As we move towards the final quarter of 2026, recent HSE enforcement cases provide some important reminders for employers about the need to ensure that health and safety arrangements are not only documented, but are implemented effectively and regularly checked in practice. This update highlights some of the key issues currently attracting attention and provides a short checklist for businesses to review their own arrangements.
HSE enforcement: what can we learn?
Recent HSE prosecutions demonstrate that relatively familiar workplace activities can result in serious injuries where basic controls are missing or ineffective.
Machinery guarding: remains a significant risk
A Merseyside manufacturer was fined £160,000 after a maintenance engineer suffered life-changing injuries when his arm was pulled into an unguarded conveyor. The HSE found that workers could reach dangerous parts of machinery through an unauthorized opening. Importantly, the company already had risk assessments, safe systems of work, inspections, management walkarounds and audits. The case demonstrates that having the correct paperwork does not, by itself, demonstrate effective control.
Action for employers
Consider carrying out a physical inspection of your machinery and ask:
- Can dangerous moving parts be accessed?
- Are guards securely fixed?
- Do interlocks and emergency stops work correctly?
- Can machinery start unexpectedly?
- Are isolation and lock-off arrangements effective?
- Do cleaning and maintenance activities have adequate controls?
- Have previous modifications to machinery been properly assessed?
Remember: risk assessments should reflect the machinery and processes that actually exist today — not simply those originally assessed.
Work at height: the basics still matter
A construction company recently received a £300,000 fine after a 24-year-old worker suffered serious spinal injuries following a fall through an unprotected stairwell opening. The HSE identified failures in the planning, supervision and control of work at height. Measures such as securing the opening or providing suitable edge protection could have prevented the fall.
A quick work at height check
Where work at height takes place, ensure the following:
- Plan: the work is properly planned and risk assessed.
- Prevent: suitable measures prevent falls wherever reasonably practicable.
- Protect: where falls cannot be eliminated, appropriate collective or personal protection is in place.
- Supervise: the work has adequate supervision and workers are competent.
- Review: controls are reviewed when circumstances or site conditions change.
Temporary openings, fragile surfaces, ladders, scaffolds, roofs and MEWPs should all form part of the review.
Lifting operations: don’t let “routine” mean “unplanned”
The HSE recently reported a case where a 1.2-tonne crate fell from a forklift, resulting in life-changing injuries. The investigation found that the unloading operation was poorly planned, inadequately assessed and unsupervised. The case highlights the importance of properly managing non-standard lifting operations.
Businesses should ensure that lifting operations are appropriately:
- Planned and risk assessed
- Supervised
- Undertaken by competent persons
- Supported by suitable equipment
- Conducted within safe working loads
- Segregated from people where appropriate
Particular care should be taken where a delivery or lifting operation is unusual or differs from the normal process.
Current regulatory focus: work-related ill health
Work-related ill health remains a key priority for the HSE. Their 2026–27 regulatory goals include a specific focus on reducing work-related ill health, covering occupational health, work-related stress and mental health and RIDDOR, alongside targeted intervention and inspection activity. As a result, employers should avoid concentrating solely on traditional accident hazards.
Consider whether your organisation actively manages the following health risks:
- Stress and mental health
- Musculoskeletal disorders
- Manual handling
- Noise
- Hand-arm vibration
- Respiratory exposure
- Occupational dermatitis
- Fatigue and workload
Consultant’s tip
When reviewing your risk assessments, ask: “Could this job make someone ill over time, even if nobody is injured today?” This simple question helps identify health risks that might otherwise go unnoticed.
Martyn’s Law: are you ready?
The Terrorism (Protection of Premises) Act 2025, commonly known as Martyn’s Law, introduces new requirements for certain premises and events to improve preparedness for terrorist attacks. The legislation currently expects to come into force in spring 2027, with the Security Industry Authority (SIA) acting as regulator. Preparatory work is already underway, including pilot inspections and development of the notification system.
Businesses potentially within scope should now consider the following:
- Whether their premises or events fall within the legislation
- Who holds responsibility for compliance
- Existing emergency arrangements
- Evacuation and invacuation arrangements
- Staff awareness and training
- Communication arrangements
- Coordination with relevant stakeholders
- How security considerations integrate with existing emergency plans
The Home Office published updated statutory guidance in August 2026 to help organisations understand whether they fall within scope and how to prepare. Don’t wait until commencement to start reviewing your arrangements.
Your September health and safety check
We recommend that management teams take 30 minutes this month to work through the following questions:
- Machinery: can anyone access dangerous moving parts?
- Work at height: are openings, edges and fragile surfaces adequately protected?
- Lifting: are non-routine lifting operations properly planned?
- Risk assessments: do they reflect what actually happens today?
- Health risks: are stress, MSDs, noise, vibration and exposure risks actively managed?
- Emergency planning: are emergency arrangements current and tested?
- Martyn’s Law: have you established whether your organisation may fall within scope?
Our recommendation
As we approach the end of 2026, now is a good time to carry out a short health and safety management review. In particular, consider whether any of the following changes have occurred:
- Changes to premises, equipment or processes
- New employees or changes in competence
- Changes to contractors or suppliers
- New substances or materials
- Changes in working arrangements
- Accidents, incidents or near misses
- Changes in legislation or guidance
- Changes to emergency arrangements
Even relatively small operational changes can introduce new risks and may require existing risk assessments and procedures to be reviewed.
Need help with your health and safety arrangements?
Our team of experienced consultants provides practical support across all areas of health and safety, including:
- Health and safety audits
- Risk assessments
- COSHH assessments
- Machinery safety
- Work at height
- Fire safety
- Construction health and safety
- Contractor management
- Training and competence
- Emergency planning
- Health and safety policies and procedures
- Martyn’s Law preparation
If you have any concerns about your current arrangements or would like assistance reviewing your health and safety compliance, please get in touch on 0161 926 8519 or visit our contact page.