Health and Safety Training for Managers: 10 Tests That Prove Competence, Not Just Attendance

964,000 workers in Great Britain reported work-related stress, depression or anxiety in 2024/25, costing an estimated 22.1 million working days (HSE statistics). Most of those cases sit in offices, not factories, and most of them pass through a line manager first. When something goes wrong, nobody asks whether that manager attended a course. They ask whether that manager was competent.

Competence is a legal concept, not a job title. In UK law and in almost every comparable system worldwide, it means training, knowledge, experience and the ability to apply them, all evidenced. A certificate proves one of those four things. An inspector, an insurer or a court will want to see the other three, and the evidence that ties them together.

That gap is where most organisations in software, AI, legal, insurance and education quietly fail. Managers are promoted for technical or commercial skill, sent on a one-day course, and assumed to be covered. This article gives you 10 yes/no tests to find out whether your health and safety training for managers has actually produced competence, across the UK and the international jurisdictions where your teams work.

---

Why "Trained" and "Competent" Are Not the Same Thing

The Health and Safety at Work etc. Act 1974, section 2 requires employers to provide "information, instruction, training and supervision". The Management of Health and Safety at Work Regulations 1999, regulation 13 goes further: employers must take account of a person's capabilities before entrusting them with tasks, train them on recruitment and whenever risks change, and repeat that training periodically during working hours.

Then regulation 7 sets the standard for anyone helping you comply: a person is competent when they have "sufficient training and experience or knowledge and other qualities". HSE's own guidance on competence describes it as the combination of training, skills, experience and knowledge, plus the ability to apply them to perform a task safely.

The pattern repeats internationally:

• European Union: the OSH Framework Directive 89/391/EEC requires "necessary capabilities" for designated workers (Article 7) and adequate training on recruitment, transfer and change (Article 12).
• Ireland: section 18 of the Safety, Health and Welfare at Work Act 2005 requires employers to appoint competent persons, with competence defined by training, experience and knowledge appropriate to the work. See our Ireland health and safety guide.
• Australia: under the model WHS laws, officers must exercise due diligence, which includes acquiring and keeping up to date knowledge of work health and safety matters. Our Australia WHS page explains how this lands on senior people.
• ISO 45001: clause 7.2 requires organisations to determine necessary competence, ensure it on the basis of education, training or experience, and retain documented information as evidence. See our ISO 45001 support.

Every one of these frameworks ends in the same place: prove it. For a deeper background read, see what health and safety competence looks like and the role of a competent person.

---

The 10 Competence Tests for Managers

The tests are grouped by the four elements of competence, plus a final pair on evidence. Answer each one honestly for a real manager in your business, not for the policy.

Element 1: Training

#### Test 1: Was the manager trained for the role they hold now, not the role they were hired into?

Regulation 13 triggers training on "exposure to new or increased risks", which explicitly includes a change of responsibilities. Promotion to team leader is that change. A developer who became an engineering manager last quarter inherits duties for DSE, stress, lone and hybrid working, and incident reporting that their original induction never covered.

What good looks like: a role-based trigger in your HR process, so every promotion or transfer generates a training requirement automatically.

Sector example (AI and data): a research lead in an AI and data business now signs off on overnight model runs and on-call rotas. That is a fatigue and lone working responsibility, and it needs specific training, not the generic course they took as an individual contributor.

#### Test 2: Is refresher training scheduled by risk, not by habit?

"Repeated periodically where appropriate" does not mean every three years for everything. It means refreshing when the law, the risk or the role changes. Our guide on how often health and safety training should be refreshed breaks this down by training type.

What good looks like: a refresher calendar driven by your risk assessments, with event-based triggers (a new office, a restructure, a new legal duty) that override the routine cycle.

Element 2: Knowledge

#### Test 3: Can the manager name the specific duties they personally hold?

Ask a manager what they are legally responsible for. "Keeping people safe" is not an answer. A competent manager can say, in plain terms, that they hold duties around risk assessment for their team, DSE, stress and workload, reporting incidents, and supervising new starters.

This matters because section 37 of the 1974 Act can make a "director, manager, secretary or other similar officer" personally liable where an offence by the organisation was committed with their consent, connivance or neglect. That provision targets people with real decision-making authority, and senior managers in professional services often have exactly that. Our leadership guide for directors and senior managers and HSE's Leading health and safety at work (INDG417) set out what that authority demands.

#### Test 4: Does the manager know which country's rules apply to each person in their team?

This is the test most UK-headquartered tech, legal and insurance businesses fail. A manager in London with reports in Dublin, Berlin and Milan is managing four legal regimes, not one. German law requires documented instruction (Unterweisung) for every employee, repeated regularly and delivered in working time; see our DGUV guide. Italian law under Legislative Decree 81/2008 sets defined training for managers (dirigenti) and supervisors (preposti); see our RSPP page.

What good looks like: a one-page jurisdiction summary for every manager who leads people outside their own country, supported by international health and safety consultants who track the local detail so your managers do not have to.

Element 3: Experience

#### Test 5: Has the manager actually completed a risk assessment, not just read one?

Experience is the element most often assumed and least often tested. A manager who has sat through a module on risk assessment but never assessed a real task, with real people, has knowledge without experience.

What good looks like: each new manager completes at least one supervised assessment within their first months in role (a team DSE review, a workload and stress assessment, or an office move) with feedback recorded.

Sector example (offices): in office environments, the most useful first assessment is often a stress and workload review. Our stress matrix gives managers a structured starting point.

#### Test 6: Has the manager handled an incident, near miss or concern, start to finish?

Knowing the reporting procedure is not the same as running it under pressure. A competent manager has taken a report, secured information, escalated correctly and followed through to corrective action at least once, even if only in a realistic exercise.

What good looks like: tabletop scenarios built into manager training, using incidents that fit your sector: a fall on a wet office floor, a disclosure of burnout, a student injury on a field trip, a client visitor taken ill at reception.

Sector example (education): in schools, colleges and universities, managers carry duties to non-employees (students and visitors) as well as staff. Their scenarios should reflect that.

Element 4: The Ability to Apply It

#### Test 7: Would the manager stop or change work that is unsafe, even under commercial pressure?

This is the hardest element to evidence and the one that matters most. Ability to apply means acting on knowledge when it is inconvenient: pushing back on a deadline that requires a team to work 70-hour weeks, refusing to approve an unassessed home working setup, or escalating a workload concern from a high-billing fee earner.

Sector example (legal): in law firms, billable-hour culture is a known driver of stress. A competent supervising partner applies what they know about workload risk, rather than treating long hours as normal.

Sector example (insurance): in insurance businesses, claims and underwriting teams face high volume and difficult customer contact. A competent manager spots the pattern and acts, rather than waiting for the sickness absence data.

#### Test 8: Is the manager's competence checked through observation, not only quizzes?

An end-of-course multiple-choice test checks recall. It does not check application. Competence is evidenced by seeing someone do the job: observing a team briefing, reviewing a manager's own risk assessment, or sampling how they handled a return-to-work conversation.

What good looks like: a short observed check within the first months of any new management role, repeated at intervals, and built into your internal health and safety audits.

Element 5: The Evidence

#### Test 9: Could you produce one manager's full competence record within an hour?

If an inspector, insurer or tender evaluator asked for evidence that a named manager is competent, could you produce it? That means training records with dates and content, not just certificates; evidence of experience; observed checks; and the date of the next refresher.

Training records hold personal data, so they also need proper governance. See health and safety records and data protection for the questions to settle first.

Sector example (software): fast-growing software businesses are often asked for this evidence during enterprise procurement or due diligence, long before an inspector ever asks. Missing records slow deals.

#### Test 10: Does a competency matrix show gaps across the whole management population?

Individual records answer "is this manager competent?" A competency matrix answers the better question: "where are we exposed?" It maps every manager against the competences their role needs, by element and by country, and highlights who is overdue, who was promoted without training, and which jurisdictions are thinly covered.

What good looks like: a live matrix held in dedicated health and safety software, with automated reminders and expiry alerts, rather than a spreadsheet maintained by one person who is about to go on leave.

---

Your Competence Scorecard

Score one point for every "yes".

Test	Question	Yes / No
1	Managers are trained for their current role, triggered by promotion or transfer
2	Refresher training is scheduled by risk and change, not habit
3	Managers can name the specific duties they personally hold
4	Managers know which country's rules apply to each team member
5	Every new manager has completed a real, supervised risk assessment
6	Managers have handled an incident or realistic exercise end to end
7	Managers act on safety concerns even under commercial pressure
8	Competence is checked by observation, not only quizzes
9	Any manager's full competence record can be produced within an hour
10	A live competency matrix shows gaps across all managers and countries

8 to 10: You have evidenced competence. Keep the matrix live and test it through an independent audit each year.

5 to 7: Training is happening, but the experience, application or evidence layers are thin. These are the gaps that surface after an incident.

0 to 4: Your managers have probably attended courses, but you could not prove competence today. This is the most common result in fast-growing tech, legal and financial services businesses, and it is entirely fixable.

---

How Arinite Closes the Gap

Arinite has supported 1,500+ businesses across 50+ countries for 15+ years, protecting 100,000+ employees. Our qualified consultants combine expert advice with our own software, so competence is built and evidenced in the same place. You choose the level of support that fits:

• Done For You: our health and safety consultants design your manager training, run observed checks and maintain your records, acting as your outsourced competent person through health and safety outsourcing.
• Done With You: we build the competency matrix and training plan with your HR and people teams, then coach your managers through their first assessments.
• DIY: you run the programme yourself using our health and safety consultants and software platform, with training records, reminders and audit trails in one system, and expert help on call.

For organisations operating across borders, our global health and safety consultants map each jurisdiction's training and competence rules into one consistent standard, so a manager in London and a manager in Lisbon are measured the same way. Explore our health and safety training to see what we deliver.

---

Frequently Asked Questions

Is health and safety training for managers a legal requirement in the UK?

There is no single mandated "manager course", but the law requires managers to be competent for the duties they hold. Regulation 13 of the Management of Health and Safety at Work Regulations 1999 requires training on recruitment, on changes of responsibility and when risks change. In practice, that makes role-specific training for managers a requirement.

What is the legal definition of competence in health and safety?

UK law describes a competent person as someone with sufficient training and experience or knowledge and other qualities. HSE adds the ability to apply these to perform a task safely. Most international frameworks, including the EU Framework Directive and ISO 45001, use the same four building blocks.

Is a course certificate enough to prove a manager is competent?

No. A certificate evidences training, which is one element of competence. You also need evidence of knowledge, relevant experience and the ability to apply it in practice, normally through observed checks, completed assessments and up-to-date training records.

How should multinational businesses manage manager competence across countries?

Start with one group standard based on the four elements of competence, then layer the local requirements on top, such as German instruction duties or Italian training for dirigenti and preposti. A central competency matrix, supported by international health and safety consultants, keeps the whole management population visible.

How often should managers' health and safety competence be reviewed?

At least annually, and whenever the role, the law or the risk profile changes. Promotions, restructures, new offices and new legal duties should all trigger a review, not just the calendar.

---

Find Your Gaps Before an Inspector Does

If your scorecard showed more than two "no" answers, you are not alone, and you do not need to fix everything at once. Book a free gap analysis with Arinite and we will review your manager training, records and competency matrix against UK and international requirements, then show you exactly where to start.

Request your free gap analysis