifically covering hours of duty, rest days and the requirements of the WTR. The WTR specify that workers (which include police officers) should not exceed an average of 48 hours per week over a specified reference period. That reference period is generally 17 weeks, unless a longer period has been agreed in advance of the start of the reference period. HR Pay Policy have provided HR managers with details of officers whose working hours are in excess of the 48 hours average, as recorded on CARM over three reference periods; and asked that they discuss with senior management how best to ensure that these officers’ working hours are brought within the requirements of the Regulations. Unfortunately, there is evidence that actual hours worked by Inspectors and Chief Inspectors are not being shown on CARM, with the suggestion that in some cases there is significant under or inaccurate recording. I shall be grateful, therefore, if you will take steps to ensure that (a) Duty states and CARM records for Inspectors and Chief Inspectors match and reflect actual hours worked; (b) Details of officers who have opted out are (if not already done so) provided to Simon Hockley, Head of HR Policy Development (c) Working hours for Inspectors and Chief Inspectors are normally 40 per week but in any event do not exceed the average of 48 over a reference period. In some cases, there may be good reasons for specific officers “opting out” of the average hours requirement and we have previously asked HR managers to provide details of such officers. It should be noted that the possibility of opting out is a voluntary one and must be with the full written agreement of the officer concerned, should only be used in exceptional cases and is not retrospective. If you have any questions or would like to discuss in further detail please contact me. . Martin Tiplady

M.P. 82(E)

RESTRICTED Form 6030 Part A

Health Assessment Questionnaire for Night Workers This questionnaire is an optional requirement under the Working Time Regulations for people who regularly do night work. It forms part of the health assessment required under the Regulations to determine whether you are fit to undertake the night work to which you have been assigned (the Regulations define night time as the period between 23.00 and 06.00).

Personal Details Name Warrant / Pay No. Rank / Grade BOCU / Branch Home Address Post Code Telephone No. Date of Birth Male / Female

Do you suffer from any of the following medical conditions? If so, please give details with dates and medication on the back of this form Please put a cross (X) in the relevant box

No

1

Diabetes requiring medication with insulin

2

Any digestive disorder that requires you to take regular meals on medical advice

3

Any significant sleep disorder requiring treatment

4

Any heart condition that causes you troublesome symptoms at night

5

Any chest conditions that are made worse at night

6

Have you any other medical condition and or are taking medication that may be adversely affected by working at night?

7

Are you suffering from any symptoms that you think may be caused or worsened by you performing night work?

8

Are you having any treatment or investigations of any kind at the moment?

9

Are you suffering from : Depression, Nervous Disorder, Psychological Problems? 1

Yes

RESTRICTED

If you crossed any of the YES boxes, this will not necessarily mean that you are unfit to perform night work. However, you may be required to undergo a further medical assessment. The completed questionnaire should be sent in a sealed envelope marked “Medical in Confidence” to your OHA. Please mark clearly on the outside of the envelope your BOCU / Branch and the letters WTR to identify it as related to the Working Time Regulations. Under Regulation 7(5) of the Working Time Regulations this health assessment cannot be discussed with any third party without your written consent. However, this does not prevent the disclosure of a simple statement to the effect that you are fit / unfit to carry out night work. Please put below any details of medical conditions that you have answered YES to overleaf. Please number your answers according to the number of the appropriate questions (ie if you have a diabetic condition, label your answer 1., etc).

This form will be filed on your OH medical file

Signed:

Date: 2

RESTRICTED Form 6030 Part 2

Night Workers Health Assessment To be completed by the OHA To the Personnel Manager

BOCU / Business Unit:

Personal Details Name Warrant / Pay No. Rank / Grade BOCU / Branch Home Address Post Code Telephone No. Date of Birth

The above named officer has completed a night workers health questionnaire from which we advise: Please put a cross (X) in the relevant box 1

The individual appears fit to undertake / continue night work at present

2

There are health problems that require further investigation. Please refer to OH on Form 6112

3

The individual is unfit to continue night work

Health Assessment completed by: Signed:

Date:

If it is appropriate under the terms of the Medical Reports Act 1988 and the Access to Health Records Act 1990 to apply for the release of personal medical information with your consent you may be asked to complete a consent form to access information. Copy: Medical File Retention Period: Life of OH medical file MP 224/09

3

RESTRICTED Form 6030 Part A

Health Assessment Questionnaire for Night Workers This questionnaire is an optional requirement under the Working Time Regulations for people who regularly do night work. It forms part of the health assessment required under the Regulations to determine whether you are fit to undertake the night work to which you have been assigned (the Regulations define night time as the period between 23.00 and 06.00).

Personal Details Name Warrant / Pay No. Rank / Grade BOCU / Branch Home Address Post Code Telephone No. Date of Birth Male / Female

Do you suffer from any of the following medical conditions? If so, please give details with dates and medication on the back of this form Please put a cross (X) in the relevant box

No

1

Diabetes requiring medication with insulin

2

Any digestive disorder that requires you to take regular meals on medical advice

3

Any significant sleep disorder requiring treatment

4

Any heart condition that causes you troublesome symptoms at night

5

Any chest conditions that are made worse at night

6

Have you any other medical condition and or are taking medication that may be adversely affected by working at night?

7

Are you suffering from any symptoms that you think may be caused or worsened by you performing night work?

8

Are you having any treatment or investigations of any kind at the moment?

9

Are you suffering from : Depression, Nervous Disorder, Psychological Problems? 1

Yes

RESTRICTED

If you crossed any of the YES boxes, this will not necessarily mean that you are unfit to perform night work. However, you may be required to undergo a further medical assessment. The completed questionnaire should be sent in a sealed envelope marked “Medical in Confidence” to your OHA. Please mark clearly on the outside of the envelope your BOCU / Branch and the letters WTR to identify it as related to the Working Time Regulations. Under Regulation 7(5) of the Working Time Regulations this health assessment cannot be discussed with any third party without your written consent. However, this does not prevent the disclosure of a simple statement to the effect that you are fit / unfit to carry out night work. Please put below any details of medical conditions that you have answered YES to overleaf. Please number your answers according to the number of the appropriate questions (ie if you have a diabetic condition, label your answer 1., etc).

This form will be filed on your OH medical file

Signed:

Date: 2

RESTRICTED Form 6030 Part 2

Night Workers Health Assessment To be completed by the OHA To the Personnel Manager

BOCU / Business Unit:

Personal Details Name Warrant / Pay No. Rank / Grade BOCU / Branch Home Address Post Code Telephone No. Date of Birth

The above named officer has completed a night workers health questionnaire from which we advise: Please put a cross (X) in the relevant box 1

The individual appears fit to undertake / continue night work at present

2

There are health problems that require further investigation. Please refer to OH on Form 6112

3

The individual is unfit to continue night work

Health Assessment completed by: Signed:

Date:

If it is appropriate under the terms of the Medical Reports Act 1988 and the Access to Health Records Act 1990 to apply for the release of personal medical information with your consent you may be asked to complete a consent form to access information. Copy: Medical File Retention Period: Life of OH medical file MP 224/09

3

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