(Posted on the HSE web site 3 July 2002)

This guide has been prepared for all providers of first-aid at work training (both onshore and offshore) and providers of medical training (offshore installations only) who have an interest in how the charging scheme will operate. It explains how charges will be made and gives an indication of the individual charge an operator may have to pay.

1 The report of the first stage of the Government's Quinquennial Review of the Health and Safety Commission (HSC) and Health and Safety Executive (HSE) recommended that charging proposals should be formulated in respect of those 'permissioning' functions that fell within existing HSC/E charging policy but for which no charge was currently made. 'Permissioning' functions, including certification, licensing and approvals, fall within the boundary of current charging policy. The HSC, having considered the findings of HSE feasibility studies which examined the extension of charging to such activities, concluded that charging should be introduced for the approval of the:

first-aid at work training function carried out by HSE under the Health and Safety (First-Aid) Regulations 1981 (the 1981 Regulations); and

first-aid at work and medical training functions under the Offshore Installations and Pipeline Works (First-Aid) Regulations 1989 (the 1989 Regulations).

Charging for the 1981 Regulations commenced from 10 October 2000 and for the 1989 Regulations from 2 April 2002.

2 The 1981 and 1989 Regulations place a duty on employers to make first-aid provision for their employees. The 1989 Regulations place a duty on employers to make first-aid and medical provisions for their employees. These regulations require employers to provide such number of suitable persons as is adequate and appropriate for rendering such assistance to their employees if they are injured or become ill at work and state that such persons shall not be suitable unless they have undergone training and obtained the necessary qualifications approved by HSE. For this purpose HSE approves training and qualifications. The details of the functions carried out by or on behalf of HSE under both sets of regulations are set out at paragraph 6.

3 Regulation 23, regulation 24 and supplementary provisions in regulation 25 of The Health and Safety (Fees) Regulations 2002 (see Annex C) gives HSE the power to charge persons/businesses applying for approval of training for the assessment of the approval application, the renewal of an approval and any subsequent visits to ascertain whether standards are being maintained. These regulations came in to force on 2 April 2002.

4 HSE, having examined the feasibility of various charging options and assessed their impact on health and safety best practice, their transparency and predictability to those who will have to pay the charge and their practicability, recommended to HSC that a system of fixed rate fees should be introduced for training approval functions and that these fees should be reviewed and updated annually. The HSC endorsed these proposals in November 1999 for the 1981 Regulations and August 2001 for the 1989 Regulations and Ministers have subsequently approved them. The costs have been calculated in accordance with Treasury rules and guidance. Details of these costs are given at paragraph 10.

Background

5 HSE is required by Government to recover the costs of performing the regulatory activities that will fall under the 1981 and 1989 Regulations through charges.

Chargeable activities

6 The charges will cover the following functions (Annex A sets out examples of these activities in greater detail):

a) original approval:

1. application for an 'original' approval which includes the 'original approval assessment visit' carried out prior to approval being granted and the 'original approval monitoring visit' carried out immediately post approval. (The costs of both these visits are included in the original approval fee);
2. an additional site-visit where a shortcoming in the training is identified during a site-visit;

b) post approval monitoring visits to ensure training standards that form part of the terms of the approval are being maintained:

1. 'initial visit' to ensure required standards are being maintained;
2. where there is a shortcoming in the training provision, an additional visit;

c) applications for renewal of approval.

Charges

7 A system of predetermined, set fees for training approvals, with discounts for multiple approvals applications, has been put in place. The fees reflect the actual cost to HSE of performing the functions. The fees have a sufficiently close relationship to the actual costs of the function being performed by HSE, on behalf of that particular training organisation, to be designated as a charge and to fall within HSE's existing charging powers. Flat rate fees linked to the approvals function will help providers plan by providing predictability and will assist HSE in recovering the relevant costs incurred. The way in which HSE has approached the identification of the relevant costs for inclusion in the fees follows the guidance in HM Treasury's Fees and Charges Guide1.

8 From 2 April 2002, the fees charged for single and multiple applications for approval are set out below.

Single 'original' and renewal applications and site-visits

(i) The fee for an application for an 'original' or first approval will cover all assessment activity including the 'original approval assessment visit' and the 'original approval monitoring visit' which is undertaken as soon as is practicable after the original approval has been granted by HSE:

first-aid training - £890;
medical training - £1,305;

(ii) where a shortcoming in the training is identified during a site-visit, an additional site-visit will be required to ascertain that the shortcoming has been addressed before the approval can be granted. The applicant will be charged an additional fee for such a visit:

first-aid training - £320;
medical training - £845;

(iii) post-approval monitoring site-visits to approved training organisations/persons are undertaken to ensure training standards that form part of the terms of the approval are being maintained. A fee will be payable for:

a) 'initial visit' to ensure required standards are being maintained:

first-aid training - £355;
medical training - £845;

b) those cases where an additional visit is considered necessary because a shortcoming in training provision has been identified:

first-aid training - £320;
medical training - £845;

c) should a visit be made to monitor standards for both first-aid and medical training, and this takes less than one day, a discount will be made of £150;

(iv) applications for renewal of first-aid and medical training approval certificates, which have a five year duration, incur a charge of £62.

Multiple 'original' applications

(v) Should the training provider apply for a second 'original' approval for first-aid training provision, or make two 'original' applications for first-aid training simultaneously, a discount will be made from the 'original' application of £150. Should the training provider holding an approval for first-aid training provision, subsequently apply for an approval for medical training provision, a discount will be made from the 'original' application of a further £50;

(vi) should the training provider apply for a second 'original' approval for medical training provision, or make two 'original' applications for medical training and first-aid training simultaneously, a discount will be made of £50. Should the training provider holding an approval for first-aid or medical training provision, subsequently apply for an approval for first-aid training provision, a discount will be made from the 'original' application of a further £150;

(vii) should the training provider apply for a second 'original' approval for first-aid provision, or make two 'original' applications, one for first-aid training and the other for medical training provision simultaneously, a discount shall be made from the 'original' application of £50. Should the training provider holding an approval for first-aid or medical training provision, subsequently apply for an approval for first-aid training provision, a discount will be made from the 'original' application of a further £150;

(viii) should the training provider apply for two 'original' approvals for first-aid training provision and also for medical training provision, a discount will be made of £200;

(ix) the table, below, summarises the discounts for multiple 'original' applications for the various combinations of first-aid and medical training:

	Application	Total Discount	Resultant fee	Guide ref.
1	Two simultaneous 'original' applications for first-aid training.	£150	£1,630	8 (v)
2	An 'original' application for first-aid training followed later by an 'original' application for another type of first-aid training.	£150	£1,630	8 (v)
3	An 'original' application for first-aid training followed later by an original application for medical training.	£50	£2,145	8 (v)
4	Two simultaneous 'original' applications for first-aid training followed later by an original application for medical training.	£200	£2,885	8 (v)
5	Two simultaneous 'original' applications, one each for "first-aid" and "medical" training.	£50	£2,145	8 (vi), 8 (vii)
6	An 'original' application for medical training followed by an 'original' application for first-aid training.	£50	£2,145	8 (vi)
7	An 'original' application for first-aid training following two 'original' applications, one for first-aid training and one for medical training.	£200	£2,885	8 (vi)
8	An 'original' approval for medical training, followed by two 'original' applications for first-aid training.	£200	£2,885	8 (vii)
9	Two 'original' applications for first-aid training and an application for medical training simultaneously.	£200	£2,885	8 (xiii)

Who will be subject to the charge?

9 Charges will fall to the person or business who makes an application to the Executive for an original approval of training or a renewal of an approval of training under regulation 3(2)(a) of the 1981 Regulations and regulation 5(2)(a) of the 1989 Regulations.

Methodology used for calculating charges

10 The fee is calculated on the basis of the full cost of HSE's First Aid Approvals and Monitoring Section (FAAMS) and the actual cost per visit carried out by HSE's contractor. The costs for each of the four functions identified in paragraph 8 above have been averaged to provide a flat rate fee payable by all providers. The fees have been calculated in accordance with HM Treasury's Fees and Charges Guide. The costs included in the calculation of the fees are:

1. gross salaries;
2. common services (e.g. finance, personnel);
3. depreciation of fixed assets;
4. accommodation costs;
5. travel and subsistence;
6. staff development and training;
7. office services (e.g. postage and telecommunications);
8. notional costs (costs of capital and insurance);
9. services bought from external suppliers;
10. any other appropriate costs that may arise.

Administrative and financial arrangements

11 HSE will issue invoices, receive payments for all chargeable activities and be responsible for debt recovery. Upfront payments will be required for applications for original and renewal approvals. However, invoices will be issued by HSE following an additional site visit in connection with an approval and for all post approval monitoring visits (including cases where an additional visit is required). Invoices will identify:

1. the type(s) of fee being charged;
2. the total payable; and
3. the location of the site visited and the date the visit took place.

12 Invoicing and debt recovery functions will be carried out centrally by HSE's Finance Unit 2; HSE staff (or their contractors) undertaking assessment activity or making monitoring visits will not be responsible for the issuing of invoices nor for any follow up actions relating to non-payment of invoices. Queries on invoices should be referred to the contact point given at paragraph 23.

Payment and invoicing arrangements

13 Payment of fees should be made as follows:

1. application for an original approval or a renewal of an approval: payment should accompany the application;
2. any additional pre-approval site visit: payment must be made prior to the notification of the result of the application;
3. post approval monitoring visits (both 'initial' and 'additional'): payment will be due to HSE within thirty days of the date of invoice (see paragraph 14).

14 Under the charging arrangements, the invoicing of training providers in respect of post approval monitoring visits will take place within twenty working days of the end of the month in which the visit was carried out.

15 HSE will actively pursue outstanding debts in accordance with its own debt recovery procedures.

16 HSE will prepare an annual Memorandum Trading Account which will be subject to scrutiny by HSE's Internal Audit and externally by the National Audit Office.

Queries on invoices

17 If a training provider queries an invoice, the principles of Service First (the new Citizens Charter - see the booklet 'The Health and Safety Executive and You' [HSE 34]) will apply. The procedures to be adopted will be subject to internal operational guides which will detail the steps to be taken in these circumstances.

18 All queries will initially be directed to HSE's Finance Unit 2, Bootle. Finance Unit will be responsible for answering queries relating to the information contained in the invoice, such as invoice accuracy, method of payment, VAT, address etc.

19 If the query relates to a visit made by HSE's contractor, Finance Unit will refer it to FAAMS for the appropriate action.

20 HSE will assume that training providers' accounting systems allow part payments to be made. If this is not the case, a note to this effect should be sent to Finance Unit (address at paragraph 23) so that standing training provider information can be amended and the appropriate action taken. Where there is a dispute over part of an invoice, the undisputed amount will be payable within 30 days. Once the dispute has been resolved, the amount agreed between HSE and the training provider will be payable within 30 days of the date of the original invoice, or where the original 30 day period has expired, within 10 days of notification of the outcome of the dispute.

21 If, once any query has been dealt with, the invoice remains unpaid and HSE is satisfied that, in all respects, the charge is in accordance with the regulations, it will actively pursue the debt in accordance with its own debt recovery procedures.

Other queries

22 A training provider may have a query which does not relate to charging e.g. concerning progress on their application for a certificate or the reason that a visit was made. In such cases, these queries should be directed to FAAMS.

Contacts for advice and guidance

23 Should you need advice on the operation of the charging system or have a specific query related to the charging scheme, please telephone or write to HSE at:

HSE
Finance Unit 2 (FAA)
Planning, Efficiency & Finance Division
Room 416
St Hugh's House
Trinity Road
Bootle, L20 3QY

Tel: 0151 951 4326
Fax: 0151 951 4141

24 If you have a query as in paragraph 21 on the operation of the 1981 or 1989 Regulations, please telephone or write to HSE at:

HSE
First Aid Approvals and Monitoring Section (FAAMS)
2nd Floor
Grove House
Skerton Road
Manchester M16 0RB

Tel: 0161 952 8322
Fax: 0161 952 8324

25 HSE's guidance 'The Training of First-Aid at Work (a guide to gaining and maintaining HSE approval - ISBN 0 7176 1896 X) is available from HSE Books: Tel: 01787 881 165.

ANNEX D

HEALTH AND SAFETY (FEES) REGULATIONS: CHARGING FOR THE APPROVAL OF FIRST AID TRAINING COURSES REGULATORY IMPACT ASSESSMENT

PURPOSE AND INTENDED EFFECT

Issue

1 These proposals arise out of a recent review in which the Health and Safety Commission (HSC) looked at the feasibility of introducing charges in statutory permissioning regimes for assessing safety cases, granting approvals, and associated regulatory activities. The review recommended that certain activities that fell within HSC/E charging policy guidelines, but for which no charge is currently made, should be further examined. One such activity is the approval of first aid at work (FAW) training.

Risk assessment

2 These proposals do not address health and safety risks. The current regime of FAW training approvals will be maintained.

Objectives

3 The proposals will enable HSE to put in place a fees regime to recover the costs of it's activities with respect to considering applications for approval and ensuring the appropriate standards are met. The principal costs incurred are those of staff time in HSEs First Aid Approvals and Monitoring Section, and also the work of HSE's contractor in undertaking assessment and monitoring.

OPTIONS CONSIDERED

Approaches considered

4 The Health and Safety (First-Aid) Regulations 1981 place a duty on employers to make first-aid provision for their employees. Any subsequent charging regime will need to be implemented via statutory instrument, and it is intended to use the Health and Safety (Fees) Regulations 2000 (as revised) for this purpose. Given this, there are two broad methods of charging:

a) an actual charge would reflect full staff time and related costs in each case.

b) a flat rate fee would be based on the average full economic cost to HSE (or the relevant approved contractor) of the activity.

5 These two options are discussed in further detail below.

Issues of equity and fairness

6 In common with other recent charging proposals, these proposals represent a transfer of funds from the private to the public sector in the first instance. Since the organisations affected are commercial concerns, we might expect any additional costs to be passed through to consumers. However, the consumers affected are likely to be representative of society as a whole, since the organisations are representative of many different sectors of industry. The overall effect of the transfer of funds should therefore be neutral. Furthermore, the actual scale of the costs involved is very small compared to industry turnover.

Information sources

7 The financial issues surrounding charging have been examined by HSE. There are no other significant economic impacts.

BENEFITS

Health and safety benefits

8 The proposals will maintain the benefits of the current FAW regime.

Other benefits

9 There may be efficiency gains in making charges explicit, where they were not before. For example, there may well be an extra incentive for training providers to ensure the training will be given approval in the first instance, without repeat visits from an assessor. Similarly, there may be additional incentives to ensure that standards are maintained, so that repeat visits are not deemed necessary during post approval monitoring.

COSTS

Business sectors affected

10 All business sectors will be affected by these regulations, in that at least some organisations across all sectors may be applying for approval, renewal of approval, or be subject to post approval monitoring at any one time.

Compliance costs to business, charities and voluntary organisations

11 HSE's planned work volumes associated with the approval of first-aid training courses are for pre-approval work on 150 cases and around 430 monitoring visits (including repeat visits if necessary) on existing approvals. These figures are based on the regime in 1997/8 and forecast for 1998/9, during which time an outside contractor has been appointed to carry out the majority (around 90%) of the work Information for years previous to this is not considered indicative of future work. The pre-approval work may include an additional site visit where a shortcoming in training is identified, and it is expected that this will be necessary in around 20% of cases.

12 Full economic costs will be recovered from industry. It is proposed that charges will fall on the persons or businesses applying for approval. The average costs to HSE and/or HSE contractors for carrying out this work are as follows:

a) application for an original approval. The economic cost includes all assessment activity including the original approval assessment visit and the original approval monitoring visit which is undertaken as soon as possible after an approval has been granted. In 1999/00 prices this amounts to £870. The cost of further pre-approval site visits, if necessary, is estimated at £300;

b) post-approval monitoring. The full economic cost of initial monitoring visits, which are undertaken to ensure that standards are being maintained, is estimated at £340. In those cases (we again assume 20%) where additional visits are necessary, these are estimated to cost £300 in full economic terms;

c) renewal. The full administrative cost of dealing with applications for renewal is estimated at £60.

13 Given the expected numbers of each type of activity, this suggests that the total yearly cost to industry for approval and monitoring will be as follows:

(150*£870) + (20%*150*£300) + 430 * (80%*£340 + 20%*£300) = £282,000

14 Costs of routine renewals are relatively small, so the total cost to industry is expected to be not more than £300,000 each year.

Compliance costs for a 'typical' business

15 The average Initial cost incurred by a training organisation has been estimated at approximately £930 in 1999/2000 prices. This cost relates to organisations requiring an Original Approval. However, training organisations which have received Approval, i.e. meet current compliance criteria, will only incur the Recurring costs. These costs have been estimated at approximately £460 over a five-year period and include the cost of a license renewal and Post-Approval monitoring. Training organisations requiring the Original Approval will incur both sets of costs which gives rise to an average cost of £1390 over a five-year period. The costs incurred by different organisations will be in direct proportion to the extent it undertakes FAW training.

Total compliance costs

16 Total compliance costs to industry are estimated at around £300,000 each year. These costs will rise slightly in real terms in future years.

Impact on small and medium sized enterprises (SMEs)

17 The issue of whether there are any disproportionate costs on SMEs depends on the option for charging introduced. If, as proposed, fixed rate fees are introduced based on the average costs of carrying out the activity, then it is possible that SMEs may be faced with relatively higher costs than those faced by large enterprises, since the scale of the work on an individual case may be lower than for larger organisations. However it has been noted following discussion with the First Aid industry (AIFAWTO), that many smaller providers already comply with the criteria and thus will incur only the recurring costs which, are less than half of total unit costs for organisations requiring an Original Approval.

18 However, an analysis of how actual costs are likely to vary suggests that the fixed fees proposed have a sufficiently close relationship to actual costs that the fee can be designated as a charge rather than a `tax' under HSE's charging powers. This suggests that any disproportionate costs born by SMEs will be small in relation to the scale of the charges, which in themselves are small in relation to turnover even amongst SMEs.

Costs to HSE

19 The costs to industry exclude certain costs, which will continue to be born by HSE. These include policy work undertaken by HSE's Health Directorate (around £7,000 in 1996/7), and also verification work undertaken by Regional Support Group specialists in HSE's Field Operations Directorate (around 20 days each, as needs arise). These costs cannot be forecast with any accuracy.

Other costs

20 There are no other costs associated with these proposals, except the costs of developing the proposals (including staff time spent on the feasibility study). These costs can now be considered as `sunk'.

Total costs to society

21 There are no costs to society as a result of these proposals.

ENVIRONMENTAL IMPACTS

22 There are no environmental impacts as a result of these proposals.

BALANCE OF COSTS AND BENEFITS

23 There are no costs or benefits to society as a whole.

Uncertainties

24 The numbers of organisations involved in FAW activity is high enough for costs to be forecast with some degree of accuracy, and similar numbers are expected to be involved in the future. There are no other uncertainties.

Arrangements for monitoring and evaluation

25 HSC/E intend to formally review the charging regimes after two years.

ANNEX E

HEALTH AND SAFETY (FEES) REGULATIONS: CHARGING FOR THE APPROVAL AND MONITORING OF OFFSHORE FIRST-AID AND MEDIC TRAINING PROVIDERS REGULATORY IMPACT ASSESSMENT

PURPOSE AND INTENDED EFFECT

Issue

1 These proposals arise out of a review in which the Health and Safety Commission (HSC) looked at the feasibility of introducing charges in statutory permissioning regimes for assessing safety cases, granting approvals, and associated regulatory activities. The review recommended that certain activities that fell within HSC/E charging policy guidelines, but for which no charge is currently made, should be further examined. One such activity is the approval and monitoring of offshore first-aid and medic training providers. First-aid at work training onshore is already subject to charging. Proposals for charging for onshore approval were agreed by HSC on 23 November 1999 for inclusion in the Health and Safety (Fees) Regulations 2000. These came into force on 10 October 2000.

Risk assessment

2 These proposals do not address health and safety risks. The current standards applying to medics and offshore first-aiders will be maintained.

Objectives

3 The proposals will enable HSE to put in place a fees regime to recover the costs of its activities with respect to considering applications for approval and ensuring the appropriate standards are met. As the feasibility study has noted, much of the work connected with the assessment of the suitability of persons for approval to train, examine and certify onshore first-aiders and post-approval monitoring work is carried out by the Training Approval Services Consortium (TASC). Should HSE move to a similar contractual arrangement for key aspects of the approval of persons to train, examine and certify offshore first-aiders the fees would, in all likelihood, mirror those for onshore approval. The principal costs incurred are those of staff time in HSEs First Aid Approvals and Monitoring Section, and also the work of HSE's contractor in undertaking assessment and monitoring. HSE carries out the assessment and monitoring of medic training providers in-house, and has no plans to change this arrangement in the short term. In the longer term, HSE plans to approach external bodies to invite them to tender for this work.

OPTIONS CONSIDERED

Approaches considered

4 The Offshore Installations and Pipeline works (First-Aid) Regulations 1989 (OFAR) require persons in control of offshore installations to ensure adequate first-aid and basic health care provision for all personnel who are injured or become ill while on offshore installations or pipeline works. It is intended to use the Health and Safety (Fees) Regulations 2002 for the purpose of introducing charging. There are two broad methods of charging:

a) an actual charge would reflect full staff time and related costs in each case;

b) a flat rate fee would be based on the average full economic cost to HSE (or the relevant approved contractor) of the activity.

5 These two options were appraised by an HSE working group. The working group concluded that flat rate fees per approval and monitoring visit was the preferred charging option measured against the following criteria and compared to actuals charging:

• does not have a detrimental effect on health and safety;
• does not adversely affect regulatory practice;
• achieves cost recovery;
• reflects regulatory effort;
• ensures charge is predictable;
• simple to administer;
• sensitive to size of operation.

6 Flat rate fees score positively against all of the above criteria, and are also the method of charging for onshore approvals work. Actuals charging was thought not to provide the degree of predictability industry seeks and is more complex to administer than flat rate fees.

Issues of equity and fairness

7 In common with other recent charging proposals, these proposals represent a transfer of funds from the private to the public sector in the first instance. Since the organisations affected are commercial concerns, we might expect any additional costs to be passed through to the offshore organisations receiving the service. This is likely to increase economic efficiency, and the actual scale of the costs involved, estimated below, is extremely small compared to industry turnover.

INFORMATION SOURCES

8 The financial issues surrounding charging have been examined by HSE in a feasibility study. There are no other significant economic impacts.

BENEFITS

Health and safety benefits

9 The proposals will maintain the benefits of the current OFAR regime.

Other benefits

10 There may be efficiency gains in making charges explicit, where they were not before. For example, there may well be an extra incentive for training providers to ensure the training will be given approval in the first instance, without repeat visits from an assessor. Similarly, there may be additional incentives to ensure that standards are maintained, so that repeat visits are not deemed necessary during post approval monitoring.

COSTS

Business sectors affected

11 Any organisation or individual employer may seek approval to train, examine and certify offshore first-aiders and medics. Approval of training and/or qualifications depends upon the organisation or employer satisfying criteria set out in appendix 6 of the OFAR ACoP, and a recent revision of that ACoP allows for the fact that this training could take place offshore. There are, currently, 15 approved offshore first-aid training providers, they also provide onshore first-aid training - 4 also approve offshore medic trainers. This number is expected to grow to around 24 approved first aid training providers and 7 approved offshore medic trainers. Actual and planned volumes of work in connection with offshore first-aid and medic approvals are currently estimated as follows:

Year	First-Aid: new	First-Aid: renewals	Medics: new	Medics: renewals
1998/99 (actual)	0	2	0	0
1999/00 (actual)	0	4	0	0
2000/01 (actual)	0	5	0	3
2001/02 (forecast)	3	2	2	0
2002/03 (forecast)	3	1	2	0

12 All offshore businesses will be affected by these regulations, in that charges will be passed through to those organisations receiving the service.

Compliance costs to business, charities and voluntary organisations

13 The tables below provides the actual fees payable. The training of offshore medics is more comprehensive than that for first-aiders because it is designed to allow them to treat injured or ill persons sometimes in accordance with the directions of a registered medical practitioner. Training for first-aiders takes four days and training for offshore medics takes four weeks. The fee proposals for offshore medic approvals and associated monitoring are substantially higher than for first-aid given the need to engage more highly skilled medical staff to carry out the approval and monitoring function. Offshore approvals will come up for review every five years.

	Fee for an original approval	Fee for an additional site-visit	Fee for renewal of approval
First-Aid	£890	£320	£62
Medic	£1,305	£845	£62

	Fee for an initial site-visit	Fee for an additional site-visit
First-Aid	£355	£320
Medic	£845	£845

14 The initial fees are designed to cover economic cost and include the original approval assessment visit and the original approval monitoring visit which is undertaken as soon as possible after an approval has been granted. After this, post approval monitoring visits take place at a frequency of approximately once every five years. The majority of organisations will not require an additional initial site visit, and the proportions requiring this cannot be predicted in advance. For the purposes of this assessment only, we take this proportion to be 20%. This would indicate expected revenue from new approvals of £5,670 in FY 2002-3, varying between £5,160 and £6,285 depending on the extent of additional visits. Revenue from renewals would be around £62, and revenue from post approval monitoring will be around £600. Total revenue in FY 2002-3 is therefore expected to be around £6,000.

15 Charges will be subject to refunds, reflecting economies where original approvals for more than one training element is applied for by the same applicant. Where an application for an original approval of either on or offshore first-aid training is made at the same or subsequently to each other, a further refund of £150 will be made. If an application for an approval of medic training is made subsequently to both these on or offshore first-aid training applications, a further refund of £50 will be made. If an application for either on or offshore first-aid training is made and at the same time or subsequently, a medic training application is made, a refund of £50 will be paid. If, after this, an application for the other type of first-aid training is made, a further refund of £150 will be made. When an application for medic training is made and at the same time, or subsequently, an offshore first-aid training application is made, a refund of £50 will be made. If after this, an onshore first-aid training application is made, a refund £150 will be made. Where all three types of application are made at the same time, a refund of £200 will be given.

16 Since the majority of current offshore trainers also cover onshore training, we assume that the refund will normally apply in the future, and we take a average figure of £100, representing the range of discounts available. This would indicate expected revenue from new approvals of £5,170 in FY 2002-03, varying between £4,660 and £5,785 depending on the extent of additional visits. Revenue from renewals would be around £60, and revenue from post approval monitoring will be around £600. Total revenue in FY 2002-03 is therefore expected to be around £5,500.

17 This figure is higher than the expected long-term average, due to an unusually high number of new applications. In the longer term, there are expected to be around two new applications each year (the majority for approval to provide offshore first-aid training).

18 New approvals are therefore expected to generate around £2,000 in any one year. Ongoing renewals will generate an additional £250. There are expected to be around three post approval initial site visits for first aid trainers and one for medic trainers each year, generating an additional £1,860. The need for pre and post approval additional site visits are expected to occur rarely. Income of some £4,100 per annum is therefore forecast in FYs 2003-4 and subsequently (these figures are in real terms, and may rise slightly).

Compliance costs for a 'typical' business

19 These are as indicated in the above tables. Over a five year period, a newly approved first-aid training provider and medic training provider would each typically incur the following costs (to the nearest £100):

First aid: [£890 + 20%*£320] + £62 + [£355+ 20%*£320] = £1,435.
Medic: [£1,305 + 20%*£845] + £62 + [£845 + 20%*£845] = £2,550.

Total compliance costs

20 The above fees will be passed on to the offshore industry. Total compliance costs to industry are estimated at around £6,000 in FY 2002-3 and £4,000 each year thereafter. These costs are expressed in current values and will rise slightly in real terms in future years.

Impact on small and medium sized enterprises (SMEs)

21 Since costs are expected to be passed on to those offshore companies receiving the benefit, the majority of whom are large enterprises, there is expected to be little impact on SMEs.

Costs to HSE

22 The costs to industry exclude certain costs, which will continue to be born by HSE. These include policy work undertaken by Health Directorate and Safety Policy Directorate, verification work undertaken by Health Directorate, and the work of granting the approvals, which is done by FAAMS. The vast majority of these costs have, and will continue, to relate to onshore approval, and the offshore element is extremely small.

Other costs

23 There are no other costs associated with these proposals, except the costs of developing the proposals (including staff time spent on the feasibility study). These costs can now be considered as `sunk'.

Total costs to society

24 There are no resource costs to society as a result of these proposals, which represent a transfer of funds from the private to the public sector.

ENVIRONMENTAL IMPACTS

25 There are no environmental impacts as a result of these proposals.

BALANCE OF COSTS AND BENEFITS

26 There are no resource costs or benefits to society as a whole.

Uncertainties

27 Both numbers of new approvals and the scale of fees are provisional at present. There are no other uncertainties.

Arrangements for monitoring and evaluation

28 HSC/E will review this charging regime after an appropriate period of time. Because of the relatively small scale of receipts, this may not be a formal review.