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OCCUPATIONAL HEALTH & SAFETY MANAGEMENT SYSTEMS AUDITOR TRAINING COURSE IRCA REG. NO. A16834 1: Introduction 1.1Background Development • During the Industrial Revolution, technological advances introduced and increased the use of machinery and toxic materials in the workplace. As a result, workers in factories faced health and safety risks that were previously unheard of. Health and safety problems and hazards that workers face include the following: • Poor working conditions • Exposure to toxic materials or chemicals • Long working hours • Work-induced stress • Excessive noise levels • Risks to life, eyes, and limb while working with machinery • In 1970, (OSHA) was established as a comprehensive occupational safety and health law “to assure so far as possible for every working man and woman in the nation safe and healthful working conditions and to preserve human resources .” • In addition, OHSAS 18001 specification and the accompanying OHSAS 18002 guidelines have been developed • OH&S management system to enable organization to control its OH&S risks and improve its performance. 1.2 Concepts of Occupational Health • Defined as "that science and art devoted to the anticipation, recognition, evaluation, and control of those environmental factors or stresses arising in or from the workplace, which may cause sickness, impaired health and well-being, or significant discomfort among workers or among the citizens of the community."[i] 1.3 Concepts of Safety Engineering • Interdisciplinary in nature & ought to be applied early in system development. • Control monetary and physical loses • Safety costs should be justified like other forces competing for limited organizational resources. • Safety should be considered a long-term investment. • Figure 1.1 shows that its application requires integration with many other functions Operations Engineering Environmental Security Medical Training SAFETY Industrial Hygiene Legal Transportation Test & Evaluation Information Systems Facilities Figure 1.1: Safety Interactions 1.4 Philosophy Supporting OH&S Management System Standards • safety denotes concern for physical injuries that might be experienced by the worker • Health denotes concern for physiological injuries • welfare refers to concern for a range of psychological conditions. • this type of approach promotes a holistic appreciation of a worker’s well being as well as a comprehensive understanding of the contribution of workplace conditions to it. The basic principles of a holistic approach to workplace health and safety are thus: • The health and safety of a worker is influenced by conditions of the workplace and by non- work related factors that can be potentiated by the workplace. • Workplace effects on human health and safety are not restricted to only the on- site workplace or the worker Environment Environmental Quality Products & Processes Attributes Workplace Raw Materials & Energy Labor Processing Environmental Health & Safety Community Occupational Health & Safety Groups Persons Institutions Product Worker Waste Occupational Health & Safety Occupational Health & Safety Figure 1.2: Holistic Overview of the Workplace, Environmental Quality & Human Community[i] 1.5 Modern OH&S Legislation • At both national and international levels, the modern corporation is perceived as having both a moral and a legal responsibility to protect its employees from: – Workplace sources of injury and; – Workplace insults to a worker’s pre- existing debilitation[i]. • By ensuring proper responsibilities, common problems such as those stated below can be avoided. – Lack of sufficient authority to implement safety- – Isolation from higher decision makers who must bear the potential liability associated with workplace injury – Isolation from production- level personnel have primary responsibility for production but they play a crucial role in the implementation of an effective safety program. 1.6 Scope of OH&S Management Systems The scope of an OH&S management system, applicable to any organization, includes: • Establishing an OH&S management system to eliminate or minimize risk to employees and other interested parties who may be exposed to OH&S risks associated with its activities; • Implementing, maintaining and continually improving an OH&S management system; • Assuring itself of its conformance with its stated OH&S policy; • Demonstrating such conformance to others; 1.7Definitions & Terminology The terms and definitions used in the OHSAS 18001 specifications are: 1. Accident 2. Audit 3. Continual Improvement 4. Hazard 5. Hazard identification 6. Incident NOTE: An accident where no ill heath, injury, damage, or other loss is also referred to as a “near miss”. The term “Incident” includes “near-misses”. 7. Interested parties 8. Non-conformance 9. Objectives 10. Occupational health and safety 11. OH&S management system 12. Organization NOTE: For organizations with more than one operating unit, a single operation unit may be defined as an organization. 13. Performance NOTE: Performance measurement includes of OH&S management activities and results. 14. Risk 15. Risk assessment 16. Safety 17. Tolerable risk Chapter 2 Introduction to OH&S Standards & Applications 2.1 Influence of the Working Environment There are various kinds of positive and negative factors in the working environments • Physical demands may refer to manual lifting loads and extended working hours. • For mental demand, it appears to be dependent on the level of mental work pressure and the experience of the worker involved. • Use of ear protection will be in order as excessive noise levels (>85 to 90 dB) can cause hearing loss. • Proper illumination is necessary to avoid having workers headaches and fatigue as a result of eyestrain. • Working temperature can cause great discomfort if it is too high or too low. mental and emotional factors to consider: • Lifting the morale of workers can do wonders to improve productivity. • A pleasant working place with convenient facilities will increase the workers’ morale, resulting in worker efficiency. 2.2 OH&S Management System Model The first three clauses of the OHSAS 18001: 1999 specifications follow the ISO 14001 approach closely. The three common clauses are: • Scope • Informative references • Definitions Organizations using the ISO 14001 approach should use the OHSAS 18002 guidelines in carrying out the respective approach for clause 4. Figure 2.1 illustrate the order of flow of OHSAS elements. Continual Improvement OH&S Policy Management Review Planning Hazard Identification, Risk Checking & Corrective Action Assessment & Risk Control Performance Measurement & Monitoring Legal & other Requirements Accidents, Incidents, NCs & Corrective & Objectives Preventive Action OH&S Management Records & Records Management programme(s) Audit Implementation & Operation Structure & Responsibility Training, Awareness & Competence Consultation & Communication Documentation Document & Data Control Operational Control Emergency Preparedness and Response Figure 2.1: OH&S Management System Model for OHSAS 18001 System Elements 2.3 OH&S Management System Elements The six elements for occupational health & safety management system are based on: • Initial Status Review • OH&S Policy • Planning • Implementation and Operation • Checking and Corrective Action • Management Review 2.3.1 Initial Status Review • An initial review of a company’s existing arrangements for managing OH&S should be carried out prior to implementation. • Performing an initial status review also provides information on the scope, adequacy and current status of the OH&S management system. 2.3.2 OH&S Policy • The OH&S policy should be defined and authorized by the organization’s top management. • Such a policy establishes an overall sense of direction and sets up the principles of action for an organization.[i] • It demonstrates formal commitment of an organization towards good OH&S management, particularly that of the organization’s top management.[ii] 2.3.3 Planning • Plans must be formulated to fulfill the OH&S policy. • Hazard identification should be performed with risk assessment. • Control measures should be implemented if necessary. • The legal requirements that are applicable to OH&S should be identified • The goals and objectives of the OH&S system established. • After identifying problematic areas, appropriate corrective actions should be implemented. 2.3.4 Implementation and Operation • responsibility of a person at the most senior management level. • Necessary training should be carried out, to ensure workers understand their safety and health responsibilities • Updates should be spread throughout the organization effectively through an efficient communication system. • In addition, a system of documentation should be established. • OH&S should be fully integrated where each employee appreciates the implications of OH&S. • In the case of foreseeable emergencies, contingency plans should be prepared in advance. 2.3.5 Checking and Corrective Action • Monitoring and measurement of performance ought to be performed on a regular basis. • The measurement of performance of the OH&S management system will give an indication of its effectiveness. • Areas that need improvement can be identified and followed up by taking necessary actions. • Corrective actions should be taken as soon as any deficiencies are found. • Relevant records of OH&S actions taken should be made to meet legal requirements. • Periodically, audits conducted by independent personnel will give a more in-depth look at the system. 2.3.6 Management Review • Involve the making of several decisions, based on the organization’s structure and size. • Matters such as frequency of audits and the effectiveness of the OH&S system as a whole and in its individual elements are considered frequently. • Following an audit, a management review decides on what should be done about identified problems. • In any management programs, the system has to be reviewed constantly to ensure its continuing suitability, adequacy and effectiveness. CHAPTER 3 INTERPRETATION OF THE OHSAS 18001: 1999 SPECIFICATIONS 3.1 Overview of the OHSAS 18001: 1999 • OHSAS 18001: 1999 is developed together with the OHSAS 18002, Guidelines for the implementation of OHSAS 18001 • OHSAS 18001 is developed such that it is compatible with the ISO 9001: 1994 (Quality) and ISO 14001: 1996 (Environmental) management systems standards. – to facilitate the easy integration of quality, environmental and occupational health and safety management systems – Nevertheless, it is not a pre- requisite that an organization has to comply to ISO 9000 or ISO 14000 requirements for the operation of OHSAS 18001. • An OH&S management system must meets both the OHSAS 18001 specification and all local legal requirements as well. • Relevant procedures and documentation, which relates to records and periodic reviews, should be added where necessary • The elements of an effective OH&S approach are presented in Figure 3.1. Continual Improvement OH&S Policy Management Review Planning Checking and Implementation Corrective Action & Operation Figure 3.1: Elements of an OH&S management system[i] • 3.2 Clauses in OHSAS 18001 clauses and requirements in the OHSAS 18001: 1999 • Clause 4.1 – General Requirements – states that the organization shall establish and maintain an OH&S management system, – Depending on the size of the organization and the nature of its activities, the extent of documentation and the resources devoted to it have to be developed and adapted to fit into the organization under review. • Clause 4.2 – OH&S Policy – states overall health and safety objectives and a commitment to improving health and safety performance. – an indication of the organization‟s overall sense of direction and principles of action. Management Review Feedback from Measuring Audit Policy Performance Planning Figure 3.2: OH&S Policy[i] • In planning the policy, the management shall ensure that: – It is appropriate to the nature and scale of the organization‟s OH&S risks. – There is a commitment to continual improvement – There is a commitment to at least comply with current applicable OH&S legislation and other requirements – It is documented, implemented and maintained as called for by the OHSAS Standards. – All employees are educated on their individual OH&S obligations. – It can be made available to interested parties. – It is reviewed periodically to ensure its relevance and suitability to the organization. • Clause 4.3 – Planning Policy Feedback from Audit Planning Measuring Performance Implementation and Operation Figure 3.3: Planning[i] OHSAS 18001 specifies planning requirements based on four categories before any implementation is to be carried out. They are addressed as follows: Clause 4.3.1 Planning for Hazard Identification, Risk Assessment & Risk Control – control measures to include routine and non-routine activities, activities of all personnel (including subcontractors and visitors) having access to the workplace, and facilities at the workplace. – defined with respect to the scope, nature and timing to ensure that it is proactive rather than reactive – Is consistent with operating experience and the capabilities of risk control measures used – Provide ways to classify and identify risks to be eliminated, or controlled by measures defined in clauses 4.3.3 and 4.3.4. – Provide input to determine the facility requirements, training needs and operational controls, – Monitoring mechanisms to ensure the effectiveness and timeliness of their implementation. The purpose of this requirement is to provide for total appreciation of all significant OH&S hazards in the organization’s domain using the process of risk assessment. The following elements of decision-making shall be reflected in the risk assessment. • Identification of risks. • Evaluation of risks within the existing control measures in place. • Decision on the tolerability of this residual risk. • Identification of any additional control measures considered necessary. • Evaluation of whether these are sufficient to reduce the risks to tolerable levels. Clause 4.3.2 Legal and other requirements • organization aware of all applicable OH&S regulations and how they can affect its activities. • legal and other OH&S requirements applicable to the organization identified and up to date. • organization able to access these legal documents conveniently, and communicate the information to other parties who have an interest in it. Clause 4.3.3 Objectives • take into account legal and other requirements • reasonable, achievable and communicated to the employees efficiently. • Suitable indicators shall be established so that objectives can be reviewed and monitored regularly. Clause 4.3.4 OH&S Management Programs • has to be established so as to achieve the OH&S objectives • important to include the documentation of the responsibility and authority for achievement of the objectives at relevant functions and levels of the organization, and the means and time scale by which the objectives are to be obtained. • individuals and tasks responsible for the deliverance of the objectives at relevant levels can be identified. • It aids the organization in allocating suitable talents, responsibilities and time- frames for jobs to be done. • The OH&S management programs shall be reviewed at regular and planned intervals in order to keep up with changes. • Clause 4.4 – Implementation and Documentation Planning Audit Implementation Feedback from and Operation Measuring Performance Checking and Corrective Action Figure 3.4: Implementation and Operation[i] Clause 4.4.1 Structure and Responsibility • The roles, responsibilities and authorities of all personnel who are involved in the running of OH&S risks of the organization shall be defined, documented and made known • The top management holds the greatest responsibility of ensuring the proper implementation of the OH&S management system. • The management representative or appointee shall : a) Ensure the OH&S management system requirements are established, implemented and maintained in accordance with the OH&S specification, b) Ensure reports on the performance of the OH&S management system are presented to the top management for the review and making of improved adjustments Clause 4.4.2 Training, Awareness and Competence • Employee awareness in the following areas is important and procedures shall be established and maintained : – The importance of conformance to the OH&S policy and procedures, and the requirements of the management system; – Both actual and potential OH&S consequences, their work activities and the OH&S benefits of improved personnel performance; – Their roles and responsibilities in conforming to the OH&S policy and requirements of the management system. – Potential consequences of straying from specified operating procedures. • Employees need to be educated on their specific responsibilities and the roles expected of them to maintain the OH&S management system. • Appropriate records of individuals training and competency shall be maintained. Clause 4.4.3 Consultation and Communication • the management has to establish and document proper procedures for easy and accurate communication. • The freedom of employee involvement and consultation arrangements shall be established so that there is an effective and open communication of OH&S information. There shall also be arrangements to: – Involve employees in the development and review of policies, and procedures to manage risks, including the carrying out or review of risk assessments relevant to their own activities. – Consult employees over changes affecting the workplace OH&S such as the introduction of new equipment, new working procedures or work patterns. – Represent employees on health and safety matters. – Inform employees their OH&S representative to the management and the selected management appointee. Clause 4.4.4 Documentation • The organization shall document all important and essential information and maintain up to date sufficient documentation to ensure that its OH&S system can be adequately understood and efficiently operated. • it shall describe the core elements of the management system and their interaction, as well as provide direction to the related documentation at the same time. • It may be more convenient and effective instead, to establish an overview document describing the inter-relation between the existing procedures and overall OHSAS requirements Clause 4.4.5 Document and Data Control • This clause calls for the organization to establish and maintain proper procedures for controlling all the important documents and data required by this OHSAS 18001 specification. • There shall be a written procedure to define the controls for the approval, issue and removal of safety documentation, together with the control of safety records and data. Arrangements must be made ensure that specified documents and data: a) Can be located. b) Are periodically reviewed, revised as necessary and approved for adequacy by authorized personnel. c) Are current and up-dated, and available at all locations where operations essential to the effective functioning of the OH&S system are performed. d) Are removed from all points of issue and points of use or otherwise assured against unintended use once they are obsolete. e) Are suitably identified, particularly for archival documents and data retained for legal or knowledge preservation purposes or both. Clause 4.4.6 Operational Control • Control measures shall be applied to those operations and activities associated with identified risks. • The organization can carry out the preparations by: a) Establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the OH&S policy and their objectives. b) Stipulating operating criteria in the procedures. c) Establishing and maintaining procedures related to the identified OH&S risks of goods, equipment and services purchased and/ or used by the organization and communicating relevant procedures and requirements to suppliers and contractors. d) Establishing and maintaining procedures for the design of workplace, process, installations, machinery, operating procedure and work organization, including their adaptation to human capabilities in order to eliminate or reduce OH&S risks at their source. Clause 4.4.7 Emergency Preparedness and Response • The organization shall have to establish and maintain plans and procedures to identify the potential for, and responses to such incidents and emergency situations and for preventing the likely illnesses, injuries or hazards associated with them. • The organization shall develop an emergency plan and identify and provide appropriate emergency equipment. • The emergency preparedness and response plans and procedures shall be reviewed frequently, especially after the occurrence of any incidents and emergencies. • The response capability of the emergency plan needs to be tested for feasibility and rehearsed where viable for employee awareness. Clause 4.5 – Checking and Corrective Action Implementation and Operation Feedback Audit Checking and from Corrective Action Measuring Performance Management Review Figure 3.5: Checking and Corrective Action[i] Clause 4.5.1 Performance Measurement and Monitoring These procedures shall provide for: – Both qualitative and quantitative measures, appropriate to the needs of the organization. – Monitoring the extent to which the organization‟s OH&S objectives are met. – Proactive measures of performance to monitor compliance with the OH&S management program, operational criteria and applicable legislation and regulatory requirements. – Reactive measures of performance to monitor accidents, ill health, incidents (including near misses) and other historical evidence of deficient OH&S performance. – Recording of data and results of monitoring and measurement sufficient to facilitate subsequent corrective and preventative action analysis. • Performance management proposes to determine whether OH&S plans and risk controls have been implemented and achieved, • to learn from any system failures including hazardous events, and to promote implementation by providing feedback and information for continual review and improvement. • Monitoring equipment, if required for any performance measurement and monitoring, have to be calibrated and maintained. • Proper procedures and records for the calibration and maintenance process shall have to be retained. • Clause 4.5.2 Accidents, Incidents, Non- conformances and Corrective & Preventive Action The organization shall establish and maintain procedures to define responsibility and authority for: a.The handling and investigation of accidents, incidents or non- conformances. b.Taking action to mitigate any consequences arising from accidents, incidents or non- conformances. c.The initiation and completion of corrective and preventive action. d.Confirmation of the effectiveness of corrective and preventive actions that have been taken. • Report and evaluation of these occurrences are necessary so that suitable corrective and preventive actions can be implemented. • The investigation process and results and subsequent corrective or preventive actions have to be documented for future reference or analysis. Clause 4.5.3 Records and Records Management • Records shall be kept to demonstrate that the OH&S system operates effectively, and that processes have been carried out under safe conditions. • Safety records that document the management system and conformance to the requirements shall be legible, identifiable and traceable to the activities involved. • These records have to be maintained and stored properly so that they are readily retrievable and protected against damage, deterioration or loss. • Their retention times before disposal have to be established and recorded as appropriate to the system and the organization‟s rules. Clause 4.5.4 Audit • An audit program and its procedures shall have to be established and maintained. Periodic OH&S audits have to be conducted to: a. Determine whether the OH&S management system conforms to planned arrangements for OH&S management including the requirements of this OH&S specification, has been properly implemented and maintained and is effective in meeting the organization‟s policy and objectives. b. Review the results of previous audits. c. Provide information of the audits results to management. • Audit program, including its schedule, has to be based on the results of previous audits and that of the risk assessments conducted. • The results of all audits shall be fed back to all relevant parties as soon as possible to allow corrective actions to be taken. Clause 4.6 – Management Review Checking and Conductive Action Management Internal Factors External Factors Review Policy Figure 3.6: Management Review[i] • it is essential that the system is reviewed and evaluated periodically to ensure its continuity, suitability, adequacy and effectiveness. • During the review, the management will evaluate the policy, objectives and other elements of the OH&S management system for possible changes in view of the management system audit results, with changes in circumstances and commitment to continual improvement. • Changing circumstances may include changes in legislation, varying expectations of interested parties, changes in the organization‟s products or activities, technological advances, marketing information, and feedback from OH&S incidents. • the management review needs to be documented. CHAPTER 4 ENSURING EFFECTIVE IMPLEMENTATION & OPERATION 4.1 Organizational Structure, Responsibility & Accountability – Ultimate responsibility for occupational health and safety rests with the top management. – The management plays a central role in implementing the occupational health and safety (OH&S) program and determining its effectiveness. – Accidents will decrease profits, as additional money has to be dealt out for workers‟ compensation, damages and other hidden costs. – While organizing an OH&S safety program, the management has to bear in mind that conflicts between staff, departments or management are inevitable • The management shall always be aware of the latest changes to health and safety requirements, legal OH&S issues and policies. • Managers shall also provide visible demonstration of their commitment to their staff, by visiting sites, being involved in accident investigation, and attending safety awareness courses and meetings. 4.1.1 The Health and Safety Committee • A committee drawn from various departments has many advantages, allowing greater committee scope and reach. • In all cases, the committee shall be chaired by the person of highest authority to ensures the committee is empowered to perform its tasks without facing too much resistance. • The health and safety committee will have various tasks at hand. To begin with, methods for obtaining feedback from all levels within the organization shall be established. • Other tasks that the committee can organize are as follows: 1. Inspections conducted on workplaces to detect hazards. 2. Hold regular meetings to discuss accident and illness prevention methods, hazards discovered in the workplace, and injury and illness records and so on. 3. Investigate accidents that occurred, and devise plans to prevent recurrence. 4. Provide information to all employees on safe working practices. 5. Recommend changes to present equipment to improve health and safety standards. 6. Develop new or revise existing rules to comply with current standards. 4.1.2 Task Groups Within a health and safety committee, several task groups may be formed. Each task group and their responsibilities are described as follows : – Safety Activities: To ensure the effectiveness of the OH&S program in reducing injuries and illness, and to diffuse information pertaining to OH&S matters. – Rules & Procedures: Prepare, maintain and review new or existing general safety rules and procedures, and to ensure that rules are being followed. – Inspection & Audit: Identify unsafe work area conditions and practices, and to increase safety awareness and participation. – Fire & Emergency: Develop effective management programs to protect people, property and environment in emergencies. – Education & Training: Manage, coordinate and review safety training programs. – Health & Environment: Recommend measures to protect people, property and environment from hazardous substances, and to keep and eye on employees‟ health and overall wellness. – Accident Investigation: Determine cause of accidents and to prevent recurrence; to eliminate and minimize hazards. – Housekeeping:Improve employee morale, quality, productivity and safety and health by maintaining proper workplace housekeeping and orderliness. 4.2 Importance of the OH&S Policy • It shall be defined in respect of the health, safety and welfare obligation to all employees. • In order to fulfill this OH&S policy, plan(s) shall be formulated and capabilities and support mechanism shall be developed. 4.3 Planning and Implementation • The management shall take note to define, prioritize and quantify the organization‟s objectives clearly. • Proper plans for any programs shall be developed in detail, and the availability of financial and other resources must be looked into before confirming any decisions. • plans and policies that have been implemented shall be measured and reviewed all the time. • organizations have to be pro- active in order to encourage continual improvement. • An important part of OH&S planning is the management of change. • Internal standards policies, procedures and safe systems of work shall be available. Draw up list of OH&S OBJECTIVES Select key OBJECTIVES Quantify key OBJECTIVE (If possible). Select OUTCOME Indicators Prepare PLAN- to achieve key OBJECTIVE. Draw up TARGETS. Implement PLAN Measure OUTCOME indicators. Have TARGETS been met? Has key OBJECTIVE been achieved? Has PLAN been fully implemented? REVIEW Figure 4.1: A Procedure for OH&S Planning and Implementing 4.3.1 Risk Assessment • Risk assessment shall be used when occupational hazards in a workplace appear to pose a significant threat and it is uncertain whether planned controls are adequate in practice. • Organizations shall carry out risk assessment as part of their efforts for continual improvement. • The intent of risk assessments is to control risks before harm could occur. • A risk assessment based on a participative approach also provides an opportunity for the management and the work force to agree on the organization‟s procedures with shared perceptions of hazards and risks. • Several risk analysis of hazards have been developed for use such as the fault- tree analysis or the criticality analysis. 4.3.2 Emergency Preparedness and Response • The basic steps in developing an effective program are – identifying the need for procedures – implementing written procedures, – conducting periodic tests, – continual improvement through review and revision. 4.4 Importance of Documentation and Record Keeping • documentation shall not be voluminous as it lowers effectiveness and efficiency. • Accurate and complete documented records are necessary because – the law calls for it – they can be made accessible at the point of use. – determining the validity of claims in a lawsuit – objective evidence to show that activities related to the requirements of an OH&S system have been satisfactorily performed. – reference purposes in the future. The following is a list of records that ought to be kept by an organization: – Occupational injuries and illnesses. – Fire Protection – Materials Handling/ Storage – Machinery and Machine Guarding – Welding, Cutting, Brazing Equipment – Training – Medical Records. Not all injuries and illnesses have to be recorded. They shall be classified according to work-related or non-work related first before it can be decided whether it is necessary to note the details of these job injuries and occupational illnesses. Injury or Illness Work-Related Non-work Related Fatality Non- Fatal Non-Fatal First Aid Lost Workday Non-Lost Workday RECORD DO NOT RECORD Figure 4.2: Recording of Occupational Injuries and Illnesses 4.5 OH&S Management System Audits & Verification • In order to ensure effective implementation, organization shall conduct periodically OH&S management system audits and verification of its on-site implementation. 4.5.1 Inspections There are in general four types of inspection that may be conducted. • Periodic : Conducted at regular scheduled intervals. • Intermittent : Unannounced or „surprise‟ inspections. • Continuous : Part of a day-to-day operation. • Special : One-off inspections conducted for especially hazardous situations. The area being inspected will thus determine the kind of inspection to be performed. Proper documentation of data is to be done to ensure that employees are kept on their toes. 4.5.2 Audits • Audits are commonly conducted at the organizations by corporate personnel, external professional consultants, and selected local authorities, professional or ad-hoc associations. • Basically, the organization has to perform a cost-benefit analysis and identify if the audit is an on-going process or on an ad-hoc basis, among others. 4.6 Periodic Status Review • The management shall demonstrate commitment to the effective implementation of the OH&S management system and shall undertake periodic status review to ensure maintenance and suitability of the OH&S policy as well as to ensure continual improvement. CHAPTER 5 HAZARD AND RISK ASSESSMENT 5.1Introduction to Risk Assessment Risk assessment is essentially • an integration of the findings provided by a hazard assessment and an exposure assessment • determines the adequacy of controls with respect to risks. • The elements of a risk assessment can be defined by using a multi- or n- dimensional matrix. • A matrix example of a risk assessment done on a construction sector is presented in Table 5.1. • Severity and Probability of Occurrence (Frequency) of each hazard is rated. Classify Work Activities Identify Hazards Determine Risk Decide if Risk is Tolerable Prepare Risk Control Plan Review Adequacy of Action Plan Figure 5.1 Risk Assessment Procedures IMPACT (Rating = Severity X Frequency) General Types of Physical Work Activity Illness Hazards Eye Injury Injuries Hearing Limbs (eg. (possibility of (possibilit Total Rank Problems Injury Cough, loss of sight) y of flu, fever, death) etc.) Operating a Loud noises compressed air & long 2x 2 4 Jackhammer exposures Inspection of steel girder alignment & Exposures deflection in bridges 2x 2 4 to lasers & buildings using lasers Working at elevated heights 2 Falls 3 x2 3x 2 12 without proper fall protection system Working over or near water without Drowning 2x 2 3x 2 10 wearing life jackets or buoyant work Handling flammable Fire 2x 2 2x 2 2x 2 12 2 liquids IMPACT (Rating = Severity X Frequency) General Types of Physical Work Activity Eye Injury Illness Hazards Injuries Hearing (possibility Limbs (eg. (possibilit Total Rank Problems of loss of Injury Cough, y of sight) flu, fever, death) etc.) Electrocution Handling Powder- & 2x 2 2x 2 2x 2 12 2 actuated tools Mechanical injuries Transportation of Explosion explosive materials 1x 1 1x 1 2x 2 2x 2 10 & Fire used in blasting Fatality to drivers Heavy vehicles & (caused by equipments in rollovers) or 2x 2 1x 2 2x 2 3x 2 16 1 operation to co-drivers (caused by runovers) Table 5.1: An Example of a Risk Assessment Matrix 5.2 Differences between Hazards and Risks • The word hazard always denotes a possibility or potential. Risk is however, defined as the combination of the likelihood and consequences of a specified hazardous event occurring. • The difference between hazard and risk lies in that a hazard is a possible (or potential) harm or injury, whereas a risk is the probability that a person will actually experience a specific hazard. 5.2.1 Hazard & Risk Reduction Strategies • Product reformulation or chemical substitutions are two ways of replacing a hazardous chemical component in a product with a less hazardous or totally harmless material. • In order to reduce the risks associated with a hazard that cannot be removed or reduced, it is necessary to reduce exposure. This is possible by implementing three exposure control approaches in the following order: a) Management Control through proper supervision of assignments, procedures, etc; b) Engineering Control c) Personal protective clothing and equipment 5.3 Hazards Identification 5.3.1 Agents of Hazards • Physical, chemical and biological agents can pose human health and safety hazards. • Heat, noise and vibration are some common physical agents • chemical agents are made up of naturally occurring and human made inorganic and organic chemicals. • Biological agents include viruses and bacteria. • They can be identified and described without reference to the human subjected to the associated hazard[i]. A. Physical Agents Acoutistic Sonic and ultrasonic sound, including continuous and intermittent (impact) Radiation noise Temperature Heat and cold stress Magnetic Magnetic flux densities, including those having influence on implanted medical Radiation devices and ferromagnetic tools Electromagnetic Visible light, lasers, radio frequency/ microwave radiation, ultraviolet radiation, Radiation and x-rays Radioactivity Radionuclides and radiation (alpha, beta and gamma) associated with unstable atomic nuclei or nuclear reactions Ergonomic Stress associated with mechanical tensions in musculo-skeletal system Stress Physical Impact Mechanical impact that exerts physical force on body Figure 5.2: Examples of Hazardous Agents in the Workplace[i] (Page 1 of 3) Chemical Agents Agents Presenting Physical Risk Asphyxiant Vapors displace air and thereby cause suffocation Combustible Burns when subjected to a temperature greater than 100 o F and below 200o F Corrosive Chemically burns living tissue on contact Explosive Suddenly releases pressure, gas and heat when ignited Flammable Burns when subjected to a temperature less than 100o F Irritant A non-corrosive material that causes itching, soreness or inflammation of exposed skin, eyes or mucous membranes Pyrophoric Ignites spontaneously in air at temperature of 130o F or lower Organic Peroxide Spontaneously explodes due to the formation of unstable peroxides Oxidizer Promotes or initiates the burning of combustible or flammable material Water Reacts with water to form a flammable or toxic gas Reactive Unstable/ Spontaneously explodes with production of pressure, gas, heat and possibly toxic fumes Reactive Figure 5.2: Examples of Hazardous Agents in the Workplace[i] (Page 2 of 3) B. Chemical Agents Agents Presenting Health Risk Carcinogen Causes cancer Mutagen Causes changes in genetic information that is inherited from generation to generation Poison Causes life-threatening damage to tissues or internal organs in very small amounts (e.g. several teaspoons or less) Sensitizer Causes allergic reactions after repeated exposures, with possibly severe or even life-threatening consequences Teratogen Causes malfunction of the developing fetus Toxic Causes life-threatening damage to tissues or internal organs, but in amounts greater than a poison Biological Agents Bloodborne Pathogens Disease causing organisms that may be transmitted through blood and other blood -related bodily fluids of infected persons Other pathogens Infectious diseases that may be transmitted by means other than bodily fluids of infected persons (e.g. water, air, food) Figure 5.2: Examples of Hazardous Agents in the Workplace[i] (Page 3 of 3) 5.3.2 Classifications of Hazards There are two types of hazards •one that is described in terms of the time interval between exposure to the hazard •another that is defined based on the manifestation of consequent harm or injury. Hazard Types Classification Acute Manifests in a few seconds, hours or a few days after exposure to the hazardous agent. Chronic Develop only years or decades after exposure to hazardous agent. Target- Organ Manifests only in specific organs or tissues, e.g. in nerves of hands. Systematic Manifests in overall condition of the whole body, e.g. blood poisoning or breakdown of central nervous system. Table 5.2: Classification of Hazard Types 5.4 Quantifying Exposure • As the essential link between hazard (a possibility) and risk (a probability), exposure must be examined in detail, with specific attention given to the following aspects[i]: 1. Quantitative measure (e.g. concentration of chemical inhaled) which includes the measures of the amount or the nature of the hazardous agent, as well as the measures of the duration and frequency of exposure. 2. Pathways by which the hazard comes into contact with human tissue (e.g. inhalation). 3. Mechanism(s) by which a hazardous agent is transformed or propagated from its source to a human. Often referred to as environmental transport or fate. 4. Mechanism(s) by which a hazardous agent might be transformed during its transport or propagation. 5. Individual humans or populations that might come into contact with the hazard. • As a more holistic, integrated approach to workplace health and safety becomes established, it can be expected that such quantification of community exposures to the hazards of individual worksites will become more common. • Any competent exposure analysis of industrial hazards includes a detailed description of the various specific pathways or routes by which a hazardous agent comes into contact with living tissue. Generic categories of environmental dynamics include: Introduction of materials and energies into major environmental compartments; Transformation of materials and energies within environmental compartments; Translocation of materials and energies from compartment to compartment; Concentration of materials and energies within compartments; Dissipation of materials and energies within compartments; Elimination of materials and energies within compartments. Introduction Translocation Dissipation Concentration Transformation Elimination Figure 5.3: Generic Environmental Processes that influence the dynamic flows and transformation of materials and energies in environmental compartments[i] 5.5Hazards Analysis • Checklists are usually drawn up to help in identifying hazards and hazardous operation relationships systematically. • The hazard matrix is made up of rows and columns – rows are made up of different items or function hazards. – columns store progressive information about hazardous events, causes, effects and severities, probability of occurrence, controls, verifications of controls, and remarks. Item/ Hazardous CAUSE(s) effects sev. prob. recommendations/ Functions conditions verifications 1. Natural 1. Leak 1.1 Valve Fire/ Cat. E10-3 Qualified Valve Design, Gas Supply Faults Explosion Installation, Pressure Testing, Inspection 1.2 Line Fire/ Cat E10-4 Qualified Line/ Integrity Explosion Connector Design, Faults Installation, Pressure Testing, Inspection 1.3 High Fire/ Cat Remote Pressure Relief Supply Explosion E10-5 Pressure Table 5.3: An Example PHA Matrix Checklist Format Using A Hot Water Heater[i] 5.5.1 Severity Rating • Severity of hazardous effects is also known as hazard level or criticality category. • It is a rating indicating the seriousness of an effect of a hazard on a worker or employee, and it can be defined into different categories with different values. • There is a direct correlation between effect and severity, therefore severity is ranked according to the hazard effect. • Severity rating shall be ranked based on the worst effects of a hazard mode. Description Severity Ranking Mishap Definition Catastrophic 8- 10 Any condition which may cause a permanent disabling or fatal personnel injury, or loss of one of the following: the launch or servicing vehicle; manned base; any NSTS cargo element, the loss of which could result in the manned base; major ground facility or critical support equipment. Critical 4- 7 Any condition which may cause a serious personnel injury; severe occupational illness; loss of safety monitoring, emergency control function or an emergency system, or requires use of emergency procedures; or involves major damage to one of the following: the launch or servicing vehicle; manned base; any NSTS cargo element, which could result in the loss of, or major damage to, a major SSF element; an on- orbit life- sustaining function; a ground facility; or any critical support equipment. Marginal 1- 3 Any condition which may cause major damage to a safety monitoring, emergency system, mishap of a minor nature inflicting first aid injury to personnel, or minor nature inflicting first aid injury to personnel, or minor damage to one of the following: a launch or servicing vehicle; the manned base; any NSTS cargo element, which could result in minor damage to a major SSF element; an on- orbit life- sustaining function; a ground facility; or any critical equipment. Table 5.4: Severity of the Hazardous Effect[i] 5.5.2 Probability of Occurrence • Occurrence is the ranking of likelihood that a specific cause will occur with existing controls. • The probability of occurrence, like severity, can be defined into different categories with different values; and has to be calculated for every cause of the hazards. Description Occurrence Ranking Hazard Probability Most Likely 9-10 Expected to happen in the life of the program. Probable 6-8 Could Happen in the life of the program. Controls have significant limitations or uncertainties. Remote 2-5 Could happen in the life of the program, but not expected. Controls have minor limitations or uncertainties. Improbable 1 Extremely remote possibility that it will happen in the life of the program. Strong controls are in place. Table 5.5: Probability of Occurrence of the Hazardous Effects 5.5.3 Risk Ratings • Severity and Probability factors are used to represent risk ratings • The risks are then rated according to different levels of trivial, tolerable, moderate, substantial and intolerable. • Risk ratings, such as „risk index categories‟ or „risk assessment categories‟ are used to guide management actions. Marginal Critical Catastrophic Improbable Tolerable Risk Tolerable Risk Tolerable Risk Remote Tolerable Risk Moderate Risk Moderate Risk Probable Moderate Risk Substantial Risk Substantial Risk Most Likely Substantial Risk Intolerable Risk Intolerable Risk Table 5.6: Risk Rating Table RISK LEVEL ACTION AND TIMESCALE Trivial (5) No action is required and no documentary records need to be kept. No additional controls are required. Consideration may be given to a more cost-effective Tolerable (4) solution or improvement that imposes no additional cost burden. Monitoring is required to ensure that the controls are maintained. Efforts should be made to reduce the risk, but the costs of prevention should be carefully measured and limited. Moderate (3) Where moderate risk is associated with extremely harmful consequences, further assessment may be necessary to establish more precisely the likelihood of harm as a basis for determining the need for improved control measures. Work should not be started until the risk has been reduced. Considerable resources may Substantial (2) have to be allocated to reduce risk. Where the risk involves work in progress, urgent action should be taken. Intolerable Risk (1) Work should not be started or continued until the risk has been reduced. If it is not possible to reduce risk even with unlimited resources, work has to remain prohibited. Table 5.7: Table showing the Interpretation of Risks 5.6 Logic Tree Analysis Death from Hot Water Heater OR Gas Explosion Gas Flash Crushed by Tipover Scalding (Closed Electro Fire (Temp > Area) cu-tion (Open Area) 140C) AND AND Ignition Source Heater Gas Present Heater Unsecured Leak Dislodged (Expt. R O Conc.) Figure 5.4: Example of a Fault Tree[i] Pilot Auto Light Switch Light Operation Operation • Fault trees are usually drawn with an undesired event at the time and ways that the event could happen beneath, connected to the upper event by basically two types of logic gates- “or” and “and”. – The “or” gate bears the meaning that any of the contributing events would be sufficient to cause the upper event, – the “and” gate means all events must be present for the upper event to occur. • At the same time, the trees are „limited‟ by using diamonds to represent a termination. • Double diamonds, one within one another, are used to mark insufficient information, to remind analysts to review those portions later on. • Caution must be given to maintain the correct logic within the tree. Without correct logic, the tree forms incorrect loops of circular logic and fails to portray reality. • 5.7 Iteration and Expanded Matrix Analyses • PHAs can and ought to be repeated with updated design information several times. • This is an example of a common iterative system process of going back and updating or correcting an analysis based upon newer information[i]. • It explains the need to review fault trees. • By changing matrix headings through asking different questions or more detailed questions, other types of matrices similar to the PHA are produced; such as, System Hazard Analysis (SHA) or the Operating and Support Hazard Analysis (O&SHA). CHAPTER 6 EMERGENCY RESPONSE AND PREPAREDNESS 6.1 Importance of Emergency & Contingency Plans • The existence of a sound emergency and disaster response plan in an organization often makes the difference between life and death. • all efforts in an occupational health and safety program would come to nothing if the organization is incapable or unprepared if ever an emergency or disaster were to arise. • The worst possible outcome of such a situation would probably include a large number of deaths, the total annihilation of a factory putting it completely out of operation, and the cost of the damage to the company amounting to millions of dollars. • In essence, emergency pre-planning measures can keep an event from becoming a disaster in the first place. 6.2 Types of Emergencies and Disasters • A disaster may be defined as a great, sudden misfortune resulting in loss of life, serious injury, or property damage[i]. Explosion Fire Bomb Threat Tornado/ Strikes/ Weather Violence Emergencies Radiation Accidents Medical Energy Emergencies Chemical Spill/ Vapor Release Figure 6.1: Types of Emergencies and Disasters 6.2.1 Fire • The quick action of the brigade is essential in order to minimize injury and damage, as well as to evacuate affected employees. 6.2.2 Explosion • It is highly dangerous as it occurs suddenly without warning, and can inflict severe injuries and damage. 6.2.3 Tornado/ Weather Situations • Employees should be instructed on how to evacuate their workplaces safely without leaving dangerous tasks unattended. 6.2.4 Sabotage and Terrorism/ Bomb Threats • Internal security measures have to be taken for advanced detection and early notification of local police and help forces. 6.2.5 Strikes/ Violence • Strikes, especially labour strikes, will affect operations badly.Thus, the company should be on the alert for any strikes. 6.2.6 Accidents • Accident prevention and investigation procedures should be present in the event of an accident. 6.2.7 Chemical Spill/ Vapor Release • When a chemical spill or vapor release arise, appropriate actions and personnel should be engaged for proper disposal of the hazardous materials. 6.2.8 Radiation • Even small amounts of radioactive material pose a significant threat to health. Therefore, facilities for showers and eyewash should be present and easily accessible. 6.2.9 Energy Emergencies • Energy emergencies are usually caused by fuel shortages. 6.3 What is Emergency & Contingency Planning An effective emergency plan will take into account the following factors: 1. Plans and procedures: Safest and most effective procedures that people affected by the emergency should follow. 2. Training, testing and practice: Sufficient testing to ascertain the emergency plan‟s effectiveness should be carried out, perhaps in conjunction with training and drills. 3. Communications equipment and personnel: To maintain open lines of communication, there should be adequate communication equipment and personnel assigned to such tasks. 4. Equipment: Sufficient equipment to deal with emergencies should be readily available. 5. Response: Immediate response to emergency from the authorities is of utmost importance. Regulatory Agencies Communities Media Public Fire Affair Rescue Environ- Counties Operations mental Public Health Industrial Hygiene Medical Safety Security States National Advocacy Groups Figure 6.2: Emergency Response Relationships 6.4 Elements of Emergency Plan & Response Most of the elements stated below are in compliance to the Chemical Process Safety Regulations 29 CFR 1910.39 (Employee Emergency Plans). • 6.4.1 Policy – The policy defines the attitude of the company towards emergency planning. • 6.4.2 Authority – A chain of command should be established to minimize confusion so that employees will have no doubt who has the authority for making decisions[i]. • 6.4.3 Emergency Escape Procedures and Routes – Emergency escape procedures and routes should be posted in each work area. • 6.4.4 Personnel who remain to operate critical operations • 6.4.5 Employee Accountability Procedures After Evacuation – Each supervisor should be responsible for his or her assigned employees, to ensure that the identities and status of well being of all the employees are established. • 6.4.6 Control Center – The function of the control center is to have a place where all instructions are given out and information is exchanged in case of an emergency. • 6.4.7 Rescue and Medical Duties – Emergency teams should be trained in the various types of possible emergencies and actions to be performed such as first- aid and transportation. • 6.4.8 Transportation – Injured people must be evacuated safely out of dangerous areas and the critically ill must be sent to hospital as soon as possible. • 6.4.9 Communications – A method of communications is required to alert employees of the evacuation. • 6.4.10 Training/ Practice • Training in the following areas will be useful: – Use of various types of fire extinguishers. – First- aid, including Cardio Pulmonary Resuscitation – Shut- down procedures – Evacuation procedures – Chemical spill control procedures – Use of self- contained breathing apparatus – Search and emergency rescue procedures[ii] • 6.4.11 Personal Protection and Rescue Equipment – Effective personal protective equipment should be stored in a place that is easily reached, checked, serviced and cleaned regularly. • 6.4.12 Lighting – Back up portable generators are indispensable in providing necessary lighting to carry out necessary rescue operations. • 6.4.13 Security – An off-limits area must be established by cordoning the area with ropes and signs. 6.5 Developing an Emergency Response Plan • The development of a practical and effective emergency response program is essentially a normative process. Figure 6.3 Three Phases for Devising Emergency Response Policies and Procedures[i] • 6.5.1 Risk Assessments Phase – Factors that are necessary in this phase are the sources and types of hazards, the degree of exposure and the persons exposed. – Techniques available to the planner include hazard analysis, failure modes and effects analysis, and fault and event tree analysis. • 6.5.2 Safety Judgement Phase – This phase seeks to determine the level of protection for each population under risk, while keeping in mind their social and cultural values and current regulatory standards. • 6.5.3 Making-Safe Strategy Phase – As shown in Figure 6.4, policies and procedures should address three basic types of emergency response activities: 1. Preparation Activities: Undertaken immediately upon discovery of a potential or actual emergency, prior to the initiation of any response. 2. Response Activities: Include all efforts to control the emergency and provide assistance to affected persons. 3. Follow-up Activities: Focus on post emergency actions to bring the company back to a state of emergency readiness, including revisions to emergency plans based on experience of past emergencies. Figure 6.4 Basic Emergency Response Operations[i] 6.6 First Aid in Emergency Planning – Safety programs must place proper emphasis on life- saving actions. – General approach in every emergency situation is explained below. 1. Survey the scene. Proper precautions have to be taken, especially in toxic atmospheres. Quick and decisive actions have to be made sometimes, such as whether to move the casualty or wait for proper medical personnel to arrive, seeking help from people around. 2. Do a primary survey of the victim. The victim‟s breathing rate, heart rate and level of consciousness are noted here. 3. Phone Emergency Medical Services for help. . The victim should always be brought to the hospital for a proper examinationbefore declaring his state of health. 4. Do a secondary survey of the victim. Vital conditions such the victim‟s breathing, heart rate, consciousness and any other injuries have to be monitored frequently. CHAPTER 7 OH&S Management System Assessment 7.1 Introduction • Auditing is a procedure for periodic, systematic, documented, and objective evaluation of operations and practices in meeting safety, health, and environmental requirements[i]. • It is also a quality assurance tool that can verify whether management and technical practices exist, function properly, and are adequate to meet the organization‟s goals[ii]. • An organization has to plan for annual internal and external safety audits to be conducted. • The safety audit ought to cover the entire operation that is subjected to the OH&S management system, and assess compliance with OHSAS 18001. 7.2 Reasons for Conducting Audits • One important advantage of developing a program to audit OH & S functions is that it is possible to be proactive. • Audits can complement regulatory oversight activities, provide an early warning system if problems exist and move the organization toward compliance with regulatory codes. • OH&S system audits can help increase OH&S awareness, as well as evaluate whether or not the organization successfully: v Develops organizational OH&S policies that implement regulatory and legal requirements and provide management guidance for OH&S hazards not specifically addressed in regulations. v Trains and motivates facility personnel to work in an acceptable manner and to understand and comply with legal requirements and the organization‟s OH&S policy. v Communicates relevant OH&S information externally and internally within the organization. v Applies best management practices and operating procedures, including good „housekeeping‟ techniques. v Institutes preventive and corrective maintenance systems to minimize actual and potential OH&S hazards. v Assess OH&S risks and uncertainties. v Substitutes materials or processes to allow use of the least hazardous substances feasible. v Evaluate causes behind any serious environmental incidents and establishes procedures to prevent recurrence. v Utilizes best available process and control technologies. v Uses the most effective sampling and monitoring techniques, test methods, record keeping systems, or reporting protocols. 7.3 Types of Audits There are three types of audits: – first-party audits, – second-party audits or – third-party audits. 7.4 Elements of an OHSAS Audit This section will describe the different aspects of an HSE Audit, namely: physical, material, operational, procedural, human and informational. • 7.4.1 Physical Aspects – Physical Aspects to be considered include all constructed and naturally occurring structural and physical features of the workplace and its environment as well as their spatial relationships. – Any location that may become a source of or contribute to an on-site workplace hazard or experience the risk of hazard due to the workplace can be considered a geographic area of actual risk. • 7.4.2 Material Aspects – Material aspects refer to those physical, chemical or biological substances or agent that may pose a threat to human health and safety. • 7.4.3 Operational Aspects – Plant operations include those activities undertaken as a direct consequence of production. • 7.4.4 Procedural Aspects – Procedural aspects of a comprehensive facility audit include both procedures for conducting production- oriented operations and for accomplishing non- production oriented tasks. • 7.4.5 Human Aspects – There is a need to recognize that this does not merely apply to employees only, but to all people who might be affected or at risk in one way or another due to the workplace. • 7.4.6 Information Aspects – Categories of information essential to design, implementation and management of a comprehensive workplace OH&S program includes the following, among others: Up-to-date copies of regulation and pertinent OH&S standards Written documents required by specific regulations (e.g., accident reports, emergency response procedures, hazardous waste manifests, etc.) Proceedings or minutes of meetings convened by the organizations OH&S committee – Description of all safety-related devices and equipment, including purpose, type, location, limits, and maintenance requirements – Description of all personal protective clothing, including purpose, type, location, limits, and maintenance requirements – Ambient monitoring records (for air and/or water) – Hazard and risk assessments of operations performed by facility personnel or by external consultants – Inventory of hazardous materials, products, and by-products – Evaluations and recommendations regarding OH&S incidents or conditions, as well as planned or implemented follow-up actions – Personnel training records regarding any aspect of workplace OH&S, such as names, dates and subject matter. 7.5 The Audit Process • The audit program and procedures should identify the activities and areas to be audited, the frequency of the audits, who is responsible for managing and conducting the audits, how and to whom audit results will be communicated, and requirements for auditor competence[ii]. • Before an external or internal audit is conducted, it is important to lay a foundation so that the audit can be conducted in an atmosphere of mutual respect, co-operation and confidence[iii]. • Most of the time, the following protocols for auditing regulatory compliance and organizational management practices are followed in an OH & S audit. Safety and Environmental Protocols for OH&S Audits v Hazardous Materials v Fire Hazards v Electrical Hazards v Operating Process Hazards v Machinery Hazards v Noise Hazards v Illumination Hazards v Ergonomic Hazards v Solid Waste v Air emissions and wastewater v Groundwater and Drinking Water v Hazardous Waste v Natural and Historic Resources Table 7.1: Safety and Environmental Protocols 7.5.1 Establishing the Audit Objectives • Audit objectives might include: 1. Management Priorities 2. Commercial Intentions 3. Management System Requirements 4. Statutory, regulatory and contractual requirements 5. Need for supplier evaluation 6. Customer requirements 7. Needs of other interested parties, and 8. Risks to the organization • 7.5.2 Confidentiality of Audit – The confidentiality of whatever information obtained in the course of its certification activities extends to all levels in the certification body including committees, external bodies and individuals acting on the certification body‟s behalf. – Information about the auditee organization and findings of the audits shall not be disclosed to a third party without the written consent of the auditee organization. – The auditor shall follow all documented procedures of the certification body to safeguard the confidentiality of all information obtained during all phases of the audit process. 7.6 Stage 1 Audit 7.6.1 Objective of Stage 1 Audit • To provide a focus for planning the stage 2 audit by gaining an understanding of the OHSMS in the context of the organization‟s OH&S policy and objectives, hazards identification, etc. • In particular, the organization‟s readiness for the audit can be assessed by reviewing the extent to which: – The OHSMS includes an adequate and effective process for identification of the organization‟s hazards and subsequent risk assessment – For any relevant activities of the organization, licenses are in place – The OHSMS is designed to accomplish the organization‟s OH&S policy – The OHSMS implementation programme justifies proceeding to stage 2 audit – Additional documentation that needs to be reviewed – Knowledge that has to be obtained in advance 7.6.2 Information to be obtained In this stage of audit, at least the following should be obtained : – OHSMS documentation inclusive of procedures and preferably a master list showing the cross reference of documentation to the related requirements of the standard – A description of the organization and its on-site processes – An indication of the hazards and their associated impacts and the determination of significance – The means by which continual improvement is achieved – An overview of the applicable regulations (including relevant licences and permits) and agreements with Authorities – Internal audit programmes and reports 7.6.3 Requirements of Stage 1 Audit In this stage, the certification body should: Review documents, plan and allocate resources for further document review where required and for stage 2 audit, verify that the necessary competence that will be available within the stage 2 audit team Collect necessary information and identify those issues which will need special attention during stage 2 audit Provide an opportunity for feedback of information to the organization Agree, with the organization, the details for stage 2 audit The following information may be needed for the stage 1 audit and may be required for detailed inspection during the stage 2 audit: – License / permit requirements – Records (inclusive of records of incidents, breaches of regulation or legislation and relevant correspondence with Authorities) on which the organization based its assessment of compliance with regulatory requirements – Details of internally identified nonconformance with details of relevant corrective and preventive action taken in the previous 12 months (or since commencement of the OHSMS implementation if this is less than 12 months) – Records of management reviews (at least one must be conducted) – Records of any OHSMS related communications received and any actions taken in response to them 7.6.4 Document Review – Lead Auditor should review the organization‟s documentation such as OH&S policy statements, programmes, records or manuals for meeting its OHSMS requirements. – If the documentation is judged to be inadequate to conduct the audit, the client should be informed and additional resources should not be expended until further instructions have been received from the client. – When stage 1 is not conducted by a single person, the certification body should coordinate the activities of the various team members are. . 7.6.5 Preparing for the on-site audit activities The audit team leader should prepare an audit plan to provide the basis for the agreement among the audit client, audit team and the auditee regarding the conduct of the audit. The plan should facilitate scheduling and co-ordination of the audit activities. The audit plan should cover the following: 1. The audit objectives 2. The audit criteria and any reference documents 3. The audit scope, including identification of the organizational and functional units and processes to be audited 4. The dates and places where the on-site audit activities are to be conducted 5. The expected time and duration of the on-site activities , including meetings with auditee’s management and audit team meetings 6. The roles and responsibilities of the audit team members and accompanying persons 7. The allocation of appropriate resources to critical areas The audit plan should also cover the following, as appropriate: 1. Identification of the auditee’s representative for the audit 2. The working and reporting language of the audit where this is different from the language of the auditor and/or the auditee 3. The audit report topics 4. Logistic arrangements (travel, on-site facilities, etc) 5. Matters related to confidentiality 6. Any audit follow-up actions The plan should be reviewed and accepted by the audit client, and presented to the auditee, before the on-site audit activities begin. 7.7 Stage 2 Audit On the basis of findings of the stage 1 audit, the certification body drafts audit plan for the conduct of stage 2. 7.7.1 Objectives for Stage 2 Audit The objectives are: • To confirm that the organization adheres to its own policies, objectives and procedures • To confirm that the OHSMS conforms with all the requirements of the OHSMS standard and is achieving the organization‟s policy and objectives 7.7.2 Focus of Stage 2 Audit To achieve the above objectives, the stage 2 audit should focus on the organization’s Hazards Identification and subsequent risk assessment Objectives derived from the evaluation process Performance monitoring, measuring, reporting and reviewing against the objectives Internal auditing and management review Management responsibility for the OH&S policy However, the auditor may at his or her discretion include additional areas which he or she deems necessary based on the findings of the Stage 1 Audit. 7.8 Roles, Responsibility and Activities 7.8.1 The Lead Auditor The roles, responsibilities and activities of a Lead Auditor are as follow: 1. Consulting with the client and the auditee, if appropriate, in determining the criteria and scope of the audit 2. Obtain relevant background information necessary to meet the objectives of the audit 3. Determining whether the requirements for an audit as given in ISO 14010 have been met 4. Forming the audit team giving consideration to potential conflicts of interest, and agree on its composition with the client 5. Directing the activities of the audit team according to the guidelines of ISO 14010 and ISO 14011 6. Preparing the audit plan with appropriate consultation with the client, auditee and audit team members 7. Communicating the final audit plan to the audit team, auditee and client 8. Coordinating the preparation of working documents and detailed procedures, and briefing the audit team 9. Seeking help to resolve any problems that arise during the audit 10. Recognizing when audit objectives become unattainable and report the reasons to the client and the auditee 11. Representing the audit team in discussions with the auditee, prior to, during and after the audit, 12. Notifying the auditee without delay, of the audit findings of critical nonconformance 13. Reporting to the client on the audit clearly and conclusively within the time agreed with in the audit plan 14. Making recommendations for improvements to the management system, if agreed in the scope of the audit. The lead auditor must also ensure that all rules and regulations of the auditee organization, especially those relating to occupational health and safety issues, made known to the Audit Team are followed. 7.8.2 The Auditor The roles, responsibilities and activities of an Auditor are as follow: a) Following the directions of and support the lead auditor b) Planning and carrying out the assigned task objectively, effectively and efficiently within the scope of the audit c) Collecting and analyzing relevant and sufficient audit evidence to determine audit findings and reach audit conclusions d) Preparing working documents under the direction of the lead auditor e) Documenting individual audit findings f) Safeguarding documents pertaining to the audit and return such documents as required g) Assisting in writing the audit report The auditor must follow all rules and regulations, especially those relating to occupational health and safety issues, made known to them. 7.8.3 The Audit Client ISO 19011 defines the audit client as an organization commissioning the audit. The client responsibilities and activities are as follow: a) Determining the need for the audit b) Contacting the auditee to obtain its full cooperation and initiating the process c) Defining the objectives of the audit d) Selecting the Lead auditor or auditing organization and, if appropriate, approving the composition of the audit team e) Providing appropriate authority and resources to enable the audit to be conducted f) Consulting with the lead auditor to determine the scope of the audit g) Approving the audit criteria h) Approving the audit plan i) Receiving the audit report and determining its distribution 7.8.4 The Auditee ISO 19011 defines the auditee as the organization to be audited. The roles, responsibilities and activities of the auditee are as follow: a) Informing employees about the objectives and scope of the audit as necessary b) Providing the facilities needed for the audit team in order to ensure an effective audit process c) Appointing responsible and competent staff to accompany members of the audit team, to act as guides to the site and to ensure that the audit team is aware of health, safety and other appropriate requirements. d) Providing access to the facilities, personnel, relevant information and records as requested by the auditors e) Cooperating with the Audit Team to permit the audit objectives to be achieved f) Receiving a copy of the audit report unless specifically excluded by the client Pertaining to item 7.8.5 c, in organizations, rules and regulations relating to any GMP, HACCP and other occupational health and safety issues are particularly important and shall be followed by the Audit Team. 7.9 Audit Sampling Techniques The decision on sample size is heavily dependent on the Auditor‟s skills, experience, statistical knowledge and time available for the audit. 7.9.1 Determining Sample Size The following guidelines should be used for determining the sampling size during an audit: a) The risk associated with the operation or activity b) The number of different or similar operations or activities c) The number of sites or locations where the activity is performed d) Whether the activity has customer or stakeholder specified requirements, or is governed by legislation or other requirements e) Competence of the Auditee performing the activity. 7.9.2 Benefits of Audit Sampling Some of the benefits of sampling are: a) It may be impossible to audit all activities of an organization and sampling offers the only feasible alternative b) Sampling results when carried out with due professional care and adequate statistical knowledge offer a high level of confidence (accuracy) in the determination of the effectiveness of the audited system c) It is proven in many studies that sampling offers reliable results while saving time and money d) Minimize disruption to the business and operation of the auditee 7.9.3 Risks of Audit Sampling Some of the risks of Audit Sampling are: a) Sampling may not be appropriate for certain activities such as checking the records of cyanide used in an electro-plating organization b) Lack of knowledge of occupational health and safety, technology, technical and environmental aspects of facility operation and sampling techniques will result in ineffective sampling plan c) Sampling requires the process to be stable and this may be difficult to achieve in certain activities where abnormal fluctuations can occur 7.10 Use of Audit Checklist – Prepared by the Audit team during the document review and pre-audit – Serve as an aid to audit planning while on-site. – Assessment investigation should pursue and cover any other aspects for conclusion. – Clues indicating nonconformities should be noted and investigated. – Note the outcome (acceptable, nonconformance, observation or legal compliance) for each audited item. – Completed checklist support the audit reporting to ensure its comprehensiveness. 7.10.1 Advantages and Disadvantages of Using Checklists Advantages: a) Checklists help auditors to organize, discuss, plan and conduct audits, and report audit results. b) Checklists facilitate a systematic and effective approach to auditing and help auditors to: i. ensure that all systems, operational areas and processes are sufficiently covered. ii. ensure that the auditing process is systematically done without sidetracking, thus saving the time and effort of both the auditees and auditors. c) Developing a checklist requires the auditor to understand the documented system in detail. It helps the auditor to establish a better understanding of the auditee‟s activities during the audit. d) Checklists allow the auditor to systematically identify high risk areas. With a checklist an auditor can identify key questions relating to this area more easily. e) Checklists may be sent to a supplier to complete before an audit is conducted to ascertain facts. f) Checklists can be a good source of information for future audits or for designing better and more comprehensive checklists. Disadvantages: a) Checklists may lead to limiting questions that generate “yes/no” answers. Further comments are usually useful and necessary. Effort should be made to avoid this problem. b) Checklists may breed complacent auditors who just go through the questions without getting into the details and seeking objective evidence. c) Use of a checklist may lead an auditor into using a predetermined sequence of thought and questions and may prevent an auditor from using his own discretion. d) Checklists can lead to a boring and rigid auditing process if the auditor is not flexible in exercising his judgment. e) A general checklist may result in a nonfocused audit; details may be overlooked. 7.10.2 Guide to Checklist Design In developing a checklist for a particular department or function, an auditor can start by doing the following: a) Examining the standard clauses that are relevant to the area of interest. For example, in auditing the company‟s occupational health and safety policy, the primary requirement is expressed in Clause 4.2. b) Looking at the specific statutory requirements, for example, in the control of hygiene for the food industry, and the control of dangerous chemicals such as cyanide. c)Reviewing the documented OH&S manual, operational procedures, internal standards and site emergency plans. It is wrong to assume that voluminous OH&S documents attest to an effective environmental management system. Extensive documentation does not ensure that OH&S is being implemented effectively or at all. Therefore, time and effort should be spent on this documentation to set questions that will test the documented system. d)Performing a task analysis of the process model. By going through the typical five inputs of a process – operators, machines, methods, materials and environment, auditors would be able to establish questions such as: “Does the operator receive formal OH&S training?”, “Are the procedures adequate and documented?”; and “Are the emission controlled to the requirements?”. e)Interacting with staff during the pre-audit plant walkthrough. A preliminary plant visit familiarizes the auditor with the facilities to be audited. It provides an overview of policies, procedures, standards and process flow. The impression that an auditor gains in this visit may help him or her to prioritize the areas of audit and provide a guide for further examination. 7.11 Conducting the Audit The following conducts of an audit process are good practices to be observed by the Audit Team (ref ISO 19011, Clause 6.5 & 6.6, ISO/IEC Guide 66, EAC/G5, IAF Guidance and IRCA requirements, where applicable). 7.11.1 Opening Meeting At an opening meeting (ref ISO 19011 clause 6.5.1) with the company‟s senior management, the lead auditor shall perform the following tasks: a) Introduce the members of the audit team, including a brief description of their skills and assigned responsibilities, to the auditee‟s management b) Review the audit scope, objectives, audit plan and agree on the audit timetable c) Where applicable, confirm the specification standard to be applied d) Provide a short introduction to the methods and procedures to be used in the audit e) Establish the official communication link between auditors and auditees f) Confirm that the resources and facilities needed by the audit team are available g) Confirm the time and date of the closing meeting h) Promote the active participation by the auditee i) Review relevant site safety and emergency procedures for the audit j) Confirm the time and date of the closing meeting. 7.11.2 Audit Methodologies The method or a combination of methods to be used in order for the audit to be effective depends greatly on the auditee‟s system, complexity of activities and processes, culture of the country, location of sites (for multi-site audits) and size of the organization. Horizontal Audit Horizontal audit focuses on one element of OHSAS 18001 at a time to audit horizontally across the organization departments for compliance to the element. Upon completion of an element, say clause 4.3.1, the auditor moves on to the next applicable requirements, in this case clause 4.3.2. . This method is suitable for small organizations where the access to all areas, facilities and information are readily available. Vertical Audit Vertical audit focuses on each department of the organization to audit all requirements of OHSAS for conformance by the department. Upon its completion, the auditor moves on to the next department assigned to him. This method is suitable for large organizations as well as in multi- sites audit where the access to all areas, facilities and information are difficult. 7.11.3 Collecting Audit Evidence OHSAS 18001 defines audit evidence as verifiable information, records or statements of facts, which can be qualitative or quantitative. Audit evidence, on a sampling basis, is typically collected through interviews, examination of documents, observation of activities and conditions, existing results of measurements and tests or other means within the scope of the audit. Evidence obtained from interview should be verified by obtaining supporting information from independent sources such as observation and existing records. 7.11.4 Recording Audits Findings OHSAS 18001 defines audit findings as results of the evaluation of the collected audit evidence compared with the audit criteria. The audit team should: – Review all audit evidences to determine where the OHSMS does not conform to the OHSMS criteria – Document all non-conformances in a clear, concise manner and supported by audit evidences – Review audit findings with the responsible auditee management in order to obtain acknowledgement of the factual basis of all findings of nonconformance. 7.11.5 Audit Team Meeting The purposes of regular meeting are to: a) Detect consistent nonconformance across different functions or department which may indicate major nonconformance or systemic failure b) Clarify uncertainties regarding audit plan, requirements of applicable standard or legal compliance issues with the Lead Auditor, Technical or Legal expert c) Highlight areas for particular attention to other Audit Team members d) Provide feedback to the Lead Auditor concerning the audit team performance and progress so that he can coordinate or make changes to improve the audit plan and timetable, where necessary 7.11.6 Reporting Audit Findings – Audit findings should be based on facts obtained during the audit that are substantiated by objective, verifiable evidence accumulated during the assessment process. – Auditors should avoid focusing on minor details and system technicalities to the extent that they lose sight of the audit purpose. – It is essential to focus on the significant deficiencies and nonconformance with the audit objectives. – The auditor should issue and sign the Non conformance Report (NCR) form and discuss it at a convenient time with the appropriate management representative (MR). – The MR shall be asked to sign the NCR form to indicate its acceptance and agreement to resolve the nonconformance. – If at any time the company is able to provide acceptable corrective action against an NCR, then the action may be verified and the NCR closed out by the lead auditor. 7.11.7 Closing Meeting The main purpose of this meeting is to present audit findings to the auditee in such a manner as to obtain their clear understanding and acknowledgement of the factual basis of the audit findings. The following are normally observed during the closing meeting: a) Thank the auditee for their assistance and cooperation b) Circulate an attendance sheet for record purposes c) Present, discuss and obtain acknowledgement on NCRs. The responsibility of proposing corrective actions should always lie on the auditee and not the audit team. d) Resolve disagreements. Final significance and description of the audit findings ultimately rest with the Lead Auditor, though the auditee or client may still disagree with these findings e) Present an objective overview of the audit findings and the strength and weakness of the organization‟s OHSMS f) Arrange a provisional revisit date, if necessary g) Lead Auditor states his recommendation h) Inform the company that it will be notified of the results of the audit directly from the certification body i) Close the meeting and leave all NCRs with the company so that it can initiate corrective actions 7.12 Auditing Skills 7.12.1 Effective Interviewing Effective interviewing requires an ability to ask appropriate questions, to listen actively, and to articulate and interpret thoughts. The following pointers serve as a guide for an effective interview: a) Be a participative and not an authoritarian auditor. Create an encouraging atmosphere for discussion with the auditee. Do not start to give instructions to the auditee b) Be open, trusting and polite. Do not assume negative roles such as policing, suspicious and accusatory c) Set a friendly tone d) Be prepared to slow down and allow time for auditee to think, if necessary e) Be sensitive to the non-verbal behavior, such as body language and attitude, of yourself and the auditee f) It is useful and constructive to point out that the aim of the audit is to verify the company‟s environmental management system for conformance and not to find fault with individual personnel 7.12.2 Questioning Techniques 1. Effective questioning techniques can elicit answers, uncover information and diffuse tension. 2. In essence, an auditor should know what he is asking, why he is asking it and how to ask it on the basis of the background of the auditee and the information required. 3. A good combination of different questioning techniques is also vital and paraphrase if necessary, to ensure that the auditee understand your question. Type of Description Examples Comments Question An open question will lead to a What is your interpretation of the Open questions may sidetrack your wide range of answers. result obtained? conversation and focus. Open Generally, use it to seek the Could you tell me how you process It may be difficult for the auditee auditee‟s opinion, to get an these intermediate results? to respond. explanation/description from the How do you implement the waste They may be so open that you will auditee or to allow for reasoning management program? get general answers. on certain matters. Do you know that there is a These questions provide limited A closed question is used to get a documented procedure for this? information and if you are in search of “yes” or “no” answer, while a What‟s your responsibility? an extended answer, use an open Closed/ direct question will invite a short Has this specific environmental impact question. Direct answer with one or a few words. been monitored? Be careful of the “tone” when you These questions are used to get use this type of question. specific information. As a guide, avoid using more than three consecutive closed or direct In what way was corrective action questions. These are open questions, but completed? If Probing/ they aim at getting more or Could you provide me with some you need to encourage the auditee to Clarifying clarifying information about a examples on these? elaborate, use this type of question. subject by specifying conditions. What do you mean by “referring to the Avoid frequent use as the auditee guidelines on the site emergency plan”? may think that you are not listening. You do check for the accuracy of the This type of questions should be Leading A leading question suggests an equipment every morning, don‟t you? avoided as it may lead to biased answer, as the answer is normally You determine your sample size based information. implied in the question. on the sampling table, don‟t you? Don‟t you agree with me that you have Avoid this type of questions. Interrogative These questions put the auditee not correctly verified the incident reports /Antagonistic on the defensive. according to the internal standards? Table 7.2: Different Types of Questions 7.12.3 Active Listening – Listening skills can be improved by observing the following pointers: a) Be friendly and support the auditee whenever possible. Indicate that you are listening by nodding your head, frequent comments such as “Yes”, “That is a good practice” when used appropriately, can demonstrate your receptiveness and encourage the auditee to give more information b) The auditing process should be controlled in the most efficient way. When the information is too lengthy, you may ask the auditee to summarize. However, when the information provided by the auditee is too brief, you should ask the auditee to elaborate c) Be observant and concentrate on what the auditee is saying. You should ask further questions if you have any doubts or when you detect inconsistencies in what he has said d) Avoid any actions that may distract the auditee. Do not talk or interrupt the auditee while the auditee is speaking e) Be patient and allow ample time for the auditee to speak f) It sometimes pays to repeat what the auditee has said to confirm that you have correctly understood what he or she had said. 7.12.4 Understanding Cultural Diversity The five different dimensions of culture are the value, belief, pattern of thought, language and body languages. Some examples of cultural diversities are: 1. Japanese prefers greater physical distance than the Americans 2. Female are not allowed in places of worship in some Islamic countries 3. Different semantics of languages in different countries 7.13 Preparation of Audit Reports After conclusions have been made, a final audit report has to be submitted to provide feedback to relevant parties, so that corrective actions can be taken. The final report should include the following elements: • Audit objectives and scope, and general information on the auditee. • Particulars of the audit plan, identification of auditors and audited representatives, as well as the date and areas subject to audit. • Audit findings such as general observations, description of cases of non- conformity, relevant CARS and recommendations, if any. • Auditor‟s appraisal. • System‟s ability to achieve stated OH&S objectives • Audit conclusion 7.14 The Certification Process Company seeking registration contacts a Request for certification body and gives details of more details its activities and scope of its system N Application N Sufficient details? Reject or Refuse OK? if the scope is not Y within the capability of Y Scope Review to select audit team the certification body End OK to Proceed? N Surveillance STAGE 1 Close out NCR Pre-audit at company premises, collect information for planning STAGE 2 audit Assessment NCR Recommendation Document Assessment + STAGE 2 Non Y NCR Site Assessment Visit Conformance N Written evidence of Audit Team Formation corrective actions by company Figure 7.1: The Certification Process Chapter 8 Comparison of OHSAS 18001, BS 8800 and ISO 14001 8.1 Significant Differences between OHSAS 18001 & BS 8800 • The publication of BS 8800 in 1996 managed to fulfill part of the latter‟s requirements, but it only offers guidance on implementing an OH&S management system, and is not intended for certification purposes. • Subsequently, OHSAS 18001 was developed to meet the market‟s growing demand for a common certification for OH&S management, which could be recognized worldwide. 8.2 Similarities between OHSAS 18001, BS 8800, ISO 14001 • The format and structure of OHSAS 18001 was deliberately based on ISO 14001 when it was developed. Unlike BS 8800, OHSAS 18001 defines the critical management elements, which could be included in a health and safety management system but not how they could be achieved[ii]. The core approach that OHSAS 18000, BS 8800 and ISO 14001 adopt, basically follow these steps: 1. Establishing a policy 2. Planning: (a) Determine legal requirements (b) Set objectives and targets (c) Arrange management program 3. Implementation and operation: (a) Organize structure (b) Delegate responsibility (c) Conduct training and Promote awareness (d) Ensure competence (e) Establish communication and documentation systems (f) Implement Operational Control (g) Data and document control (h) Prepare emergency response plan 4. Checking and Corrective Action: (a) Monitoring and measurement (b) Corrective action (c) Records (d) Audits OHSAS 18001: 1999 BS 8800: 1996 Clause Clause Clause Clause (Based on ISO ISO 14001 ISO 9001: 2000 14001) 1 Scope 1 Scope 1 Scope 1 Scope 2 Reference Publications 2 Informative 2 Normative 2 Normative References References References 3 Terms and Definitions 3 Definitions 3 Definitions 3 Definitions 4 OH & S Management 4 OH & S 4 Environmental 4 Quality Management System Elements Management Management System System Elements System 4.1 General Requirements 4.0. General 4.1 Requirements General 4.1 General 1 Requirements Requirements 4.2 OH & S Policy 4.1 OH&S Policy 4.2 Environmental 5.3 Quality policy Policy 4.0 Initial Status A.4.2.1 (Not 2 Review mandatory but good practice) Initial Env. Review 4.3 Planning 4.2 Planning 4.3 Planning 5.4 Planning 4.3.1 Planning for Hazard 4.2. Risk Assessment 4.3. Environmental 5.2 Customer Focus Identification, Risk 2 1 Aspects Assessment & Risk Control 4.3.2 Legal and other 4.2. Legal and other 4.3. 4.3.2 Legal and 5.2 Customer Focus requirements 3 requirements 2 other requirements Table 8.1: Table Showing the Correspondence between OHSAS 18001, BS 8800, ISO 14001, & ISO 9001 (page 1 of 3) Clause OHSAS BS 8800: 1996 (Based on Clause Clause Clause 18001: 1999 ISO 14001) ISO 14001 ISO 9001: 2000 4.3. Objectives 4.2 Including personnel and 4.3.3 Objectives 5.4 Quality Objectives 3 .4( resources for the .1 a) organization to achieve its policy. 4.3. OH&S 4.2 OH & S Management 4.3.4 Environmental 5. Quality Management 4 Management .4 Arrangements Management 4.2 System Planning Program(s) Program(s) 4.4 Implementation 4.3 Implementation and 4.4 Implementation 7 Product Realization and Operation Operation and Operation 4.4. Structure and 4.3 Structure and 4.4.1 Structure and 5.5. Responsibilities & Authority 1 1 Responsibility .1 Responsibility Responsibility 5.5. Management Representative 2 4.4. Training, 4.3 Training, Awareness & 4.4.2 Training, 6.2 Competence, Awareness 2 Awareness & .2 Competence Awareness & .2 and Training Competence Competence 4.4. Consultation 4.3 Communication 4.4.3 Communication 5.5 Internal communication 3 and .3 .3 Communicatio 4.4. n Documentation 4.3 OH & S Management 4.4.4 Environmental 4.2. General 4 .4 System Documentation Management 1 4.2. System 2 Quality Manual Documentation 4.4. Document and 4.3 Document Control 4.4.5 Document Control 4.2 Control of Document 5 Data Control .5 .3 Table 8.1: Table Showing the Correspondence between OHSAS 18001, BS 8800, ISO 14001, & ISO 9001 (page 2 of 3) OHSAS 18001: Cl BS 8800: 1996 Cl Cl Clau 1999 aus (Based on ISO aus ISO 14001 aus ISO 9001: 1994 se e 14001) e e 4.4.6 Operational 4.3 Operational Control 4.4 Operational Control 7 Product Realization Control .6 .6 4.4.7 Emergency 4.3 Emergency 4.4 Emergency 8. Control of Preparedness .7 Preparedness and .7 Preparedness and 3 nonconforming product and Response Response Response 4.5 Checking and 4.4 Checking and 4.5 Checking and 8 Measurement, analysis Corrective Corrective Action Corrective Action and improvement Action 4.5.1 Performance 4.4 Monitoring and 4.5 Monitoring and 7.6 Control of monitoring & Measurement .1 Measurement .1 Measurement measurement devices and Monitoring 8.4 Analysis of Data 4.5.2 Accidents, 4.4 Corrective Action 4.5 Non- Conformance 8.3 Control of Incidents, Non- .2 .2 and Corrective and nonconforming product Conformances, Preventive Action 8.5.2 Corrective Actions and Corrective 8.5.3 Preventive Actions and Preventive 4.5.3 Action and Records 4.4 Records 4.5 Records 4.2 Control of Records Records .3 .3 .4 Management 4.5.4 Audit 4.4 Audit 4.5 Environmental 8.2 Internal Audits .4 .4 Management System .2 Audit 4.6 Management 4.5 Management 4.6 Management Review 5.6 Management Review Review Review Table 8.1: Table Showing the Correspondence between OHSAS 18001, BS 8800, ISO 14001, & ISO 9001 (page 3 of 3) 8.3 Advantages of Integrating OHSAS 18001 & ISO 14001 • For organizations that already have the ISO 14001 environmental management system implemented, there is no need for a complete set of new procedures to be prepared for the OH&S system. • If existing management procedures exist, they could be modified or cross-referenced. • This approach could make it quicker and cheaper for an organization to develop and implement an OH&S system. CHAPTER 9 LEGAL ASPECTS & LOCAL LEGISLATION 9.1 Employment Law In the context of Occupational Health and Safety Legislation, we are concerned with the following: v Workplace Safety Law v Worker‟s Compensation v Damages v Tort Law 9.2 Workers’ Compensation The following sections will look into details of workers‟ compensation laws. 9.2.1 Objective of Workers’ Compensation Laws The six basic objectives that underlie workers‟ compensation laws are: 1. To provide sure, prompt, and reasonable income and medical benefits to work related accident victims, or income benefits to their dependents, regardless of fault. 2. To provide a single remedy, and reduce court delays, cost and workloads arising out of personal injury litigation. 3. To relieve public and private charities of financial drain incident to uncompensated industrial accidents. 4. To eliminate payment of fees to lawyers and witnesses, as well as time consuming trials and appeals. 5. To encourage maximum employer interest in safety and rehabilitation through an appropriate experience-rating mechanism. 6. To promote frank study of causes of accidents (rather than concealment of fault), thus reducing preventable accidents and human suffering. 9.2.2 Requirements for Benefits under Workers’ Compensation Four conditions or criteria must be established in order for the injured worker or surviving dependents to establish a claim for compensation. 1. There has to be an injury. 2. The injury must have resulted from an accident. 3. The injury must have arisen out of the worker‟s employment. 4. The injury must have occurred during the course of employment. However, there are exceptions disallowing workers to claim compensation as a result of actions or inactions on the part of the employee. 1. Intoxication or the use of a controlled substance 2. An intentional self-inflicted injury 3. The commission of a felony or a misdemeanor 4. The willful failure, or refusal, to obey a reasonably written or printed safety rule of the employer 5. Horseplay or altercation with a fellow employee 6. Falsification of application of employment 9.2.3 Benefits Provided under Workers’ Compensation – Cash benefits will depend on the level of disability that the worker suffers as a result of an injury caused in the workplace. – Medical benefits give the worker coverage over hospitalization, consultation and other medical bills incurred as a result of the work related injury. 9.3 Federal Occupational Safety and Health Act (OSHA) • 9.3.1OSHA’s Objectives OSHA‟s objectives are as follows: 1. Encourage employers and employees to reduce workplace hazards and to implement new or improved existing safety and health programs. 2. Provide for research in occupational safety and health and develop innovative ways of dealing with occupational safety and health problems. 3. Establish “separate but dependent responsibilities and rights” for employers and employees for the achievement of better safety and health conditions. 4. Maintain a reporting and record-keeping system to monitor job-related injuries and illness. 5. Establish training programs to increase the number of competent occupational safety and health personnel. 6. Develop mandatory job safety and health standards, and enforce them effectively. 7. Provide for the development, analysis, evaluation, and approval of state occupational safety and health programs. 9.3.2 Employers’ Responsibilities under OSHA – He must ensure that the workplace complies with OSHA standards. – Records of work-related injuries and illnesses and exposure to toxic materials are to be kept and maintained. – Effort should be made to minimize or reduce accidents, as well as to provide medical examinations to employees as required by OSHA standards. 9.4 Local (Singapore) Movement In the Ministry of Manpower‟s quest to attain their objectives, the services they provide include the following: 1. Registration of factories. 2. Inspection of factories to check for compliance with the Factories Act and related safety laws. 3. Investigation of accidents to determine the causes and to recommend measures to prevent recurrence. 4. Registration and inspection of pressure vessels and lifting equipment. 5. Setting standards on OH&S. 6. Providing education and training in OH&S. 7. Promotion of OH&S. • In addition, the ministry is committed to ensure that safety requirements are adequate and relevant. • Moreover, a permanent exhibition on occupational health and safety occupies an area in the head office of Ministry of Manpower building located at Havelock Road. • The ministry also publishes various material regarding OH&S. An example is the OSH newsletter which is published quarterly and distributed free of charge. • Other pamphlets regarding OH&S information such as “Fire Prevention Awareness for Industrial Workers”, “How to Report Accidents to the Ministry of Manpower”, and “Department of Industrial Safety” can be readily obtained from their office. 9.5 The Factories Act In this Act the term „factory‟ covers all premises where workers are employed: (a) To make any article, or part of it, (b) To alter, repair, clean or break up any article, or (c) To adapt any article for sale. This work shall be carried out for trade or for gain, for a more detailed interpretation of the term „factory‟, reference should be made to Appendix A – Interpretation of „Factory‟. 9.5.1 Registration of Factories – All factories must be registered with the Department of Industrial Safety of the Ministry of Manpower. – The certificate of registration to the occupier will only be issued when the premises satisfy the requirements of a factory. • 9.5.2 General Health Requirements Aspects of general health such as cleanliness, overcrowding, ventilation, noise and vibration, lighting, drainage and toilets are explained in this section. • 9.5.3 Welfare and Equipment Safety – It is the management‟s responsibility to ensure that all equipment, structures and the working environment are safe for everyday usage. – Measures and precautions to prevent explosions and fires are stated in detail in the Act. In addition, the Act also sets safety standards for the operations, maintenance and inspections for lifting equipment, pressure vessels and gas plants. – The Act goes on to list the various types of personal protective equipment that must be provided free to workers who are exposed to hazards, such as: approved head protection, hand protection, respirators and goggles, etc. – The minimum requirements of employee‟s welfare, for example, drinking water, washing facilities and first aid are set out. • 9.5.4 Toxic Substances – The proper containment, labeling of toxic substances is described in the Act. – Furthermore, precautionary measures to prevent the release of harmful substances are listed. – The MSDS states that the necessary precautions for safe use and must be available to all persons who may be exposed to the substance. • 9.5.5 Medical Examinations and Accident Reporting – The Factories Act requires workers who are exposed to a list of substances and environment to undergo regular medical examinations specific to the type of hazards involved. These examinations must be paid for by the employer. – Serious accidents, illnesses and injuries as listed in the act must be reported to the Chief Inspector of Factories. • 9.5.6 Safety Officers, Committees and Record Keeping – In addition, factories employing 50 or more workers are required to form a safety committee comprising representatives from both management and workers. – The types of records that the occupier is required to keep for a period of at least five years are also listed. Type of Safety Officers Required Classes of Factories Full Time Part-Time Shipyard Employs 100 or more persons Employs less than 100 persons Woodworking Employs 100 or more persons Not applicable Refining/Processing of petroleum Employs any number of persons Not applicable and petroleum products Garments manufacturing Not applicable Employs 500 or more persons Project of a contract sum of $10 Building operations or works of Project of a contract sum of $50 million or more, but less than $50 engineering construction million or more million Others (except garments Employs 100 or more persons, but Employs 500 or more persons manufacturing) less than 500 persons Table 9.1 Descriptions of Factories for Full-Time or Part-Time Officers[i] 9.6 Code of Practice – Safety and Health at Construction Worksites • It provides a convenient and safe reference for the site supervisor or manager in ensuring safety is upheld in the course of work. • As can be seen in Table 9.2, there are many processes that occur in any construction worksites, such as welding, demolition, and pile driving, and these processes are often dangerous if not carried out properly. • In addition to regulating work processes, precautionary measures such as fire prevention, and safety organization are described. These measures will certainly reduce the incident rate of fire and accidents. Part 1 Part 2 1 General Provisions 1 Scaffolds 2 Workplaces and Equipment 2 Roofworks 3 Safety Organization 3 Excavation 4 Ladders and Stairs 4 Handling Materials 5 Lifting Appliances and Equipment 5 Structural Steel Erection 6 Ropes, Chains and Accessories 6 Erection of Prefabricated Parts 7 Hand Tools, Portable Power Driven Tools 7 Welding and Flame Cutting 8 Pile Driving 8 Demolition 9 Concrete Work 10 Prevention of Fire Table 9.2 Content of Code of Practice on Safety and Health at Construction Worksites – Parts 1 & 2 [i] [ii] 9.7 Courses Conducted by The Occupational Safety & Health (Training & Promotion) Center in Singapore The courses conducted are divided into four categories, with the courses in each category meant for the appropriate class of persons. The four categories are: • 9.7.1 OSH Courses for Supervisors – These courses for supervisors are geared to train supervisors on the practical measures for accident prevention in their respective industries. – The supervisors are also taught their role in accident prevention. – The courses also cover motivation, communication and accident investigation techniques and fire prevention and control. • 9.7.2 OSH Courses for Managers – The courses for managers are designed to help senior personnel in industry to effectively manage safety in the workplace through the development and implementation of safety systems and also the monitoring and measurement of safety performance. • 9.7.3 Courses for OSH Personnel – Our courses for OSH personnel are geared to impart the necessary knowledge and skills to the participants to enable them to effectively carry out their duties. • 9.7.4 Safety Courses for Workers – These courses for workers are intended to inform workers of the nature and types of hazards that they may be exposed to in the course of their work, and the measures and precautions that need to be taken by them to prevent accidents. Courses for OSH OSH Courses for OSH Courses for Safety Courses for Personnel Managers Supervisors Workers Safety Officers Safety Management Basic Industrial Shipyard Safety Instruction Training Course Course Safety and Health Course for Workers (General Course for Trade) Supervisors Shipyard Safety Safety Instruction Building Shipyard Safety Instruction Assistants Course Course for Ship Repair Construction Safety Course for Workers (Hot- Managers Supervisors Course work Trade) Industrial First Aid Construction Safety Shipyard Supervisors Shipyard Safety Instruction Course Course for Project Safety Course Course for Workers (Painters Managers Trade) Industrial First Aid Safety Instruction Construction Safety Refresher Course Course (Manhole) for Orientation Course for Supervisors Workers Industrial Hygiene Oil/Petrol Chemical Safety Orientation Course Course Industry Supervisors (Manhole) for Workers Safety Course Training Course for Lifting Supervisors Construction Safety Safety Committee Safety Course Orientation Course Members (Tunneling) for Workers Shipyard Safety Power Press Safety Assessors (Hot-work) Course for Certification Course Supervisors Table 9.3 Courses Conducted at OH&S Training Center Chapter 10 IRCA Auditor Certification Scheme 10.1 Introduction (Ref: IRCA/503) The OH&S Scheme is based on the key standards: OHSAS 18001:1999, Occupational Health & Safety Management Systems - Specification HSG 65, Successful Health & Safety BS 8800, Guide to Occupational Health & Safety Management Systems And the auditing guidance standard: ISO 19011:2002, Guidelines on Quality and/or Environmental Management Systems Auditing 10.2 The OH&S Scheme The IRCA Auditor Certification Scheme recognized that you understand and are competent (depending on the grade awarded) to: • Uphold the principles of proper ethical conduct, fair presentation and due professional care • Communicate clearly orally and in writing with personnel at all levels of an organization • Plan and organize an audit of an OH&S management system • Identify and understand relevant business processes • Evaluate objective evidence and determine the effectiveness of an OH&S management system • Report accurately audit findings and conclusions • Lead the audit team and manage the audit process • Audit a management process 10.3 Certification Grades The OH&S Scheme has five grades of certification: • OH&S Internal Auditor • OH&S Provisional Auditor • OH&S Auditor • OH&S Lead Auditor • OH&S Principal Auditor For more information, please refer to the IRCA official website at www.irca.org CHAPTER 11 CASE STUDY OF A CONSTRUCTION COMPANY 11.1 Introduction • This example is given in the context of the construction sector to illustrate some aspects on how to develop the Occupational Health and Safety Management System following the OHSAS 18001: 1999 standard. 11.2 Company Profile • XYZ Pte Ltd is a construction company in Singapore. • The employees of the company are very often exposed to occupational health and safety risks and hazards. • Some of these risks and dangers that they experienced can be eliminated from their tasks. • Thus, the company‟s management has decided to implement an OH&S system following the OHSAS 18001: 1999 specification standards. 11.3 XYZ Pte Ltd OH& S POLICY The OH&S Policy of XYZ Pte Ltd is presented in Figure 11.1. It is the policy of our company to ensure every employee works under the safest possible conditions. In recognition of this, we will constantly work towards: • Providing our employees a safe and healthful working environment. • Providing safe working equipment and personal protection. • Increasing risk and consequence awareness. • Ensuring the best first aid and medical service available in the case of injury • Reducing legal liability by showing due diligence. • Improving business performance. • Creating a positive corporate image. Peter Ho Peter Ho (President) Edward Ong Edward Ong (Safety Director) 11.4 XYZ Pte Ltd Organization Structure and Responsibility The organization‟s structure, responsibilities and accountabilities with respect to OH&S requirements are presented in Figure 11.2. Duties and responsibilities of the Safety Director include: Ensuring the OH&S system is properly implemented. Ensuring the overall effectiveness of the safety program. Review and analysis of accident information, safety meeting reports, etc. Communication of pertinent information to all the jobs and shops. Duties and responsibilities of the Superintendent include: Review of all accident investigations and safety inspection reports for the job or shop. Passing of safety information along to all foremen. Maintenance of an accident log to help in identifying accident trends and problem areas so that additional safety effort can be directed as needed. When necessary, advise contractors, etc., of physical changes or new safety regulations. Conducting regular scheduled foremen‟s meetings at which job or shop work progress, hazards, accidents, and other work and safety items are to be discussed. A written record of these meetings should be maintained. Duties and Responsibilities of the Foreman include: Conducting safety inspections daily, supplemented by periodic checklist and typewritten safety inspections as specified by the superintendent. Ensuring all accidents are reported and first aid rendered in case of injury. Investigating all work related accidents and near misses and then submitting a report to the superintendent. Ensure necessary actions are taken to prevent similar accidents from happening in future. Duties and Responsibilities of All Employees include: Exercising maximum care and good judgment in preventing accidents. Report to their foreman and seek first aid for all injuries, however minor they may be. Report unsafe conditions, equipment or practices as soon as possible. Use all personal protective equipment provided whenever necessary. Peter Ho Peter Ho (President) Edward Ong Edward Ong (Safety Director) Figure 11.2: XYZ Pte Ltd Organization Structure, Responsibilities and Accountabilities 11.5 XYZ Pte Ltd Risk Assessment Program HARMFUL SEVERITY OF HARM LEVEL - Superficial injuries, minor cuts and bruises, eye irritation from dust Slightly Harmful - Nuisance and irritation (e.g. headaches), ill-health leading to temporary discomfort. - Lacerations, burns, concussion, serious sprains, minor fractures Harmful - Deafness, dermatitis, asthma, work related upper limb disorders - Ill health leading to permanent minor disability. - Amputation, major fractures, poisonings, multiple injuries, fatal Extremely injuries Harmful -Occupational cancer, other severely life shortening diseases, acute fatal diseases Table 11.1: XYZ Pte Ltd Interpretation of Harm Level Slightly Harmful Harmful Extremely Harmful Highly Unlikely Trivial Risk Tolerable Risk Moderate Risk Unlikely Tolerable Risk Moderate Risk Substantial Risk Likely Moderate Risk Substantial Risk Intolerable Risk Table 11.2: XYZ Pte Ltd Risk Rating RISK LEVEL ACTION AND TIMESCALE No action required, no documentary records to be kept. Trivial No additional controls required. Consideration may be given to a more cost- Tolerable effective solution or improvement that imposes no additional cost burden. Monitoring required to ensure that controls are maintained. Effort should be made to reduce risks, but costs of prevention should be carefully measured and limited. Moderate Where moderate risk is associated with extremely harmful consequences, further assessment may be necessary to establish more precisely the likelihood of harm as a basis for determining the need for improved control measures. Work should not start until risk has been reduced. Considerable resources may Substantial have to be allocated to reduce risk. Where risk involves work in progress, urgent action should be taken. Intolerable Work should not start or continue until risk has been reduced. If it is not possible to do so even with unlimited resources, work has to remain prohibited. Table 11.3: XYZ Pte Ltd Interpretations of Risks • Conducted at Site: Loyang Drive / Construction of ABC Condominium • Conducted on: 12/ 2/ 2000 Conducted by: John Lee (Safety Engineer) IMPACT (Rating = Severity X Frequency) Eye Work Types of Physical Heari Injury Lim General Activity Hazards Injuries ng (possibi bs Illness (e.g. Tot Ra (possibili Proble lity of Inju Cough, flu, al nk ty of ms loss of ry fever, etc.) death) sight) Operating a compressed Loud noises & 2x2 4 air long exposures Jackhammer Inspection of steel girder alignment & Exposures to deflection in 2x2 4 lasers bridges & buildings using lasers Table 11.4: XYZ Pte Ltd Risk Assessment Matrix (Page 1 of 3) IMPACT (Rating = Severity X Frequency) Work Types of Eye Physical Activity Hazards Heari Injury Lim General Injuries ng (possibi bs Illness (e.g. Tot Ra (possibili Proble lity of Inju Cough, flu, al nk ty of ms loss of ry fever, etc.) death) sight) Working over or near water without wearing life Drowning 2x2 3x2 10 jackets or buoyant equipment Handling flammable Fire 2x2 2x2 2x2 12 2 liquids Handling Electrocution Powder- & 2x2 2x2 2x2 12 2 actuated Mechanical tools injuries Table 11.4: XYZ Pte Ltd Risk Assessment Matrix (Page 2 of 3) IMPACT (Rating = Severity X Frequency) Eye Work Types of Physical Heari Injury Lim General Activity Hazards Injuries ng (possibi bs Illness (e.g. Tot Ra (possibili Proble lity of Inju Cough, flu, al nk ty of ms loss of ry fever, etc.) death) sight) Handling high-voltage Electrocution 2x2 2x2 8 machinery Transportatio n of explosive Explosion 1x1 1x1 2x2 2x2 10 materials used & Fire in blasting Fatality to drivers Heavy (caused by vehicles & rollovers) or to 2x2 1x2 2x2 3x2 16 1 equipments co-drivers in operation (caused by runovers) Table 11.4: XYZ Pte Ltd Risk Assessment Matrix (Page 3 of 3) 11.6 XYZ Pte Ltd Risk Assessment Results & Analysis • The risk assessment matrix (refer to Table 11.1) on the company‟s occupational health and safety revealed that the severity of risk due to heavy vehicles in operation ranked the highest among other form of risks, leading to many cases of fatality to drivers (rollovers) and to co-workers (runovers). • After a thorough investigation with the foreman and his workers, the following reasons were believed to be the cause of heavy vehicle accidents: i. Heavy construction vehicles have to maneuver in congested areas; ii. There is no speed limit for vehicles at the worksite; iii. There is no policy that all drivers have to be certified to operate a specific vehicles; iv. Routes where the construction vehicles are to operate are not marked; v. Construction vehicles have no protection against impacts of any forms; vii. Workers are not informed of the precautions they should take at worksites. 11.7 XYZ Pte Ltd Action Plan • 11.7.1 Key Objectives – The organization‟s key objective is to plan and implement an action plan to reduce site transport risks to as low a level as possible within six months. – The plan specified improvements in outcome indicators that would demonstrate a site transport risk that was as low as possible and that could be sustained over time. 11.7.2 Outline Indicator The objectives will be judged if they have been met based on the following indicators: i. Reported near-misses and transport accidents; ii. Number of transport related unsafe acts and conditions observed by foremen and co-workers; iii. Review from foremen of operator compliance with relevant regulations; • 11.7.3 Objective Plan The broad content of the action plan to achieve key objectives, within an agreed budget, is finalized after consultation with relevant parties and a review of the plan‟s adequacy are: i. Install rollover protective structure (ROPS) on vehicles; ii. Improve operator visibility and pedestrian awareness on site; iii. Introduce on site safety awareness training; iv. Introduce biennial inspection of construction vehicles. • 11.7.4 Target Plan and Timescale – A detailed Occupational Health and Safety Management Programme has been drawn up in Table 11.5. – Proper planning is essential to ensure that targets can be met within a reasonable timescale. Also, the targets will be inspected against a checklist given in Figure 11.3. CHECKLIST FOR EVALUATION OF SITE TRANSPORT ACCIDENTS 1. Are the routes where these vehicles are to operate marked or otherwise restricted? 2. Have speed limits and other precautionary measures been posted prominently? 3. Is it a policy that only authorized personnel will operate the vehicles? 4. Is it a policy that all drivers will be certified to operate specific vehicles? 5. Are vehicles, which can be subjected to bumpy roads or sudden stops or turns, provided with seatbelts or other means of restraints to prevent injury to the occupant? 6. Are vehicles, which might upset, equipped with rollover protection for the driver and other occupants? 7. In personnel carrying vehicles subject to impacts or sudden starts or stops, are cushioning materials used to prevent injury by safeguarding the riders from hitting hard surfaces? 8. In such vehicles, have sharp points, knobs, and other hard protuberances against which personnel can injure themselves by impact been removed or safeguarded? 9. Will the vehicle be able to stop within a reasonable distance if the surface on which it is moving is wet? Does the vehicle have any unreasonably unsafe characteristics on a wet surface? 10. Is the braking surface and capability adequate for the vehicle’s weight and unexpected operating speed? Figure 11.3: Checklist For Site Transport Accidents • 11.7.5 OH&S MANAGEMENT PROGRAMME (CLAUSE 4.3.4) DUE DATE PRESPONSIBILITY NO. SIGNIFICANT OBJECTIV MEANS (CLAUSE 43.4B) OH&S IMPACTS E (3.9) OBJECTIVES (3.5) (CLAUSE 4.3.3) TIME FRAME IN MONTHS IMPLEME- PROCED- MONIORIN OBJEC- TAR- 1 2 3 4 5 6 7 8 9 10 11 12 NT URE G& TIVE GET MEASURE MENT (CLAUSE4. 5.1) Foremen 1 FATALITY TO REDUCE 30 10 / 0 DRIVERS SITE 1.Report-ed Progress 100% A AND CO- TRANSPO near-misses -ion P WORKER RT RISK and R 1.1 Install rollover transport protective accidents structure 2. Review (ROPS) on from 1.1.1 foremen of Progress 100% A constructio Construct operators -ion P 30 10 / 0 n vehicles R ROPS at complianc- the back of es with the constructio regulations n vehicles 1.1.2 F Ensure 3. Number Progressi 100% A o 2 1 the of tranport on P r 5 0 securing related R e / of seatbelt unsafe acts m 0 1.2 Improve by drivers e operator n visibility and 1 pedestrian Progressi M 3 7 0 awareness 100% 0 on A 0 / Y 0 1.2.1 Segregate pedestrian 1.3 M 2 6 1 and Progressi 100% Introduce vehicles on A 5 5 0 on-site using road Y / safety markings 0 awarenesstr and aining barrier 100% M 6 1 2 A 5 5 0 Y / 1.3.1 0 Establish safety 1.4 awarenes Increase M 1 Introduce s d Safety 100% 2 7 0 A 5 bi-annually workshop Awarene Y 5 / inspection 1.3.2 ss 0 of Conduct Progressi construction one day on of vehicle training and competen S cy test Progressi 100% 1 on E P 0 / 0 DUE DATE PRESPONSIBILITY NO. SIGNIFICANT OBJECTIV MEANS (CLAUSE 4.2.b4) OH&S IMPACTS E (3.9) OBJECTIVES (3.5) (CLAUSE 4.3.3) TIME FRAME IN MONTHS IMPLEME- PROCED- MONIORIN OBJEC- TAR- 1 2 3 4 5 6 7 8 9 10 11 12 NT URE G& TIVE GET MEASURE MENT (CLAUSE4. 5.1) Superintendent and foremen 2 INJURIES Reduce 25 10 / 0 AND DEATH accidents Progress 100% A DUE TO due to falls -ion P FALLS R 2.1 Ensure proper 1. Reported erection of near-misses scaffold and 2.1.1 Provide transport Progress A accidents 100% sufficient -ion P 30 10 / 0 and sound R material 2.Review for scaffold from foremen of operators Progress 100% 2.1.2 A 30 10 / 0 compliance -ion Inspect the P tubes, with the R couplers, regulations and boards for defects before use DUE DATE PRESPONSIBILITY NO. SIGNIFICANT OBJECTIV MEANS (CLAUSE 4.3.4B) OH&S IMPACTS E (3.9) OBJECTIVES (3.5) (CLAUSE 4.3.3) TIME FRAME IN MONTHS IMPLEME- PROCED- MONIORIN OBJEC- TAR- 1 2 3 4 5 6 7 8 9 10 11 12 NT URE G& TIVE GET MEASURE MENT (CLAUSE4. 5.1) 1 2.1.3 50 10 / 0 Scald fold 3. Number Progress 100% M to be of transport -ion A erected by related Y qualified unsafe acts and experience 2.2 Install workers guidance 2.1.4 Progress 100% Inspect -ion and maintain scaffold once a 10 / 0 week after 50 erection Progress 100% J -ion U 2.2.1 N Floors and walls to be Progress J guided by 100% U -ion railings on N open sided floors 2.2.2 Draw Progress 100% J 10 / 0 -ion 50 warning U lines 6ft N from edge of roof Supervisor Progressi 100% J 5 1 2.3 Safety on U 0 0 belts N / 0 2.3.1 Ensure worker wear Progressi 100% J safety belts, on U 1 5 lanyard, and N 0 0 2.4 Ensure / persons lifeline when working at a 0 working at heights height of 6 ft adhere to or more Progressi J 1 precautiona 100% U 5 ry measures on 0 0 N / 2.4.1 Permit 0 persons to work at J 1 heights only Progressi after they 100% U 5 0 on N 0 have / indicated or 0 demonstrated no adverse effects 2.4.2 Arrange an experienced worker to 1 accompany a J 5 0 new worker Progressi U 0 / to observe on 100% N 0 worker’s reaction 1 0 / 0 DUE DATE PRESPONSIBILITY NO. SIGNIFICANT OBJECTIV MEANS (CLAUSE 43.4B) OH&S IMPACTS E (3.9) OBJECTIVES (3.5) (CLAUSE 4.3.3) TIME FRAME IN MONTHS IMPLEME- PROCED- MONIOR OBJEC- TAR- 1 2 3 4 5 6 7 8 9 10 11 12 NT URE ING & TIVE GET MEASU REMEN T (CLAUS E4.5.1) 2.4.3 Persons Progress J 5 1 who are under ion 100% U 0 0 medication N / that cause 0 drowsiness or recovering 2.5 from cold or Provide flu should not safeguard be allowed to s to avoid work at J 4 7 hard heights U 0 0 impacts Progress 100% ion L due to falls where 100% 1 2.5.1 Place J 0 possibilitie Progress 7 s of falls well packed ion U 0 / cannot be earth around N the buildings 0 eliminated Progress 2.5.2 Install 100% J 1 safety nets to ion 6 U 0 break fall L 0 / 0 11.8 Monitoring and Measurement Plan • In order to monitor the OH&S management system, a monthly safety record (Figure 11.4) will have to be kept. Items included in the record are: date of incident or occurrence, indication of whether it involves an accident, near miss, ill health or discovery of a new hazard, a description of the incident or occurrence, by whom was it reported by and the action that was taken. • The superintendent will conduct regular risk assessments every month to check areas where potential work hazards might occur. • This risk assessment will be supplemented by feedback from other employees on the work hazards they face in the course of their work or any new potential work hazards that they might observe. AC NEAR ILL WORK REPOR ACTIO MISSES DESCRIPTION DATE CI HE HAZAR TED BY N DE ALT D TAKEN NT H DISCOV ERED 03/01/ 1 3 0 Yes It was discovered that an accident Headman Pending 2000 and three near- misses were caused Tony by one of our workers, Salleh. He Ang did not have the Class 4 driving license needed to drive the transport truck. He drove the truck into a partially completed building boulder and almost hit three other fellow workers working on the boulder. They suffered minor injuries and cuts. Salleh fractured his collarbone and needed to be hospitalized for observation. Figure 11.4: XYZ Pte Ltd Safety Record Sheet 11.9 Investigation Procedures • An investigation committee has been set up to look into all accidents and near- misses. • The safety engineer of our company will head the committee. • Corrective action plans have to be approved by the safety engineer before they can be carried out. • Investigation personnel should begin their preliminary analysis of facts while further information is collected. • In the process of investigation, corrective action has to be taken to prevent further or reduce similar cases of accidents from occurring. • It should not be carried out only after a thorough investigation has been conducted as by then, more similar accidents would have occurred. LIST OF INVESTIGATIVE QUESTIONS TO ASK THE WITNESS 1. Where did the accident occur? 2. When did it occur? 3. What did the witness see with his/her own eyes? 4. What was the driver doing when the accident occurred? 5. What was the victim doing when the accident occurred? 6. Did the driver have his seatbelt on? 7. Were both the driver and the victim following the rules and regulations? 8. In the witness‟s view, what had caused the accident? Figure 11.5: XYZ Pte Ltd List of Investigative Questions for Witness LIST OF INVESTIGATIVE QUESTIONS TO ASK THE VICTIM 1. What was he doing when the accident occurred? 2. Was he supposed to be present at the place of accident? 3. Was he under any medication at that time? 4. Is he experienced in that particular job? 5. Did he check the vehicle before using it? 6. Did he comply with the rules and regulations? 7. In his opinion, what had caused the accident to happen? Figure 11.6: XYZ Pte Ltd List of Investigative Questions for Victim 11.10 Emergency Response Plan for Heavy Vehicle Accidents The following steps shall be followed should there be any major heavy vehicle accident at the worksite: 1. Remove victim if possible. 2. All workers in danger or at potential harm are to evacuate the worksite to a safe control station. 3. The foreman shall be informed as soon as possible. 4. The foreman is to inform all relevant authorities. 5. No one should be allowed to leave the control station until further instructions. 6. Put out all fires immediately. 7. Apply first aid to victim. 8. Do not panic and wait for help to arrive. 11.11 Audit Program • Internal audits are to be carried out every three months. • There will also be an external certification audit scheduled once a year. • The main purpose of the audits is to check if the OH&S system has been properly implemented within the company. • It is also a review of our company‟s performance in the area of OH&S performance. • An audit checklist developed based on the OHSAS 18001: 1999 specification requirements will be used during the internal audits to aid assessment. GENERAL REQUIREMENT 4.1 Does the organization maintain an established OH&S Management System? Are there objectives set up for the policy? What are they? 4.2 Is the company‟s OH&S policy appropriate to the nature and scale of the organization‟s OH&S risks? 4.2a Are employees committed to continual improvement? 4.2b Are employees committed to comply with current applicable OH&S legislation and other requirements? 4.2c Is the OH&S policy being documented, implemented and maintained in the organization? 4.2d Are all employees aware of their individual OH & S obligations? Is the OH&S policy available to interested parties? 4.2e Is the OH&S policy reviewed periodically to ensure its relevance and appropriateness to the organization? 4.2f Are there established procedures to identify the OH&S hazards in the organization? 4.2g Are risk assessment & control measures implemented? 4.3.1 Is the organization‟s methodology for hazard identification and risk assessment -Defined with respect to its scope, nature, and timing? -Able to classify and identify risks to be eliminated or controlled? -Consistent with operating experience and capabilities of risk control measures? -Able to provide input into the determination of facility requirements, identification of training needs and development of operational controls? -Able to provide for the monitoring of required actions to ensure both the effectiveness and timeliness of their implementation? Are legal & other relevant requirements identified & made readily accessible? 4.3.2 Are the OH & S objectives established and maintained? 4.3.3 Are documented objectives and targets consistent with the OH&S policy including commitment to continual improvement? 4.3.4 Are programs for achieving overall plans & objectives established & maintained, including designation of responsibilities, and methods and time- scale by which they are achieved? 4.4.1 Is everyone in the organization aware of their roles & responsibility for the health & safety of those they manage, themselves & others whom they work with? Are resources essential to the implementation, control and improvement of the OH&S management system provided? 4.4.2 Does the workers at the site possess appropriate education, training and/or experience on OH&S aspects? Are employees competent and trained in performing their tasks? Are the employees aware of -The importance of conformance to the OH&S policy and procedures, and the requirements of the OH&S system? -The actual and potential OH&S consequences of their work activities and benefits of improved personal performance? -Their roles and responsibilities in achieving conformance to the OH&S policy and requirements? - Potential consequences of departure from specified operating procedures? 4.4.3 Are there procedures to ensure that pertinent OH&S information is communicated to and from the employees and other interested parties? Are employees involved in the development and review of policies and procedures to manage risks and consulted when there are changes that affect workplace health and policy, and represented on health and safety matters, informed of their representative? 4.4.4 Are information that provide direction to related documentation and describe core elements of the management system and their interaction established and maintained in a suitable medium? Are documented procedures efficiently located and suitably identified? 4.4.5 Are documented procedures reviewed periodically, and approved for adequacy by authorized personnel? Are the documented procedures kept up to date & available to all at essential locations? Do the documented procedures contain obsolete documents? Are control measures applied to those operations and activities associated with identified risks? 4.4.6 Are there established and maintained procedures to cover situations where their absence could lead to deviation from OH & S policy and objectives? Are the procedures stipulating operating criteria? 4.4.7 Are arrangements made to establish contingency plans for foreseeable emergencies & to mitigate their effects? 4.5.1 Is the performance measurement established for monitoring the policy & its objectives? 4.5.2 Are corrective actions taken & root causes identified whenever deficiencies arise? What are they? 4.5.3 Are there any records maintained? 4.5.4 Is there an audit program to assess the OH&S management system? 4.6 Does the management carry out reviews of the OH&S system periodically? Is frequency & scope of periodic reviews of the OH&S management system defined according to its needs? 11.12 Management Review • Management review is to be conducted on the first Friday of every six months to review the OH&S system implemented. • Evaluation will be planned based on the current flow of events, including any latest changes to legislation, policy, or objectives.
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