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In accordance with The Health & Safety at Work an organisation with 5 or more employees must have a written policy. It should contain three individual sections: • Statement of Intent – What we intend to achieve • Organisational Responsibilities – Who is responsible • Arrangements for Implementation – How it will be done Key elements of a health & safety management system Management Systems This is a tool that helps organisations achieve compliance and manage risks. Recognised systems ensure smooth operation and also provide auditable control of any process. Examples are: • Health & Safety (HSG 65, OHSAS 18001) • Quality (ISO 900, 9001 etc) • Environmental (ISO 14001) • Security, Energy Key elements of a health & safety management system • Policy – setting clear aims, objectives, state management intentions, lay down criteria, principles for action and response. • Organisation – Ensure adequate control of H&S activities, allocate responsibilities, ensure staff competence, effective communication, cooperation between management and employees. • Planning and Implementation – Identify hazards, assess risks, introduce controls, SSOW and documentation to reduce risks. • Measuring Performance – Measuring performance provides an opportunity to see where achievements have been made, and also identify areas of weakness or failure. This can be using reactive (accident stats etc) or proactive (inspections etc). • Review – evaluating performance, trends, set remedial actions and set targets. • Audit – This can be independent audit of the whole system and ensure compliance to legislation. The actions can then be noted and acted against to improve standards or procedures where there are weaknesses. OHSAS 18001
Health & Safety Management System Policy – Key elements of a H&S Management System Health & Safety Management System Policy – OHSAS 18001 Model Health & Safety Management System Policy 1 Health & Safety Management System Policy - HSG 65 Model
Policy – Statement of Intent The policy forms the commitment from management that H&S is taken seriously and offer a measure of performance as well as compliance with legal requirements. The policy statement is signed by the most senior person on site, and should be dated to ensure a review period is set. This is usually annually but may be more often should certain changes occur such as a change of CEO / GM, a restructure, or where new changes to legislation or working practice dictate a review of the statement of intent. Policy – Organisational Responsibilities This defines how H&S is organised. It defines roles and responsibilities for each area. Often this supported by an organisational chart. Such positions may be • Directors – required to set general policy and objectives and make sure adequate resources are available. • Middle manager – may be required to implement policy in their area of responsibility, or carry out risk assessments. • Supervisors – May be required to check day to day compliance. • Competent Persons / Safety advisors – have specific responsibilities on advising the company on H&S matters. • Safety representatives – representing the workforce in relation to H&S. • Employees – acting responsibly for themselves and others. • First Aiders • Fire Marshals Policy – H&S Arrangements This is where procedures are detailed for implementing the policy. This is imperative to monitor compliance and setting objectives and how these arrangements are communicated to the workforce. This should include: • Risk assessments – when they are done, forms, who carries them out, review period. • H&S Training – Identifying needs, induction training, frequency of refresher training. Specific needs such as fork lift truck licenses etc. • Monitoring H&S performance – regular inspections, investigating accidents, incidents, audits, who should be responsible. • Contractor selection and management – how competency is assessed, who appoints them, how assessment is recorded, control of contractors. • Communication / consultation with employees. • SSOW / Permit to Work – who is responsible, how SSOW are documented and communicated to staff, tasks that require permits, training. • Disciplinary procedures. • Emergency Procedures – actions to take, procedures such as fire, first aid, major disasters etc. • Accident investigation – who accidents are reported to, records to be kept etc. • PPE – Storage, use and maintenance of PPE • First aid – arrangements, who first aiders are, contacts, supplies etc. • Visitor Safety – Control of visitors • Welfare facilities – arrangements in place / Environmental controls – Waste etc Policy – Review The policy must be reviewed on a regular basis so it is up to date and relevant. Reasons for review may include change in management, accidents where findings indicate a need for a change of procedure or system of work, moving premises, authority findings or audit findings. The policy must also be communicated to all employees to ensure everyone is aware of it by either posting the statement on notice boards or issuing to each employee or making them aware of its location through mail etc.
Health & Safety Management System Policy – Organisational Responsibilities Health & Safety Management System Policy – Policy Review Health & Safety Management System Policy – Statement of Intent Health & Safety Management System Policy – H&S Arrangements
Policy – Communication of Health & Safety Policy Examples of how the policy can be communicated are: • Issue a hard copy to each individual employee, and obtain a signature of receipt. • E-mail a copy to all employees and add a read receipt. • Training courses (good practice to include the policy in every training course). • Display the policy on notice boards or the intranet. • Employee handbooks if used. Other interested parties may be: • Visitors • Contractors • Enforcing Authorities • Clients / Customers • Shareholders Organisation – Roles and responsibilities – Directors It is good practice for directors to have overall responsibility for health and safety, and to show the collective director responsibilities as well as their own individual responsibilities to provide health and safety leadership within the organisation. Directors must ensure that board decisions reflect their health and safety intentions and recognise their role in engaging the active participation of the workers in improving health & safety standards. As a board member, directors will need to ensure that any health & safety failures are clearly communicated at board level and that any investigation findings are also brought to this forum. Directors have responsibility under section 37 of the HSWA 1974 ‘Where an offence is committed by the body corporate and is attributable to any neglect, consent or connivance of a director or senior manager, then that person may also be prosecuted’. Organisation – Legal and organisational roles and responsibilities Every organisation has to ensure that it clearly defines safety roles and responsibilities across the workforce. The responsibilities will need to include provisions for anyone affected by the activities of the organisation. Managers and individuals must know what they are responsible for in order to fulfil their duties and only then will it be possible to measure these individuals against their responsibilities. This can be achieved by a combination of the following: • Job descriptions (including health & safety responsibility) • Appraisal systems • Arrangements for dealing with poor performance • Disciplinary procedures. In terms of organisational requirements, every level of employee should have defined responsibilities including, directors, senior managers, line manager / supervisors, employees, H&S manager / advisor. Organisation – Roles and responsibilities – Senior Managers can demonstrate commitment to health & safety by: • Ensuring adequate resources for health and safety • Defining roles and responsibilities of all staff. • Appointing a member of senior management with specific responsibility for health and safety. • Appointing one or more competent persons to advise on health and safety. • Conducting regular reviews of health and safety performance. This commitment can be further reinforced by senior managers setting the right example. For instance: • Wearing PPE when necessary • Following marked walkways • Participation in safety inspections • Participations in safety meetings • Initiating and being personally involved in any health and safety training.
Health & Safety Management System Organising – Legal and Organisational Roles and Responsibilities Health & Safety Management System Organisation – Roles and Responsibilities – Senior Managers Health & Safety Management System Policy – Communication of Health & Safety Policy Health & Safety Management System Organisation – Roles and Responsibilities - Directors
Organisation – Health & Safety Culture Organisation – Roles and Responsibilities - Employees should be given responsibility to report any shortcomings within the organisations health & safety arrangements and report immediately any unsafe acts or conditions. Employees should be instructed that they have a duty to work in accordance with the organisations health and safety arrangements and should not endanger anyone they are working with or around by unsafe behaviour. These requirements are set out in sections 7 and 8 of the HSWA 1974 and regulation 14 of the MHSWR 1999. Organisation - Health and Safety Culture Definition of a health and safety culture: “A system of shared values and beliefs about the important of health and safety in the workplace”. In health and safety guidance (HSG 65), the four C’s of a positive health and safety culture are defined as: • Competence – Competence of individuals with relevant skills, knowledge, ability, training and experience. • Control – Method of control within the organisation, e. g. Supervision, monitoring, enforcement. • Communication – Method of communication throughout the organisation, e. g. posters, DVD’s e-mail, notice boards etc. • Cooperation – means of securing cooperation between individuals, safety representatives and groups, e. g. safety committee meetings etc. Tangible outputs or Indicators of an organisations health and safety culture. • Accident Rate – A high number can indicate poor safety, whereas a low number can mean accidents are not being reported. • Absenteeism and Sickness Rates – Excessive rates of sickness or absence can indicate a poor culture or unsafe environment of an organisation. • Staff turnover – High staff turnover is unsettling and can slow production down as new recruits learn the job. It can indicate a poor working environment if staff do not wish to stay at an organisation for long. • Level of health & safety compliance – the level of compliance directly correlates with the attitudes displayed within the H&S culture. Senior management can support this. Any decrease in compliance will impact the culture. • Complaints about working conditions – Complaints about working conditions can indicate a positive culture because the workforce actively tries to bring about change. It can be negative if complaints are not followed up or no feedback is given, or could be used by the workforce as a reason not to work safely because the work condition indicate as such. Organisation – Factors promoting a negative health and safety culture There are certain factors that will influence the health & safety culture of an organisation in a negative way. These include: • Lack of effective communication and /or consultation. • A blame culture • Lack of leadership and commitment at senior level. • Loss of key personnel. • Health and safety being put second to production / quality • Setting unrealistic / unachievable targets. • Lack of monitoring / enforcement • Poor working environment / conditions. • High staff turnover • External influences e. g. economy / unemployment • Reorganisation • Redundancy • Influence of peers
Health & Safety Management System Organising – Health and Safety Culture Health & Safety Management System Organisation – Factors Promoting a Negative Health & Safety Culture Health & Safety Management System Organisation – Roles and Responsibilities - Employees Health & Safety Management System Organisation – Health & Safety Culture – Tangible Outputs and Indicators
Organisation – Job / Task Factors Organisation – Factors Influencing Safety Related Behaviour Organisation – Individual Factors The HSE recognises the importance that human factors can play in helping avoid accidents in the workplace. Some areas are: Competence – Competence is generally considered to be a combination of skills, knowledge, ability, training and experience relevant to the role. Personality – Personality can be defined as “a dynamic and organised set of characteristics possessed by a person that uniquely influences their cognitive, motivations and behaviours in various situations. Attitude – Attitude can be defined as “A feeling or opinion about someone or something, or way of behaving because of this”. Risk Perception – Perception can be defined as “An awareness of risk, based on what is taken in through the senses and previous experiences” Motivation – Motivation can be defined as “A person’s reason for doing something”. Motivations can be appetitive (towards something we want) or aversive (away from something we don’t want). Age and Experience – This can be both negative and positive for young and older workers who can be inexperienced or complacent towards tasks and safety. Other Factors – Sensory defects, drugs, alcohol, physical disability / capability, aptitude, stress, fatigue. Task Demands – Unachievable targets can lead to mistakes, pressure and could lead to an accident. If high levels of alertness are required for long periods or the tasks are monotonous this can lead to fatigue and could cause accidents. Disturbance / Interruptions – Being disturbed or interrupted can distract us from what we are doing or we may miss vital information. Constant interruptions can cause a lot of frustration and lead to mistakes. Bonus Systems – These can lead to mistakes being made or accidents not being reported correctly. Environment – Suitable lighting and temperature makes a work environment more pleasant to work in. Poor lighting, extremes of temperature, an unclean work area can lead to poor safety culture, or least to occupational illnesses, or more accidents. Displays and Controls – Displays and controls should be arranged in order relevant to the operation required. They should be easy to see, reach and operate in a logical manner. They should also be consistent such as red for stop, green for start. Procedures – Procedures need to be: current and up to date, supported by training, use familiar language, identify hazards and precautions, be in a suitable format, be accessible, use consistent terminology. Organisation – Organisational Factors There are several organisational factors that can influence safety behaviour. These include: Health & Safety Culture - The culture or an organisation directory influences safety behaviour, so a negative culture will be less likely to have diligent attitudes to safety. Management Commitment – Leadership displayed by management impacts behaviour. If a manager is diligent, his reports are likely to follow the example. Resources allocated -Sufficient resource should be provided for the size and scope of the organisation. Not enough resources will impact negatively. Work Patterns – Shift patterns can have a negative effect. Working at night or outside of normal hours can affect behaviour. Communication – this is key to good safety. Key messages must be delivered to the right people, or this can lead to accidents or not enable individuals to make the right decisions. Training – Training can help ensure competence, and different levels of training may be required for different people or groups depending on the task. It helps keep skills fresh which decreases the risk of mistakes or accidents. Supervision – Supervision of the workforce ensures that activities are carried out in accordance with work instruction and training.
Health & Safety Management System Organising – Factors Influencing Behaviour - Individual Health & Safety Management System Organisation – Factors Influencing Behaviour – Organisational Factors Health & Safety Management System Organisation – Factors Influencing Safety Related Behaviour Health & Safety Management System Organisation – Factors Influencing Behaviour – Job / Task Factors
Organisation – Communication is important for all organisations for all information, not just information coming into the organisation but going out also. There are different types of communication – written, verbal or graphic. Verbal Communication – This includes discussion, speeches, presentations and interpersonal communication. Language, distractions, tone and body language can all influence verbal communication. Written Communication – This includes letters, memos, emails. Care needs to be taken with language, jargon, tone or overloading with information or making the message too complex. Graphic Communication – This includes drawings, sketches, pictures, photographs. These can help enhance the message you need to get across. Things to bear in mind – keep language clear and without jargon, so it may be understood, ensure there are no distractions if messages are delivered verbally, ensure body language is positive, attitude to delivery the message is enthusiastic and positive, and be aware of people who may have sensory defects such as hearing or sight impairment. Types of communication could be, films, DVD’s, posters, toolbox talks, letters, email, handbooks, intranet, training, newsletter. Organisation – Information, Instruction and Training There are legal requirements under section 2(2) of the HSWA 1974 to provide health & safety training to employees, and regulation 13 of the MHSWR. Effective training can improve reliability and improve a persons perception of risk and hazards, and can improve skills which can improve morale, attitude and competence. Possibly the most important is induction training. Some items that should be covered are: Content of the H&S policy, line management, specific hazards / risks an control measures, local safety procedures and rules, employees responsibilities under health and safety law, consultation procedures for who the site safety reps are and arrangements for the health & safety committee, accident reporting procedures and arrangements, health surveillance if required, welfare facilities and emergency procedures. Additional training may be required or refreshed if: new processes are introduced, job change, new legislation, accident trend, risk assessment, refreshers that are needed, staff appraisals, counteract complacency. Organisation – Consultation with Employees Employers have a legal obligation to consult with employees on matters of health & safety. This is covered by two separate pieces of legislation: Unionised workplaces must comply with the Safety Representatives and Safety Committees Regulations 1977. Non-unionised workplaces must comply and refer to the Health and safety (Consultation with Employees) Regulations 1996. Consultation is a two way process – consulting meaning to ‘seek information or advice from’, and ‘seek permission or approval from’. Organisation – Safety Representatives and Safety Committees Regulations 1977 Scope – regulations apply to unionised workplaces, the recognised trade union may appoint safety representatives from among the employees and notify the employer in writing, safety representatives ideally should have two years service. There are no actual defined duties of a safety representative included in the regs, however there are specific functions. These include: • Representing employees in consultation with employer. • Investigating hazards and dangerous occurrences and accidents. • Investigating employees complaints relating to health and safety. • Carrying out inspections in the workplace. • Representing employees in consultation with inspectors. • Attending safety committee meetings. An appointed representative is entitled to the following as part of their role: Time off with pay to carry out their duties, health & safety training, reasonable facilities, if 2 or more reps request a safety committee, the employer must establish one within 3 months. A rep may inspect the workplace: every 3 months, following a change in work conditions, when new information is available from HSE, following a notifiable accident, disease or danger occurrence.
Health & Safety Management System Organising – Information, Instruction and Training Health & Safety Management System Organisation – Factors Influencing Behaviour – Organisational Factors Health & Safety Management System Organisation – Improving Health & Safety Behaviour - Communication Health & Safety Management System Organisation – Safety Representative and Safety Committee Regulations 1977
Organisation – Safety Representatives Organisation – Health and Safety (Consultation with Employees) Regulationss 1996 Scope: Employer can choose whether to consult directly (small companies) or through an elected Representative of Employee Safety (Ro. ES). The functions of a non-unionised safety representative role are similar to the union safety rep, but with the following exceptions: Non-unionised Safety Representatives are NOT entitles to: • Inspect the workplace • Investigate accidents • Attend safety committee meetings. The number of employee representatives that an employer has depends on a number of factors: • Size of the workplace and number of locations. • Total number of employees. • Type of work and risks involved. • Variety of occupations at the workplace. • Operation of shift patterns. • Areas which might not be covered by Trade Union (TU) Consultation should happen when measures are introduced affecting employee health and safety. It is expected that employees should be made aware of: • Any arrangements / measures at the workplace which may substantially affect their health and safety. • Information from risk assessments and / or control measures. • Arrangements for appointing a competent person to assist in complying with health and safety arrangements. • Introduction of new technology / materials. The employer does not have to disclose information if: it violates a legal prohibition, endanger national security, individual who has not given consent, could commercially damage the business, obtained in connection with legal proceedings. Organisation – Importance of Developing Emergency Procedures Organisation – Safety Committees When an organisation is required, or decides to form a committee, it must make certain that there is a clear agenda, and equal representation across the workforce. To be representative, the committee should have a balance between management and employees. The functions of a committee meeting might include: Study accident / ill health / near miss reports, examine health and safety audit and inspection reports, consider reports from enforcing authorities, monitor and review the effectiveness of health and safety training and communication, new legislation, new processes or equipment, changes in H&S documentation, training requirements, communications. To be effective, there should be: terms of references / objectives, backing of the board, regular meetings, nominated chairperson, agenda set out in advance. Regulations 8 & 9 of the MHSWR require the employer to make suitable arrangements for emergency situations (Serious & Imminent Danger and Contact with Emergency Services). Appropriate plans should be in place for: • Major Accidents / Dangerous Occurrences • Gas / Dust Explosion • Chemical release or spills • Security / intruder alert / terrorism • Bomb / explosive device. • Flood • Vehicle crash • Disease / epidemic outbreak • Environmental damage • Severe weather conditions (e. g. floods). Emergency procedures ensure that businesses have continuity in the event of an incident, and ensure legal compliance. There must also be plans in place to summon emergency assistance and it must be communicated to the workforce.
Health & Safety Management System Organising – Safety Committees Cont’d Health & Safety Management System Organisation – Importance of Developing Emergency Procedures Health & Safety Management System Organisation – Health and Safety (Consultation with Employees) Regulation 1996 Health & Safety Management System Organisation – Safety Representatives
Organisation – First Aid Arrangements The two main functions of first aid are: the preservation of life and / or minimising the effects of the injury until help arrives, and treatment of minor injuries that would not receive or do not need medical attention. According to the Health & Safety (First Aid) Regulations 1981, an employer must make an assessment of first aid provision to ensure they have adequate facilities, equipment and personnel. The arrangements for first aid must be communicated to employees. Consideration must be given to: hazards associated with the work, level of risk, accident stats, number of employees, vulnerable groups such as young people or disabled, geographic spread of the workforce, shifts and work patterns, distance to services, remote, lone or travelling employees, employees at other sites and members of the public. Organisation – First Aid Arrangements Cont’d The requirement for first aid provision is a legal requirement, but the scope of provision is not as each workplace is different. The facilities may also depend but should include where appropriate: First aid room, suitable lighting, heating and ventilation, chair or bed, sink, soap and drying facilities, clinical waste bin, accident book, phone, and signage. First aid kits have minimum requirements for their contents, and should include plasters, eyes pads, triangular bandages, large and medium dressings, safety pins, wipes, shears, gloves, eye wash and advice leaflet. Appointed Person – this person must take charge of health & safety arrangements, look after equipment / facilities and call the emergency services when required, and may provide emergency cover when first aiders are absent due to unforeseen circumstances and do not have to be trained. First Aider – is someone who has undertaken training and has an approved qualification in either; First aid At Work, or Emergency First Aid at Work. There should be at least one first aider per 50 employees, depending on the risk. Planning – Setting Objectives Effective planning is concerned with prevention of accidents and ill health through identifying, eliminating and controlling hazards and risks. When planning for health and safety there are three key questions that need to be addressed: • Where are we now? • Where do we want to be? • How do we get there? Targets should be set to demonstrate management commitment and to prioritise health & safety issues. Targets can also motivate staff and encourage ownership giving them something to aim for. Any objectives should be SMART objectives which stands for: Specific Measureable Achievable Reasonable / Realistic Time Bound Objectives need to be smart. E. g. reducing manual handling injuries by 50% over 3 years is SMART. Setting zero accidents is not. Planning – Risk Assessment There is a legal requirement for organisation to complete risk assessments. Regulation 3 of the MHSWR places this requirement on employers. It states: • There is a legal duty on employers to carry out risk assessments • A written record must be maintained if there are 5 or more employees • There must be a regular review. • Risk Assessments must be suitable and sufficient. The objectives of a risk assessment are two-fold: • To identify hazards faced by an organisation and evaluate how risk each hazard is. • To decide if enough is being done about the hazards or if further action is necessary. Morally it is not acceptable for an organisation to expect their workforce to risk life and limb in the pursuit of profit. This can cause bad publicity, accidents, loss of orders, difficulty if recruiting, or even prosecution , From an economical point of view, it is bad business to have accidents with costs of down time, loss of earnings, replacement labour, investigations, defences against prosecutions, person injury claims and impact on insurances.
Health & Safety Management System Organising – First Aid Arrangements Cont’d Health & Safety Management System Planning – Risk Assessment Objectives Health & Safety Management System Organisation – First Aid Arrangements Health & Safety Management System Planning – Setting Objectives
Planning – Birds Triangle Planning - Risk Assessment – Hazard and Risk Definition of Hazard is “A hazard is something that has the potential to cause harm” Typical examples of hazards include: • Physical – noise, vibration, electricity. • Chemical – asbestos, toxins, carcinogens • Biological – hepatitis, HIV, leptospirosis (also known as Weil’s disease) • Psychological – stress, verbal abuse Organisations should consider many different types of incident when assessing the risks posed by known hazards. Specific attention should be paid to more minor incidents and near misses as they alert the organisation to the potential of more serious injury or harm. The definition of risk is “the likelihood of harm resulting from the hazard”. Risk is a calculation of how likely an event is to happen, and if it does happen, how severe the outcomes are likely to be. Essentially this is calculated as: Risk = Probability x Severity Planning – Different Types of Incident Planning – Risk Assessors / Risk Assessments There are different types of incident, other than an accident, and these are listed below: Ill Health – In terms of health and safety, ill health refers to an illness that has developed as a result of exposure to something within the workplace. An example of ill health is asbestosis, a disease contracted due to inhalation of asbestos fibres. It also covers issues such as stress or depression. Injury – Injury describes the outcomes of incidents that result in harm. Accident – An accident is best described as an unplanned and undesired event which results in harm to a person or damage to property. Near miss – An unplanned and undesired event which, under slightly different circumstance, could have resulted in harm to people or damage to property. Dangerous Occurrence – Dangerous occurrences are event that, had the inputs been different, could have resulted in a major incident. They are specified types of near misses that have to be reported under RIDDOR. Damage Only Accident – Damage only event are when no-one is injured but there may have been damage to the building, plant, equipment or materials. Risk Assessors must be competent with adequate skills, knowledge, ability, training and experience. Ideally risk assessments should be carried out by people who are familiar with the work. The assessor should be able to: • Identify hazards and assess risks • Use additional sources of information as appropriate • Draw valid and reliable conclusions from assessments and identify steps to reduce risks • Make clear record of the assessment and communicate the findings. • Recognise their limitations and call on further expertise when necessary. Criteria for a suitable and sufficient risk assessment: • Identify the significant risks and ignore the trivial details that will not result in harm. • Allow the employer to identify and prioritise control measures. • Identify those who might be affected and should be appropriate to the nature of the work. • Identify a time period during which it is likely to remain valid and identify additional controls in order that priorities can be set against them.
Health & Safety Management System Planning – Types of Incident Health & Safety Management System Planning – Risk Assessment – Risk Assessors Health & Safety Management System Planning - Risk Assessment – Hazard and Risk Health & Safety Management System Planning – Birds Triangle
Planning - Principles of Risk Assessment The HSE recommends the 5 step approach to risk assessments: Planning – Risk Assessment – Categories of Accidents as Causes of Injuries / Health Related Accidents are categorised by cause of injury. Examples of these are: • Slips / Trips / Falls • Falls from height • Flying / Falling objects • Collision with objects • Trapping / Crushing under or between objects. • Manual handling • Contact with machinery / hand tools • Electricity • Transport • Contact with Chemicals • Asphyxiation / Drowning • Fire and Explosion • Animals • Violence These categories can also help with hazard identification. Walking round the workplace you could ask ‘Are there any objects that could fall, working from height etc’. Categories or Health Related Hazards: • Chemical – toxic or harmful substances • Biological – leptospirosis, legionella • Physical – noise or vibration • Psychological - stress Planning – Risk Assessment – Identifying the Hazards There a number of methods available to ensure that hazards can be identified. • Walk round the workplace and look what could cause harm. • Taking to employees. • Referring to manufacturer’s instructions. • Previous accidents and incidents. • Reference to Legislation • External references such as accidents in similar organisations or industry knowledge, or articles in professional body publications. A detailed examination of specific tasks can be used to develop control measures, using a Job Safety Analysis (JSA) or Task Analysis involving: • Selecting the job to be analysed • Recording the steps in the process of that job. • Examining the component parts of that job. • Developing control measures. • Installing the safe system. • Maintaining and monitoring the safe system. Planning – Risk Assessments – Decide Who can be harmed. When considering the identification of those people at risk, the employer is expected to look beyond considering just their workforce. Anyone may be affected. These populations should include: • Young workers, trainees, new and expectant mothers, who may be at particular risk. • Maintenance and cleaning staff. • Contractors • Visitors • Members of the public • Trespassers (if it is a risk that a trespasser may enter) • Neighbours (if there is a change they could be affected)
Health & Safety Management System Planning – Risk Assessment, Identifying the Hazards Health & Safety Management System Planning – Risk Assessment – Decide Who Might be Harmed Health & Safety Management System Planning – 5 Step Risk Assessment Process Health & Safety Management System Planning – Risk Assessment – Types of Accident and Ill health categories
Planning - Evaluating Risk and Adequacy of Controls Planning – Risk Assessment Grid Risk assessments should focus on significant risks. Each hazard should be considered for what harm it could cause. Existing controls for each hazard must be evaluated to check their adequacy. Once this is done, the residual risk can be decided whether it is high, medium or low. Legislation also needs to be checked to ensure there is nothing stipulated such as providing hearing protection in an environment where noise levels may get to or exceed 85 db. The hierarchy of control must be considered: • Eliminate – We should always first seek to eliminate the risks where possible. • Reduce – Reducing the amount of the hazard or the exposure can help control the risks. • Isolate – Isolating the hazard to prevent contact. • Control – Control such as SSOW and permits to work are means of control. • PPE – The supply of PPE should be a last resort when all other risk control have been considered. • Discipline – Installing discipline into the workforce through the use of supervision and, where necessary, having the means to discipline employees. Planning – Risk Assessment – Scoring a Risk Assessment Planning – Risk Assessments – Recording Significant Findings When a scoring system is used to calculate a risk in a risk assessment, this is referred to as a semi-quantitative RA. This is often done as a five by five calculation. If an organisation employs more than 5 people, the record of significant findings of the RA must legally be in writing. This includes the hazards present and the conclusions which details the required controls and how the hazard are to be mitigated. Organisations need to show that these have been communicated to employees, proper checks have been made and that those who might be affected were consulted. The RA should also show that any significant hazards have been controlled and in conjunction with how many are affected. They should indicate the controls are reasonable and that any remaining risk (residual risk) is low or as low as reasonable practicable. The term ‘low as reasonably practicable’ should encourage you to consider the benefits of reducing a risk again the costs involved (time, money and effort). It must demonstrate the cost involved in reducing the risk further is appropriate to the benefits gained. Likelihood: 1 – Almost Impossible 2 – Unlikely 3 – Possible 4 – Likely 5 – Almost Certain Severity 1 – Insignificant (no injury) 2 – Minor (injuries requiring first aid only) 3 – Over 7 days absence 4 – Major (more than 7 days absence) 5 - Fatality
Health & Safety Management System Planning – Risk Assessment – Scoring a Risk Assessment Health & Safety Management System Planning – Risk Assessment – Recording Significant Findings Health & Safety Management System Planning – Risk Assessment – Evaluating Risks and Adequacy of Controls Health & Safety Management System Planning – Risk Assessment Grid
Planning - Risk Assessment - Review It is good practice to review risk assessments after a period of time, to ensure they remain up to date and that the control measures in place are effective. This may be a yearly review but there may be other reasons which trigger a review: • Accident / Near Miss / Ill Health – It is common after an incident to review the RA’s relating to the task or activity. • Enforcement action – This maybe the HSE or LA ad may identify RA’s do not comply with legislative requirements. • Change to process, work methods or materials – When the process, work methods or materials change significantly, the risk assessment associated should be reviewed. • New Technology / plant changes – Keeping up with technological advances is good. New technology should always be considered and invested in and should indicate a RA review. • Changes in legislation – Any changes to legislation should trigger a review of RA’s. • Complaints by employees – involving the workforce in RA’s is critical. Any complaints should prompt a review. • Change in personnel – Introduction of new / vulnerable employees will trigger a review. Additional RA’s may be needed for young people, new or expectant mothers etc. Planning – Risk Assessment – Young Persons In the MHSWR, it states: • In reviewing or making the assessment, an employer who employs or is to employ a young person must take account of: • Inexperience, lack of awareness of risks and immaturity of young people. • The fitting out and layout of the workplace and the workstation. • The nature, degree and duration of exposure to physical, biological and chemical agents. • The form, range, and use of work equipment and the way it is handled. • The organisation of processes and activities. • The extent of the H&S training provided or to be provided. • Risks from agents, processes and work listed in the ANNEX to Council Directive 94/33/EC on the protection of young persons. It is also important to recognise that young people should not be employed if the work is: • Beyond physical or psychological capabilities. • Involves harmful exposure to radiation. • Involves exposure to agents that are toxic, carcinogenic, cause heritable damage. • Involves extreme heat, cold, noise or vibration. Young persons should also have a details induction and be mentored and supervised. Planning – Risk Assessments – New and Expectant Mothers Planning – Risk Assessment – Specific and Special Case Risk Assessments that will require special consideration include: • Fire • Manual Handling • Display Screen Equipment • Harmful Chemicals. There should also be specific risk assessments for: • Young Persons • New and expectant mothers, which includes nursing mothers. Regulation 16 of the MHSWR state: Where, the persons working in an undertaking include women of child-bearing age and; the work is of a kind that could invoke risk, by reason of her condition, to the health and safety of a new or expectant mother, or to that of her baby, from any processes or working conditions, or physical, biological, or chemical agents, including those specified in Annexes I and II of council directive 92/85/EC, on the introduction of measures to encourage improvements in the safety and health at work of pregnant workers and worker who have recently given birth or breastfeeding. Regulation 18 is concerned with actions that must be taken when employers are notified in writing. Risks can include Physical risks (posture, long periods standing or sitting, manual handling, vibration, radiation, temperature), Biological (HIV, Rubella), Chemical (Toxic, mutagens, carbon monoxide, lead), Working Conditions (fatigue, stress, passive smoking, heights, violence).
Health & Safety Management System Planning – Risk Assessment – Specific and Special Case RA’s Health & Safety Management System Planning – Risk Assessment – New and Expectant Mothers Health & Safety Management System Planning – Risk Assessment – Review Health & Safety Management System Planning – Risk Assessment – Risk Young Persons
Planning - Principles of Prevention There are some general principles or common rules that assist the safety practitioner, and these combine three types of control. These are Technical, Behavioural, and Procedural. When controlling risks, the following principles should apply: • Avoiding Risks – Where possible, design the risks out, or eliminate. Some risks cannot be avoided but should be where possible. • Evaluating Unavoidable Risks – If a risk cannot be avoided there needs to be careful consideration about the hazards involved, use the hierarchy of control and find the best way to mitigate the risks AFARP. • Controlling the hazards at source – You should seek to see where the hazard stems from and mitigate it at this point. E. g. if a level of noise is being produced that is high, then focus on reducing the risk at source rather than issuing hearing protection. • Adapting to the Individual – Give employees a degree of control taking into account their physical and mental capabilities. Planning work around them. • Adapting to Technical Progress. • Replacing the Dangerous with the non or less dangerous. • Developing a coherent policy – Where risks cannot be avoided or changed, prevention policies can be used. SSOW, communication, training, information, instruction, and supervision. Collective preventative measures should always be given priority over individual ones. Planning – Collective / Individual Protective Measures Collective Measures - This is the concept of creating a ‘safe place’. This is the focus on ensuring everyone is protected rather than just the individual. Collective safety should always take priority over individual safety. Collective measures include avoidance of risk, controlling at source, replacing the dangerous with the non or less dangerous etc are all collective measures. Individual Measures – The most obvious example is issuing PPE, so that the individual is protected but does not directly reduce the hazard. An example of this is falls from height. The collective measure is the use of scaffold to prevent a fall, but an individual measure would be to wear a harness. This should be with always providing the appropriate information, instruction, training and supervision, including the use of signage to reinforce the communication. Planning – Health and Safety (Safety Signs) Regulations. There are four main types of standardised safety signs. These are: Planning – General Hierarchy of Control This is defined as ‘A list of risk control measures, which are considered in order of importance, effectiveness and priority’. The following is another example of a hierarchy of control for health and safety: • Elimination • Substitution • Engineering Controls – isolated, guarding, barriers, local exhaust ventilation • Administrative Controls – signs, training, SSOW, job rotation, supervision, changing tasks regularly. • PPE. Then there are welfare facilities such as first aid, washing facilities, provision of barrier cream or storage for PPE, and then monitoring and supervision to ensure tasks are carried out as per instructions and training.
Health & Safety Management System Planning – Collective / Individual Measures Health & Safety Management System Planning – General Hierarchy of Control Health & Safety Management System Planning – Principles of Prevention Health & Safety Management System Planning – Risk Assessment – Risk Young Persons
Planning – Safe System of Work (2) Planning - Sources of H&S information Internal Sources – These include, accident and ill health data, near miss reports, absence reports (reactive data), and inspections, maintenance reports are proactive data sources. Audits and staff complaints can also be used and this data can be collated and compared with other companies in similar industries. External sources – These include, legislation, HSE guidance, EU publications. Manufacturer’s data, British, European and International standards provide further information and compliance requirements. Trade associations, International Labour Organisation. Other Sources – Risk Assessments, employee / safety reps, task analysis, accident and absence analysis, training records, results of surveys, specialists (Occy health), can all be used to help measure performance. Analysing Tasks, identifying hazards and assessing risks. It is vital to consider all aspects of the task, not just the physical but the potential health problems too. You could ask: what is used, who does what, where is the task carried out, how is the task going to be done. Then you need to identify and evaluate the hazards and risks. Implementing the System. The SSOW must be communicated properly so it is understood by those who need to use it. Adequate training needs to be provided, and make provision for stoppages if an issue arises. If there are works that require specialist knowledge, competent people can be used to advise on the SSOW. Monitoring the Systems should be checked to ensure that: • Employees continue to find the system workable. • Procedures laid down are being carried out and are effective. • Any changes in circumstances which require alterations to the system of work are taken into account. Written Procedures A written procedure should include: an unambiguous description of the way each step of the job is done, an emphasis on the do’s and don’ts. This should include enforcement of the rules. Planning – Confined Spaces Planning – Safe Systems of Work The duty to provide a safe system of work comes from the HSWA Section 2(2) to: Provide and maintain a plant and safe systems of work that AFARP without risk to health. A definition of a safe system of work is “A formal procedure, which results from systematic examination of a task in order to identify all of the hazards. It defines safe methods to ensure that hazards are eliminated or risks reduced. When developing a safe system of work, the 5 steps of assessment should be applied. • Assess the Task • Identify hazards • Define safe methods • Implement system • Monitor system “A defined space is any space of an enclosed nature where there is a risk of death or serious injury from a specific risk”. Examples include: storage tanks, silos, enclosed drains, sewers, chambers, vats, ductwork, and unventilated rooms. Hazards to consider are: lack of oxygen, poisonous gas, fumes or vapour, ingress of liquids from free flowing solids, fire and explosion, residues, dust, hot conditions. Confined spaces are covered in specific legislation “Confined Space Regulations 1997”. This places the following requirements on this type of work: • Avoid entry to confined spaces • If entry is unavoidable, follow a SSOW • Put in place adequate emergency arrangements before work starts. The SSOW is likely to include: Issuing of a permit to work, provision that the person must be medically fit and suitably trained, incoming services are isolated (e. g. gas), adequate ventilation, air tests are conducted during work, tools and lighting are suitable, suitable PPE is provided, emergency arrangements are in place, monitoring and supervision are in place, with provision for communication (e. g. radio).
Health & Safety Management System Planning – Safety System of Work (1) Health & Safety Management System Planning – Confined Spaces Health & Safety Management System Planning – Sources of Health & Safety information Health & Safety Management System Planning – Safe Systems of Work (2)
Planning - Lone Working Lone working can include one person working alone, or people working on the same site, but far away from each other. This can also be people working outside of normal hours, or remote workers. A safe system of work for lone workers is likely to include: • Training and competent staff – ideally avoiding new recruits or recent trained people, or vulnerable (young persons or expectant mothers). • Adequate supervision – regular contact, regular visits where possible. • Regular contact – Where physical visits are not possible. Helps make the person feel safe and sense of belonging. • Automatic Warning Devices – Man down alarms, sensors (such as fire sensor or gas). • Personal Alarms – to summon help is the person cannot do this themselves. • Diary System – Helps to identify the tasks and location of worker. • First aid provision and training - providing adequate training and first aid supplies. • Emergency Procedures / Contact details – being aware of arrangements. • A second person to assist when needed – providing help is required. Measuring, Audit and Review There a number of reasons why we would want to monitor health & safety performance: • Determine whether or not health and safety plans have been implemented and objectives achieved. • Check that adequate risk controls are in place. • Learn from health & safety failures (including management failures) • Provide information that can be used to review and improve aspects of the health and safety management system. Organisations are required by law to have arrangements for effective monitoring and review. This is covered under regulation 5 of the MHSWR. It requires the organisation to have in place arrangements for effective: planning, organisation, control, monitoring and review. This is based on the Plan-Do-Check-Act theory of continuous improvement. Plan – Establish the objectives and processes necessary to deliver results in accordance with the expected output. Do – Implement the new processes. Check – Measure the new processes and compare the results against the expected results. Act – Analyse the differences to determine where to apply changes that will include improvement. You cannot manage, what you cannot measure. Planning – Permit to work system A permit to work system is a formal written system that is used to control certain types of high hazard work. It specifies the work to be done, and the precautions to be taken. This includes ensuring control measures are recorded and signed authority is given. Operation and Application The types of work that warrant a permit to work are: • Hot Work (grinding, welding) • Confined Space Entry • Maintenance Work • Live Electrical work. • Excavations • Works at height Generally it should include: Permit title and reference number, job location and plant identification, date, time, duration of permit, description of work tasks, hazard identification, necessary precautions, PPE required, authorisation, acceptance, handover or extension procedure, cancellation. Measuring Performance The measures used to monitor H&S performance must be appropriate to the size and complexity of the risks to the business. They should cover workplace precautions, risk control systems and management arrangements that take into account the health & safety culture. Incident reporting data is a measurement of failure within an organisation because its use as a measure is reliant upon the workforce logging occurrences. There is no ideal measure of performance as each measure has it’s own advantages and disadvantages. Monitoring is only a means to an end; effective monitoring combines both proactive and reactive methods. It identifies areas for improvement, but the results must be acted upon for the monitoring to have any benefit. Monitoring health and safety performance is an on-going activity. Measurement should be both efficient and effective and needs to be planned appropriately.
Health & Safety Management System Planning – Permit to Work Health & Safety Management System Measuring Performance Health & Safety Management System Planning – Lone working Health & Safety Management System Measuring, Audit and Review General
Accident Calculations Active Monitoring There a number of methods that an organisation can use to achieve active monitoring. These include: • Workplace Inspections - Doing this should spot hazards and unsafe conditions before an accident occurs. These can include, statutory inspections like lifting equipment, safety sampling, enforcement authority inspections. • Safety Tours and Safety Sampling – This is doing only a partial group or area to indicate whole workplace compliance. • Attitude surveys – These can be surveys using equipment to say measure noise (Safety Survey) or of staff to measure opinion. • Behavioural monitoring – Watching employees at work and correcting unsafe behaviour and praising safe behaviour. Help promote a positive culture. • Environmental monitoring - Ensuring environmental aspects are measured (waste etc) • Benchmarking against other organisations. • Health surveillance. Reactive Monitoring Health and Safety Auditing. Reactive monitoring includes the use of historic data and focuses on what has already gone wrong within an organisation. The types of data that are used for reactive monitoring include: • Accidents and ill health - (Shown on next card) – good because accidents that are RIDDOR are hard to suppress, good for benchmarking, can identify trends. Bad for negative measures, random in nature, reporting rates can vary, poor at assessing awareness raising as this can increase accident reporting. • Sickness absence – can show trends in areas where sickness is high. Can highlight stress or problem areas. • Dangerous occurrences • Near Misses / property damage – by investigating near misses, we can prevent accidents, you can learn from it without the injury. More frequent than actual accidents. • Civil compensation claims • Enforcement action. An audit is a thorough, critical, examination of an organisation. Audits should be planned for due to the in-depth nature and number of information sources required. The outcomes of an audit should be provided in report format, which details performance standards against targets. The results should provide confirmation that the H&S systems are in place and are effective, and provide evidence that the organisation is achieving legal compliance. Where there are non conformances, these should be reported with suggested corrective actions. An effective audit should be: • Independent • Systematic • Critical • Comprehensive • Objective • Evidence-Based.
Health & Safety Management System Planning – Reactive Monitoring Health & Safety Management System Health & Safety Auditing Health & Safety Management System Active Monitoring Health & Safety Management System Accident Calculations
Audit and Inspection Differences There are several key difference between an audit and an inspection: Audit Inspection A lengthy process, examining the whole management system. Shorter timescale, simple observation of workplace. A full, comprehensive report is produced. Less detailed, can be carried out by supervisors, H&S reps. Involves external or internal auditors who observe, interview and review. Short report / checklist Requires detailed planning, and carried out infrequently More frequent and less time and resources than audit. Considerate resource and effort required. Gives early indication of declining standard. Advantages / Disadvantages of Auditing The advantages of health & safety auditing are: • Measures performance against pre-set standard • Easy to identify levels of improvement or deterioration from previous audits. • Numerical / ranking systems (quantitative) can be used. • Issues involved are directly under control of managers • Check management arrangements against actual performance • Organisations are familiar with the audit as a management tool. Disadvantages are: • Can only be infrequent or they will lose effectiveness. • Audit fatigue – lots of audits for finance, quality, environmental etc • Usually a long list of corrective actions • Different systems use different scoring so can be hard to compare. • Much depends on the individual auditor. • Off the shelf systems can be too general. Pre-Audit Preparations Typically , the audit uses three types of evidence: • Documentary • Observation • Interview Documentation can be prepared in advance and include: H&S policy, RA’s, training records, maintenance records, inspection / previous audit reports, H&S minutes, SSOW / Procedures, liaison with enforcement agencies, accident/ incident reports, complaints from employees. The audit must be communicated in advance so people are aware who will need to be involved and documentation can be prepared, what the agenda is and a time frame. A post audit meeting should be organised to go through preliminary findings before the audit report is written up. Internal audits – these can be useful as can pick up issues before an external one, but can be biased. External audits – useful as the auditor is likely to have wide reaching experience, and the report will be more credible. They will also be well qualified, training and up to date with the law. Accidents and Incidents Injury - Injury describes the types of incident that result in harm. Ill-Health – Refers to an illness that has developed as a result of exposure to something within the workforce. E. g. asbestosis. Dangerous Occurrence – are events that if the inputs had been different, could have resulted in a major incident. Damage Only – Where no-one is injured but there may have been damage to the building, plant equipment or materials. Accident – An unplanned and undesired event which results in harm to a person or damage to property. Near Miss – An planned, undesired event, which, under slightly different circumstances could have resulted in harm to a person or damage to property. Accident Causation - Identification of causes of an accident is a critical step in the investigation process. It can be chain of failures and errors that lead to the cause, often known as the domino effect. Causes of accidents include the immediate cause (unsafe acts and conditions) and root causes or the underlying causes (management system failures).
Health & Safety Management System Advantages / Disadvantages of Auditing Health & Safety Management System Planning – Accidents and Incidents Health & Safety Management System Audit and Inspection Differences Health & Safety Management System Pre-Audit Preparations
Statutory Requirements for Recording and Reporting Incidents RIDDOR Reporting The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 state that certain types of event must be reported to the relevant authority by the responsible person. These events include: • Death • Major injury • Dangerous occurrence • Diseases • Any worker incapacitated for more than 7 days as a result of an accident at work. • Immediate hospitalization of a non worker. RIDDOR places specific duties on the reporting of certain accidents. The requirements to report are based upon the severity of the injuries. These include major accident, certain diseases and certain dangerous occurrences. RIDDOR Reportable Examples An organisation is duty bound to report major injuries, fatalities, dangerous occurrences and hospitalisation. In the event of any of these occurring, the responsible person must report by the quickest practicable means. In case of a fatality or major injury this will be by telephone. This will need to be followed by form F 2508 within 10 days. Over 7 days injuries must also be reported within 15 days. These days are even if they include the weekend or days when the employee was not due to be at work. Most of these reports are now made to the HSE via the Incident Contact Centre. Accident Reporting and Investigation In addition to the enforcing authority, there are other parties who may need to be informed of accidents depending on the severity. Examples are: • Senior Management • Safety Representatives • Health & Safety Advisor / Manager • Next of Kin • First Aider or Emergency Services • Police and coroner (if a fatality) • Insurance company In the event of an incident, the investigation should follow these basic steps. • Ensure the wellbeing of the injured person. • Preserve the scene. • Report the incident / accident • Assemble the investigation team – This is likely to include: someone familiar with the work location, person(s) involved, supervisor, line manager, director, H&S professional, other experts, Safety representative.
Health & Safety Management System RIDDOR Reportable Examples Health & Safety Management System Accident Reporting and Investigation Health & Safety Management System RIDDOR Reporting Health & Safety Management System Statutory Requirements for Recording and Reporting Incidents
Investigation Approach The information gathered should include not just physical evidence at the scene, but documentary evidence and human evidence, such as witness reports. The findings must be analysed and causes determined. The team should make recommendations and issue them as part of an action plan. The investigation should include photographs, sketches relating to the incident, and include relevant records such as training records, maintenance records or risk assessments. The team should conduct interviews with witnesses, which should be done soon after the event in a private room individually. They need to be put at ease and informed it is a fact gathering interview, not to apportion blame. A written record should be taken. Once the initial investigation has been completed with determined root causes the organisation may need to collect data for litigation purposes. Consideration must then be given to the return to work of the injured person. Remedial Actions The significant findings must be communicated effectively, if improvements and opportunities to reduce the likelihood of recurrence are to be acted upon. Actions must be assigned priority status and deadline for completion. Action Plan and Implementation • Provide an action plan with SMART objectives. • Ensure the action plan deals with immediate, underlying and root causes. Include lessons to be learned. • Provide feedback to all parties involved. • Information should be fed back into a review of the risk assessment. • Communicate the results of the investigation and action plan to those who need to know. • Include arrangements to ensure the actions plan is implemented and progress monitored.
Health & Safety Management System Investigation Approach Health & Safety Management System Remedial Actions / Action Plan