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In general, standards in the observance by employers of their responsibilities under the Act
are very high in the City. During the year the instances of exceptionally good standards have
been the rule rather than the exception. Very good standards are found both in multi-storey singleoccupation
blocks and in some smaller and older premises which have been internally rebuilt to
quite high specifications. Instances of bad or unsatisfactory conditions are usually associated
with office buildings having some external constraint or inhibitor to modernisation. These may be
office buildings situated within proposed demolition or redevelopment zones. In these circumstances,
where a definite undertaking is received that the premises will be vacated by a specific
date in the near future it is the practice to require only cleanliness and safety measures and not
to press for any structural works.
The use of Section 22 of the Offices, Shops and Railway Premises Act, 1963, has been found
to be of considerable value in the City, more in its implications than in its application. During
the year the provisions of Section 22 of the Act were drawn to the attention of both landlords and
occupiers, mainly in relation to hoists and lifts; drive shafting of ventilation plant; the ill design
and abuse of stationery chutes. In all these circumstances the dangerous practices were stopped
immediately. A particular problem area relates to the report by a competent person on a hoist or
lift where defects are found which require immediate attention in order that the lift may be used in
safety. Since a period of twenty-eight days is allowed before a copy of the report is required to be
filed with the Local Authority, it is inconsistent to suggest that in these circumstances the provisions
of Section 22 might be used nearly one month after the danger was discovered. This is
particularly so, since, if the danger were noted during a routine visit by the Public Health Inspector
it could be stopped on the day of discovery. In this connection some strengthening of
legislation would be desirable.
A further area where strengthening of existing powers would have been helpful is associated
with the high rate of turnover of office situations within the City. Office development is predominantly
on a speculative basis, although a small proportion of development is designed for
specific use. In many cases the prior approval of this Department is sought. Since the Offices,
Shops and Railway Premises Act is geared to both occupation and structure, approval is usually
given only when facilities are at a high level in relation to the proposed or expected density of
occupation. This places firms seeking approval at a financial disadvantage to those not seeking
approval and allowing poor design to be shown up later during a routine inspection.
In conclusion, the implementation of the Act and Regulations has proceeded at a satisfactory
pace, with the introduction of more efficient methods. The City office-workers' environment has
been found to be reasonably satisfactory, with predominantly more good premises than bad,
although standards should progressively rise. Some strengthening of legislation is thought necessary
in the correlation between Section 22 provisions of the Act and the reporting by competent
persons of defects which require immediate attention. Additionally, in view of the high degree of
speculative office development in the City it is felt that adequate standards regarding structure
and facilities could be controlled more effectively if firms were required to obtain prior approval
under the Act.
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