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ENVIRONMENTAL AND SAFETY ENGINEERING DEPARTMENT

Lecture Notes On

Occupational Health & Safety Management


(Short Course)

Compiled by:

Eric Stemn (PhD)


[Environmental & Safety Engineering Department]

April 2020

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Lecture Notes on Short Course on Occupational Health & Safety Management November 2020

GENERAL COURSE INFORMATION


Course Details
Course Code: Short Course OHS
Course Title: Occupational Health and Safety Management
Coordinating Department: Environmental & Safety Engineering Department
Semester: Semester 2, 2019/2020 Academic Year
Level: Short Course
Contact Hours: 4 hrs/day for 5 days (total of 20 contact hours)

Course Staff
Course Coordinator: Dr Eric Stemn, Mr Francis Krampah
Course Organiser: Mr Theophilus Joe-Asare

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Lecture Notes on Short Course on Occupational Health & Safety Management November 2020

COURSE AIMS & OBJECTIVES


Occupational safety and health (OSH) is generally defined as the science of the
anticipation, recognition, evaluation and control of hazards arising in or from the
workplace that could impair the health and well-being of workers, taking into account the
possible impact on the surrounding communities and the general environment. Over the
years, OHS has become an important subject across several industries and has received
significant research attention. This strong focus on OHS is largely due to the need to
protect the health, safety and well-being of workers are they are key to the sustainability
of business and play an important role in ensuring operational excellence of industry.

This course is therefore, an introduction to the management principles of occupational


health and safety and aims at offering student both theoretical and practical to support
theme create awareness of public and occupational health and safety requirements
associated with the work environment.

Specifically, the course seeks to ensure an understanding of the following broad objectives

✓ The relevance of OHS and how effective OHS contributes to productivity and
profitability
✓ Why investing in OHS is good business
✓ The components of an effective OHS management plan
✓ How to design and implement an effective OHS management plan

LEARNING RESOURCES
Required Resources
This handout is the minimum learning resource required for this course. Students should
note that several references have been made in the handout and they are encouraged to
read those references to better appreciate the course. Additionally, several reading
assignments, which are none-scoring have equally been outlined in the handout. Some of
the reference materials have been upload as part of the course materials on the online
platform and course participants can freely download them.
Recommended Resources
The recommended resources have been provided as footnote and reading assignment in
their respective chapters throughout this handout. Other recommended resources have
been provided at the online platform and are freely downloadable.

Other Learning Resources & Information


The students will need to utilise information from a large number of documents and
reference sources. All of this reference material is available either on the web or as
reference texts. The most important of these have been provided as references in this
lecture notes. The students will, however, need to search the web for other useful
information and reference material.

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Lecture Notes on Short Course on Occupational Health & Safety Management November 2020

TEACHING & LEARNING ACTIVITIES


Learning Activities
A schedule of the learning activities has been provided below

Day Date Learning Activity

Mon, Nov 23 Course Overview, Occupational Health and Safety Foundation


1
Mon, Nov 23 Occupational Health and Safety Policy

Tue, Nov 24 Organising for Occupational Health and Safety


2
Introduction to Occupational Health and Safety Management
Tue, Nov 24
System

Wed, Nov 25 Hazard at the Workplace and their Control I


3
Wed, Nov 25 Hazard at the Workplace and their Control II

Thu, Nov 26 Risk Management


4
Thu, Nov 26 Accidents and Emergencies

Fri, Nov 27 Monitoring, Review and Audit


5
Fri, Nov 27 Recap, Final Examination

Other Teaching and Learning Activities Information


There will be weekly lectures and tutorials. Additional group and individual support can
be arranged with the course lecturers on a need basis and by arrangement.

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COURSE ASSESSMENT
Assessment of Student
The student’s assessment will be in two forms:
Continuous Assessment [60%] (Quizzes, Class Attendance, Assignments and Group
Project)
End of Course Examination [40%].
Assessment Summary
This is a summary of the assessment in the course. For detailed information on each
assessment, see the Assessment Detail below.

Assessment Task Due Date

In Class Quiz, Quizzes on readings and lecture materials Nov 23-27

Assignment 1, Risk Assessment Nov 26 by 11:pm

Final Exams, End of Course Examination Nov 27, by 7pm

Assessment of Lecturer
At the end of the course, each student will be required to evaluate the course and the
lecturers’ performance by answering a questionnaire specifically prepared to obtain the
views and opinions of the student about the course and lecturer. The date of this exercise
will be communicated. Please be sincere and frank!

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TABLE OF CONTENTS
GENERAL COURSE INFORMATION .............................................................................. i
COURSE AIMS & OBJECTIVES ..................................................................................... ii
LEARNING RESOURCES ............................................................................................... ii
TEACHING & LEARNING ACTIVITIES ........................................................................ iii
COURSE ASSESSMENT ................................................................................................ iv
TABLE OF CONTENTS .................................................................................................. v
LIST OF FIGURES ......................................................................................................... xi
LIST OF TABLES ........................................................................................................... xi

1. OCCUPATIONAL HEALTH AND SAFETY FOUNDATIONS .................................. 1


1.1 Introduction ............................................................................................................ 1
1.2 Basic Definitions ..................................................................................................... 2
1.3 Moral, Legal and Financial Arguments for Health and Safety Management ........... 3
1.3.1 Moral arguments .............................................................................................. 3
1.3.2 Legal argument ................................................................................................ 4
1.3.3 Financial arguments ......................................................................................... 4
1.4 Legal Framework of Occupational Health and Safety ............................................ 5
1.4.1 Criminal law..................................................................................................... 7
1.4.2 Civil law ........................................................................................................... 7
1.4.3 Negligence ....................................................................................................... 8
1.4.4 Duties of care ................................................................................................... 9
1.4.5 The legal case for OHS management in Ghana ............................................... 9
1.5 The Framework for Health and Safety Management ............................................ 11
1.5.1 Policy ............................................................................................................. 11
1.5.2 Organising ..................................................................................................... 11
1.5.2 Planning and implementing ........................................................................... 12
1.5.3 Measuring performance ................................................................................. 12
1.5.4 Reviewing performance ................................................................................. 12
1.5.6 Auditing ......................................................................................................... 12

2. OCCUPATIONAL HEALTH AND SAFETY POLICY ............................................. 14


2.1 Introduction .......................................................................................................... 14

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2.2 Legal requirements ............................................................................................... 14


2.3 Key elements of a health and safety policy ........................................................... 14
2.3.1 Policy statement of intent ............................................................................... 14
2.3.2 Organization of health and safety .................................................................. 16
2.3.3 Arrangements for Health and Safety .............................................................. 17
2.4 Review of health and safety policy ....................................................................... 18

3. ORGANISING FOR HEALTH AND SAFETY ......................................................... 20


3.1 Introduction .......................................................................................................... 20
3.2 Control ................................................................................................................. 20
3.2 Employers’ responsibilities ................................................................................... 21
3.3 Employees’ responsibilities ................................................................................... 21
3.4 Role and Functions of Health and Safety and other Advisers ............................... 21
3.4.1 Competent person ......................................................................................... 21
3.4.2 Health and safety adviser ............................................................................... 22
3.5 Contractors........................................................................................................... 22
3.5.1 Introduction ................................................................................................... 22
3.5.2 Legal considerations ...................................................................................... 23
3.5.3 Safety rules for contractors ............................................................................. 23

4. INTRODUCTION TO SAFETY MANAGEMENT SYSTEMS .................................. 24


4.1 Introduction .......................................................................................................... 24
4.2 Historical perspective to the development of SMS ............................................... 25
4.2.1 System Safety ................................................................................................ 25
4.2.2 Human Factors .............................................................................................. 26
4.2 3 Business management ................................................................................... 27
4.3 Truth and Misconceptions – What an SMS is and is not ....................................... 28
4.4 Why a Safety Management System ...................................................................... 29
4.4.1 Moral Obligation ............................................................................................ 29
4.4.2 Legal/Regulatory Compliance ........................................................................ 29
4.4.3 Cost Reduction .............................................................................................. 30
4.4.4 Employee Relations ....................................................................................... 30
4.5 Building a Safety Management System ................................................................ 31
4.6 Components of a Safety Management System ..................................................... 31

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4.6.1 Safety Policy and Objectives .......................................................................... 32


4.6.2 Safety Risk Management................................................................................ 33
4.6.3 Safety Assurance ............................................................................................ 33
4.6.4 Safety Promotion ........................................................................................... 33
4.7 Practical Implementation of SMS ......................................................................... 34

5. HAZARDS AT THE WORKPLACE AND THEIR CONTROLS ............................... 35


5.1 Introduction .......................................................................................................... 35
5.2 Movement of People and Vehicle Hazards and Control ....................................... 35
5.2.1 Introduction ................................................................................................... 35
5.2.2 Hazards to pedestrians ................................................................................... 35
5.2.3 Control Strategies for Pedestrian Hazards ...................................................... 37
5.2.4 Hazards in vehicle operations ........................................................................ 39
5.2.5 Control strategies for safe vehicle operations ................................................. 40
5.2.6 The management of vehicle movements ....................................................... 41
5.3 Manual and mechanical hazards and control ....................................................... 41
5.3.1 Manual handling hazards and injuries ............................................................ 41
5.3.2 Manual handling assessments ........................................................................ 43
5.3.4 Reducing the risk of injury ............................................................................. 46
5.3.5 Manual handling training ............................................................................... 46
5.4 Psychosocial Hazard ............................................................................................ 47
5.4.1 Introduction ................................................................................................... 47
5.4.1 Contributing factors ....................................................................................... 48
5.4.2 Signs and symptoms of Psychosocial Hazard................................................. 48
5.4.3 Effects of Psychosocial Hazard ....................................................................... 48
5.4.4 Control of Psychosocial Hazards .................................................................... 48
5.5 Biological Hazards ................................................................................................ 49
5.5.1 Introduction ................................................................................................... 49
5.5.2 Effects of Biological Hazards .......................................................................... 49
5.5.3 Biological Hazards Control ............................................................................ 49
5.6 Electrical Hazards ................................................................................................. 50
5.6.1 Introduction ................................................................................................... 50
5.6.2 Common Electrical hazards ........................................................................... 50
5.6.3 Effects of Electrical Hazards ........................................................................... 50

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5.6.4 Electrical Hazards Control .............................................................................. 50


5.7 Mechanical Hazard ............................................................................................... 51
5.7.1 Mechanical hazards control /prevention ......................................................... 51
5.8 Chemical Hazards ............................................................................................. 51
5.8.1 Types of chemical hazards ............................................................................. 52
5.8.2 Effects of Chemical Hazards .......................................................................... 52
5.8.3 Routes of Entry into the Body ........................................................................ 52
5.8.4 Chemical Hazard Control .............................................................................. 52
5.8 Personal Protective Equipment ............................................................................ 53
5.8.1 Maintenance .................................................................................................. 53
5.8.1 Monitor and review ........................................................................................ 53
5.8.1 Eyes ............................................................................................................... 53
5.8.2 Head and neck .............................................................................................. 54
5.8.3 Ears................................................................................................................ 54
5.8.4 Feet and legs .................................................................................................. 54
5.8.5 Lungs ............................................................................................................. 55
5.8.6 Whole body ................................................................................................... 55

6. RISK MANAGEMENT ............................................................................................. 56


6.1 Understanding the Importance of Risk Management ............................................ 56
6.2 Key Concepts of Risk Management ...................................................................... 57
6.3 Humans and Risk ................................................................................................. 57
6.4 Risk Communication ............................................................................................ 58
6.5 Risk Identification ................................................................................................. 58
6.5 Risk Analysis Theory ............................................................................................ 60
6.6 Risk evaluation and the concepts of tolerable risk and ALARP ............................. 62
6.7 Risk assessment tools and techniques ................................................................... 65
6.8 Risk Treatment ..................................................................................................... 66
6.8.1 Identification of Unwanted Events ................................................................. 66
6.8.2 Selection and Optimisation of Risk Controls .................................................. 69
6.9 Management of Controls: Monitoring and Review, and Verification Activities ..... 70
6.10 Communication and Consultation ..................................................................... 70

7. ACCIDENTS AND EMERGENCIES ....................................................................... 71

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7.1 Managing Workplace Emergencies ....................................................................... 71


7.1.1 Emergency procedures .................................................................................. 71
7.1.2 Points to include in emergency procedures .................................................... 71
7.1.3 Chain of command ........................................................................................ 71
7.1.4 Emergency response team ............................................................................. 72
7.1.5 Emergency response activities........................................................................ 72
7.1.6 Training ......................................................................................................... 72
7.1.7 Personal protection ........................................................................................ 73
7.1.8 Medical treatment .......................................................................................... 73
7.2 Accident at the Workplace .................................................................................... 73
7.2.1 Why investigate? ............................................................................................ 74
7.2.2 Who should do the investigating? .................................................................. 74
7.3.3 Should the immediate supervisor be on the team? ........................................ 75
7.2.4 Why look for the root cause? ......................................................................... 75
7.2.5 What are the steps involved in investigating an incident? .............................. 76
7.2.6 What should be looked at as the cause of an incident? .................................. 76
7.2.7 How are the facts collected?........................................................................... 79
7.2.8 What should I know when making the analysis and recommendations? ........ 81
7.2.9 Why should recommendations be made? ...................................................... 82
7.2.10 The written report ........................................................................................ 82
7.2.11 How should follow-up be done? .................................................................. 83

8. MONITORING, REVIEW AND AUDIT ................................................................... 84


8.1 Introduction .......................................................................................................... 84
8.2 The Traditional Approach to Measuring Health and Safety Performance ............ 84
8.3 Why Measure Performance? ................................................................................ 85
8.3.1 Introduction ................................................................................................... 85
8.3.2 Answering questions ...................................................................................... 86
8.3.3 Decision making ............................................................................................ 86
8.3.4 Addressing different information needs .......................................................... 86
8.4 What To Measure ................................................................................................. 87
8.4.1 Introduction ................................................................................................... 87
8.4.2 Effective risk control ....................................................................................... 87
8.5 Measuring Failure – Reactive Monitoring ............................................................. 88

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8.6 Active Monitoring – How to Measure Performance .............................................. 88


8.6.1 Introduction ................................................................................................... 88
8.6.2 Inspections ..................................................................................................... 89
Daily/weekly/monthly safety inspections ................................................................. 90
8.7 Who Should Monitor Performance? ..................................................................... 90
8.8 Frequency of Monitoring and Inspections ............................................................ 91
8.9 Report Writing ...................................................................................................... 91
8.10 Review and Audit ............................................................................................... 91
8.10.1 Audits – purpose .......................................................................................... 91
8.10.2 Gathering information ................................................................................. 93
8.10.3 Making judgements ...................................................................................... 93
8.10.4 Performance review ..................................................................................... 94

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LIST OF FIGURES
Figure 1.1 Insured and uninsured cost of accidents ......................................................... 5
Figure 1.2 Key elements of successful health and safety management ........................... 13
Figure 4.1 Interrelationships among the four major components of an SMS ................. 32
Figure 5.1 Manual handling – there are many potential ................................................ 41
Figure 5.2 Main injury sites caused by manual handling ............................................... 43
Figure 5.3 HSE guidance for manual lifting – recommended weights ............................ 45
Figure 5.4 Elements of a good lifting technique ............................................................. 47
Figure 6.1 Approach to risk identification ...................................................................... 59
Figure 6.2 Risk matrix .................................................................................................... 61
Figure 6.3 Risk matrix .................................................................................................... 62
Figure 6.4 Risk intolerability and ALARP ....................................................................... 63
Figure 6.5 Safe/unsafe operating zone diagram (from Hassall et al, 2015) .................... 68
Figure 6.6 Approach to risk identification ...................................................................... 69
Figure 6.7 Defining a control (from Hassall et al, 2015) ................................................ 69
Figure 6.8 Traditional view of risk management ............................................................ 70
Figure 7.1 Incident Categories ....................................................................................... 77
Figure 8.1 Health and safety management system......................................................... 87

LIST OF TABLES
Table 6.1 Definitions for Risk Identification ................................................................... 58
Table 6.2 Definitions of Risk analysis ............................................................................. 60
Table 6.3 Definitions of risk analysis .............................................................................. 63
Table 6.4 Range of possible decision-making strategies (Hassall and Sanderson, 2011)65
Table 6.5 Examples of unacceptable risks and unwanted events from the resources
industry .......................................................................................................................... 67

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CHAPTER 1
1. OCCUPATIONAL HEALTH AND SAFETY FOUNDATIONS
1.1 Introduction
Occupational health and safety is relevant to all branches of industry, business and
commerce including traditional industries, information technology companies, the Health
Service, schools, universities, leisure facilities and offices.
The purpose of this chapter is to introduce the foundations on which appropriate health
and safety systems may be built. Occupational health and safety affects all aspects of work.
In a low hazard organization, health and safety may be supervised by a single competent
manager. In a high hazard manufacturing plant, many different specialists, such as
engineers (electrical, mechanical and civil), lawyers, medical doctors and nurses, trainers,
work planners and supervisors, may be required to assist the professional health and safety
practitioner in ensuring that there are satisfactory health and safety standards within the
organization.
There are many obstacles to the achievement of good standards. The pressure of
production or performance targets, financial constraints and the complexity of the
organization are typical examples of such obstacles. However, there are some powerful
incentives for organizations to strive for high health and safety standards. These incentives
are moral, legal and economic.
Corporate responsibility, a term used extensively in the 21st Century world of work, covers
a wide range of issues. It includes the effects that an organization’s business has on the
environment, human rights and third world poverty. Health and safety in the workplace is
an important corporate responsibility issue.
Corporate responsibility has various definitions. However, broadly speaking it covers the
ways in which organizations manage their core business to add social, environmental and
economic value in order to produce a positive, sustainable impact on both society and the
business itself. Terms such as ‘corporate social responsibility’, ‘socially responsible
business’, and ‘corporate citizenship’ all refer to this concept.
In Ghana, within the mining and mineral industry, the Inspectorate Division of the Minerals
Commission (IDMC) is to ensure that the risks to health and safety of workers are properly
controlled. In terms of corporate responsibility, they are to encourage organizations to:
✓ improve management systems to reduce injuries and ill health
✓ demonstrate the importance of health and safety issues at board level
✓ report publicly on health and safety issues within their organization, including their
performance against targets
It is generally believed that effective management of health and safety:
✓ is vital to employee well-being
✓ has a role to play in enhancing the reputation of businesses and helping them
achieve high-performance teams

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✓ is financially beneficial to business.

1.2 Basic Definitions


Before a detailed discussion of health and safety issues can take place, some basic
occupational health and safety definitions are required:
Health – the protection of the bodies and minds of people from illness resulting from the
materials, processes or procedures used in the workplace.
Safety – the protection of people from physical injury. The borderline between health and
safety is ill-defined and the two words are normally used together to indicate concern for
the physical and mental well-being of the individual at the place of work.
Welfare – the provision of facilities to maintain the health and well-being of individuals at
the workplace. Welfare facilities include washing and sanitation arrangements, the
provision of drinking water, heating, lighting, accommodation for clothing, seating (when
required by the work activity), eating and rest rooms. First aid arrangements are also
considered as welfare facilities.
Occupational or work-related ill-health – is concerned with those illnesses or physical and
mental disorders that are either caused or triggered by workplace activities. Such
conditions may be induced by the particular work activity of the individual or by activities
of others in the workplace. The time interval between exposure and the onset of the illness
may be short (e.g. asthma attacks) or long (e.g. deafness or cancer).
Environmental protection – arrangements to cover those activities in the workplace which
affect the environment (in the form of flora, fauna, water, air and soil) and, possibly, the
health and safety of employees and others. Such activities include waste and effluent
disposal and atmospheric pollution.
Accident – may be defined as ‘any unplanned event that results in injury or ill health of
people, or damage or loss to property, plant, materials or the environment or a loss of a
business opportunity’. Other authorities define an accident more narrowly by excluding
events that do not involve injury or ill health. In this course we will adopt this definition of
an accident.
Near miss – is any incident that could have resulted in an accident. Knowledge of near
misses is very important since research has shown that, approximately, for every 10 ‘near
miss’ events at a particular location in the workplace, a minor accident will occur.
Dangerous occurrence – is a ‘near miss’ which could have led to serious injury or loss of
life. Examples include the collapse of a scaffold or a crane or the failure of any passenger
carrying equipment
Hazard a hazard is the potential of a substance, activity or process to cause harm. Hazards
take many forms including, for example, chemicals, electricity and working from a ladder.
A hazard can be ranked relative to other hazards or to a possible level of danger.

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Risk - A risk is the likelihood of a substance, activity or process to cause harm. A risk can
be reduced and the hazard controlled by good management.
It is very important to distinguish between a hazard and a risk – the two terms are often
confused and activities such as construction work are called high risk when they are high
hazard. Although the hazard will continue to be high, the risks will be reduced as controls
are implemented. The level of risk remaining when controls have been adopted is known
as the residual risk. There should only be high residual risk where there is poor health and
safety management and inadequate control measures.

1.3 Moral, Legal and Financial Arguments for Health and Safety Management
1.3.1 Moral arguments
The moral arguments are reflected by the occupational accident and disease rates
Accident rates
Accidents at work can lead to serious injury and even death. The International Labour
Organisation (ILO) estimates over 2.3 million work-related death annually. The ILO
further estimate about 313 million non-fatal accidents every year. In Ghana, the mining
industry loses at least five (5) people every year. Although there has been a decrease in
fatalities over recent years, there is still a very strong moral case for improvement in health
and safety performance.
Disease rates
Work related ill-health and occupational disease can lead to absence from work and, in
some cases, to death.
Such occurrences may also lead to costs to the country and to individual employers (sick
pay and, possibly, compensation payments) (consider the Workman Compensation Act
19987, PNDCL 187).
Work related illness and occupational accidents constitute a significant cost to individuals,
families, employers and the wider community and their subsequent reduction could be a
key component of some government’s public health and social exclusion agenda. In 2012,
the then Minister of Employment and Labour Relations, Hon. Nii Armah Ashietey in a
statement said an amount of GH¢956, 362.00 was paid as Workmen’s Compensation to
121 victims of occupational accidents in the public sector. According to him an additional
amount of GH¢915, 177.00 was paid to 273 private sector workers who sustained various
degrees of industrial injuries. In all, the economy of Ghana lost about GH¢1.8 million on
occupational injuries and diseases apart from the loss of live, and source of livelihoods
(Sarpong, 2013). These work-related injuries also result in million of working days lost.

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1.3.2 Legal argument


The legal arguments, concerning the employer’s duty of care in criminal and civil law, will
be covered in the next section. Some statistics on legal enforcement indicate the legal
consequences resulting from breaches in health and safety law. There have been some
very high compensation awards for health and safety cases in the civil courts. There are
some clear legal reasons for sound health and safety management systems.

1.3.3 Financial arguments


Costs of accidents
Any accident or incidence of ill-health will cause both direct and indirect costs and incur
and insured and an uninsured cost. It is important that all of these costs are taken into
account when the full cost of an accident is calculated. In a study undertaken by the HSE
of UK, it was shown that indirect costs or hidden costs could be 36 times greater than
direct costs of an accident. In other words, the direct costs of an accident or disease
represent the tip of the iceberg when compared to the overall costs, as shown in Figure
1.1
Direct costs
These are costs which are directly related to the accident and may be insured or uninsured.
Insured direct costs normally include:
✓ claims on employers and public liability insurance
✓ damage to buildings, equipment or vehicles
✓ any attributable production and/or general business loss.
Uninsured direct costs include:
✓ fines resulting from prosecution by the enforcement authority
✓ sick pay
✓ some damage to product, equipment, vehicles or process not directly attributable
to the accident (e.g. caused by replacement staff)
✓ increases in insurance premiums resulting from the accident
✓ any compensation not covered by the insurance policy due to an excess agreed
between the employer and the insurance company
✓ legal representation following any compensation claim.
Indirect costs
These are costs which may not be directly attributable to the accident but may result from
a series of accidents. Again, these may be insured or uninsured. Insured indirect costs can
include:
✓ a cumulative business loss
✓ product or process liability claims

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✓ recruitment of certain replacement staff.


Uninsured indirect costs include:
✓ loss of goodwill and a poor corporate image
✓ accident investigation time and any subsequent remedial action required
✓ production delays
✓ extra overtime payments
✓ lost time for other employees, such as a First Aider, who attend to the needs of the
injured person
✓ the recruitment and training of most replacement staff
✓ additional administration time incurred
✓ first aid provision and training
✓ lower employee morale possibly leading to reduced productivity
Some of these items, such as business loss, may be uninsurable or too prohibitively
expensive to insure. Therefore, insurance policies can never cover all of the costs of an
accident or disease either because some items are not covered by the policy or the
insurance excess is greater than the particular item cost.

Figure 1.1 Insured and uninsured cost of accidents

1.4 Legal Framework of Occupational Health and Safety


Legal and regulatory regimes can be broadly categorised into compliance or risk-based
systems. In compliance systems, the governing body (Government and/or Regulator)
specify mandatory guidelines and standards that a company must abide by in order to
operate legally and to avoid civil and criminal penalties. In risk-based systems the
emphasis is on the operator to demonstrate duty of care of the employers to ensure health
and safety of workers and to demonstrate systematic processes are used to identify and

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manage potential risks to an acceptable/tolerable level. In the mining industry, different


countries have adopted different approaches. For example, the USA and Ghana uses a
compliance based regulatory system. Australia, on the other hand, officially adopted risk-
based regulations in 1999 for Queensland and in 2002 for NSW 1.

Reading Assignment
Poplin, GS., Miller, HB., Ranger-Moore, J., Bofinger, CM., Kurzius-Spencer, M., Harris,
RB., Burgess, JL. (2008) ‘International evaluation of injury rates in coal mining: A
comparison of risk and compliance-based regulatory approaches’, Safety Science, 46(8),
pp. 1196-1204

Most jurisdictions have laws relating to the management of risks associated with health
and safety, environment and social impact and executing business activities (e.g.
contracting, conducting business transactions etc). Examples of such legislation are listed
below:
✓ Constitution of Ghana
✓ Labour Regulations, 2007 (L.I. 1833).
✓ Labour Act, 2003 (Act No. 651).
✓ Ghana National Fire Service Act
✓ Radiation Protection Instrument (No. 1559 of 1993)
✓ Constitution of the Republic of Ghana (No. 282 of 1992)
✓ Factories Offices and Shops (Amendment) Act (No. 275 of 1991)
✓ Factories, Offices and Shops Act (No. 328 of 1970)
✓ Mineral Commission Act (Act 450 of 1993)
✓ Mining and Mineral Act (Act 703, 2006)
✓ Minerals and Mining (Health, Safety and Technical) Regulations, 2012 (L.I. 2182)
✓ National Fire Service Regulation, 2003 (L.I 1725)
✓ Environmental Protection Act (Act 490 of 1994)
In addition to the legislation listed above there are other legal requirements that a company
and/or individual should abide by. These include an environment authority/license/permit,
commitment agreements with stakeholders, contractual agreements with employees,
vendors, supplier, etc.
Therefore, there is a myriad of laws that an industry professional needs to be aware of
especially when you consider the OHS, environmental, financial, contractual, human
resources laws that typically apply to the activities of resource companies. Thus,
participants are encouraged to examine for themselves the legislation and regulations that
govern the activities they are involved with.

1 Poplin, GS., Miller, HB., Ranger-Moore, J., Bofinger, CM., Kurzius-Spencer, M., Harris, RB., Burgess, JL. (2008) ‘International evaluation of
injury rates in coal mining: A comparison of risk and compliance-based regulatory approaches’, Safety Science, 46(8), pp. 1196-1204

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There are two sub-divisions of the law that apply to health and safety issues: criminal law
and civil law.

1.4.1 Criminal law


Criminal law consists of rules of behaviour laid down by the Government or the State and,
normally, enacted by Parliament through Acts of Parliament. These rules or Acts are
imposed on the people for the protection of the people. Criminal law is enforced by several
different Government Agencies who may prosecute individuals for contravening criminal
laws. It is important to note that, except for very rare cases, only these Agencies are able
to decide whether to prosecute an individual or not.
An individual who breaks criminal law is deemed to have committed an offence or crime
and, if he is prosecuted, the court will determine whether he is guilty or not. If he is found
guilty, the court could sentence him to a fine or imprisonment. Due to this possible loss of
liberty, the level of proof required by a criminal court is very high and is known as proof
‘beyond reasonable doubt’, which is as near certainty as possible. While the prime object
of a criminal court is the allocation of punishment, the court can award compensation to
the victim or injured party. One example of criminal law is the Road Traffic Acts (Act 683,
2004) which are enforced by the police. However, the police are not the only criminal law
enforcement agency. The LI 2182 (Minerals and Mining (Health, Safety and Technical)
Regulations, 2012 (L.I. 2182)) is another example of criminal law and this is enforced by
the Inspectorate Division of the Minerals Commission. Other agencies which enforce
criminal law include the Fire Service, the Environment Protection Agency, Customs Excise
and Preventive Service.
There is one important difference between procedures for criminal cases in general and
criminal cases involving health and safety. The prosecution in a criminal case has to prove
the guilt of the accused beyond reasonable doubt. While this obligation is not totally
removed in health and safety cases, section 40 of the Health and Safety at Work Act 1974
of the UK for instance transferred, where there is a duty to do something ‘so far as is
reasonably practicable’ or ‘so far as is practicable’ or ‘use the best practicable means’, the
onus of proof to the accused to show that there was no better way to discharge his duty
under the Act. However, when this burden of proof is placed on the accused, they need
only satisfy the court on the balance of probabilities that what they are trying to prove has
been done.

1.4.2 Civil law


Civil law concerns disputes between individuals or individuals and companies. An
individual sues another individual or company to address a civil wrong or tort. The
individual who brings the complaint to court is known as the plaintiff and the individual
or company who is being sued is known as the defendant.

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The civil court is concerned with liability and the extent of that liability rather than guilt or
non-guilt. Therefore, the level of proof required is based on the ‘balance of probability’,
which is a lower level of certainty than that of ‘beyond reasonable doubt’ required by the
criminal court. If a defendant is found to be liable, the court would normally order him to
pay compensation and possibly costs to the plaintiff. However, the lower the balance of
probability, the lower the level of compensation awarded.
In extreme cases, where the balance of probability is just over 50%, the plaintiff may ‘win’
his case but lose financially because costs may not be awarded and the level of
compensation low.
For cases involving health and safety, civil disputes usually follow accidents or illnesses
and concern negligence or a breach of statutory duty. The vast majority of cases are settled
‘out of court’. While actions are often between individuals, where the defendant is an
employee who was acting in the course of his employment during the alleged incident, the
defence of the action is transferred to his employer – this is known as vicarious liability.
The civil action then becomes one between the individual and a company

Reading assignment
Identify the legal system in Ghana relating to health and safety, focusing on criminal and
civil law.

1.4.3 Negligence
The only tort (civil wrong) of real significance in health and safety is negligence. Negligence
is the lack of reasonable care or conduct which results in the injury, damage (or financial
loss) of or to another. Whether the act or omission was reasonable is usually decided as a
result of a court action.

For negligence to be established, it must be reasonable and foreseeable that the injury
could result from the act or omission. In practice, the Court may need to decide whether
the injured party is the neighbour of the perpetrator. A collapsing scaffold could easily
injure a member of the public who could be considered a neighbour to the scaffold erector.
An employee who is suing his employer for negligence, needs to establish the following
three criteria:

✓ a duty was owed to him by his employer since the incident took place during the
course of his employment
✓ there was a breach of that duty because the event was foreseeable and all
reasonable precautions had not been taken
✓ the breach resulted in the specific injury, disease, damage and/or loss suffered.

These criteria should also be used by anyone affected by the employer’s undertaking (such
as contractors and members of the public) who is suing the employer for negligence. If the
employer is unable to defend against the three criteria, two further partial defences are

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available. It could be argued that the employee was fully aware of the risks that were taken
by not complying with safety instructions. This defence is unlikely to be totally successful
because courts have ruled that employees have not accepted the risk voluntarily since
economic necessity forces them to work.

The second possible defence is that of ‘contributory negligence’ where the employee is
deemed to have contributed to the negligent act. This defence, if successful, can
significantly reduce the level of compensation (up to 80% in some cases).

1.4.4 Duties of care


Several judgments have established that employers owe a duty of care to each of their
employees. This duty cannot be assigned to others, even if a consultant is employed to
advise on health and safety matters or if the employees are sub-contracted to work with
another employer. These duties may be sub-divided into groups. Employers must:

✓ provide a safe place of work, including access and egress


✓ provide safe plant and equipment
✓ provide a safe system of work
✓ provide safe and competent fellow employees
✓ provide adequate levels of supervision, information, instruction and training

These duties apply even if the employee is working at a third-party premise or if he has
been hired by his employer to work for another employer.

1.4.5 The legal case for OHS management in Ghana


In Ghana, apart from the sector/industry specific laws (Acts and Regulations) that governs
OHS management at the workplace, the Labour Act 2003 (Act 651) and the Factories,
Offices and Shop Act 1970 (Act 328) are the main legal framework governing OHS
management across a range of industries. The Labour Act, which emerged partly due to
Ghana’s involvement in the International Labour Organisation (ILO) applies to all
industrial sectors and covers all workers so far as OHS management is concern, with the
exception of employees in strategic position like Armed forces, Police, Prison services,
Security Intelligence Agencies. The Act outlines general labour issues including OHS
requirements such as the OHS rights and duties of employers and employees, and Part
XV of the Act is very specific to Occupational Health, Safety and Environment.

Unlike the Labour Act, the Factories, Offices and Shop Act is very specific to OHS and
contains detailed information and requirements for the effective management of OHS at
workplace. Specific sections include: the notification of accidents and dangerous
occurrence, hygiene and welfare at the workplace, first aid, among others.

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Employer Cares - Sources: §118-121 of the Labour Act 2003 (Act 651)

✓ In accordance with the Labour Act, it is obligatory on the employer to ensure


health, safety and welfare of persons at workplace by minimizing the causes of
hazards inherent in the working environment.
✓ Employer must ensure careful and safe use, handling, storage and transport of
articles and substances; and provide the necessary information, instructions,
training and supervision as needed.
✓ Employer must take measures to prevent contamination of the workplaces and
protect the workers from, toxic gases, noxious substances, vapours, dust, fumes,
mists and other substances or materials hazardous to safety or health.
✓ Employer must provide separate, sufficient and suitable toilet and washing facilities
and adequate facilities for the storage, changing, drying and cleansing from
contamination of clothing for male and female workers. Adequate supply of clean
drinking water must be available at the workplace.
✓ If an employer fails to comply with the required health and safety standards, he/she
is liable to a fine of maximum 1000 penalty units or to imprisonment of 3 years
maximum or to both.
✓ Worker must use the safety equipment with care and act according to the
prescribed instructions to preserve his health and protect himself from getting
injured. He/she must stop working and report his supervisor about the presence of
danger to his/her life, safety or health. Employer may not terminate the
employment or deduct wages because of this and must not compel the worker to
work there unless the workplace is safe enough.
✓ In case of occupational injury and disease at workplace, employer must report to
the relevant Government agency within seven days. The Minister may issue the
regulations regarding specific measures to be taken by the employer to ensure
health and safety of the workers at workplace.
Free protection- Sources: §118(2)(e) &119(3) of the Labour Act 2003 (Act 651)

✓ In accordance with the provisions of Labour Act 2003, it is obligatory for the
employer to provide protective equipment for free and must not charge or deduct
any amount from the employees' salary for the provision of such equipment.
✓ The employer must provide workers with adequate safety appliances, suitable fire-
fighting equipment, personal protective equipment, and instruct the workers in the
use of such appliances or equipment. Workers are under the obligation to use the
safety appliances, firefighting equipment and personal protective equipment
provided by the employer in compliance with the employer’s instructions.

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Trainings - Sources: §118(2)(c) of the Labour Act 2003 (Act 651)

✓ In accordance with the Labour Act, it is the responsibility of an employer to provide


instruction, training and supervision according to the age, literacy level and other
circumstances of the workers to ensure health and safety at work.

Reading Assignment for class discussion


Identify specific sections of the Labour Act 2003 (Act 651) and the Factories, Offices and
Shop Act 1970 (Act 328), relating to (i) machinery and equipment, (ii) manual handling,
(iii) PPEs, (iv) fire, accident and emergencies, (v) first aid, (vi) cleanliness, housekeeping,
hygiene, washing facilities, (vii) safety signs, (viii) safety training.

1.5 The Framework for Health and Safety Management


Most of the key elements required for effective health and safety management are very
similar to those required for good quality, finance and general business management.
Commercially successful organizations usually have good health and safety management
systems in place. The principles of good and effective management provide a sound basis
for the improvement of health and safety performance.
Six (6) key elements involved in a successful health and safety management system have
been identified as shown in Figure 1.2. These will briefly be discussed in the next
subsections.

1.5.1 Policy
A clear health and safety policy contribute to business efficiency and continuous
improvement throughout the operation. The demonstration of senior management
involvement provides evidence to all stakeholders that responsibilities to people and the
environment are taken seriously. The policy should state the intentions of the organization
in terms of clear aims, objectives and targets.

1.5.2 Organising
A well-defined health and safety organization offering a shared understanding of the
organization’s values and beliefs, at all levels of the organization is an essential component
of a positive health and safety culture. An effective organization will be noted for good
staff involvement and participation; high quality communications; the promotion of
competency; and the empowerment and commitment of all employees to make informed
contributions.

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1.5.2 Planning and implementing


A clear health and safety plan involves the setting and implementation of performance
standards, targets and procedures through an effective health and safety management
system. The plan is based on risk assessment methods to decide on priorities and set
objectives for the effective control or elimination of hazards and the reduction of risks.
Measuring success requires the establishment of practical plans and performance targets
against which achievements can be identified.

1.5.3 Measuring performance


This includes both active (sometimes called proactive) and reactive monitoring to see how
effectively the health and safety management system is working. Active monitoring
involves looking at the premises, plant and substances plus the people, procedures and
systems. Reactive monitoring discovers through investigation of accidents and incidents
why controls have failed. It is also important to measure the organization against its own
long-term goals and objectives.

1.5.4 Reviewing performance


The results of monitoring and independent audits should be systematically reviewed to
evaluate the performance of the management system against the objectives and targets
established by the health and safety policy. It is at the review stage that the objectives and
targets set in the health and safety policy may be changed. Changes in the health and
safety environment in the organization, such as an accident, should also trigger a
performance review Performance reviews are part of any organization’s commitment to
continuous improvement. Comparisons should be made with internal performance
indicators and the external performance indicators of similar organizations with exemplary
practices and high standards.

1.5.6 Auditing
An independent and structured audit of all parts of the health and safety management
system reinforces the review process. Such audits may be internal and external. The audit
assesses compliance with the health and safety management arrangements and
procedures. If the audit is to be really effective, it must assess both the compliance with
stated procedures and the performance in the workplace. It will identify weaknesses in the
health and safety policy and procedures and identify unrealistic or inadequate standards
and targets. The conclusions from an audit of an organization’s health and safety
performance should be included in the annual report for discussion at Board meetings.

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a clear health and safety policy contributes


to business efficiency and continuous
Policy improvement throughout the operation

Involvement & participation,


Auditing Organising communication,
Internal & external audits
competencies, improvement

HS mgt

Reviewing Planning &


Evaluating results of performance Implementing Performance standards,
performance measurement targets, procedure

Measuring
Active and reactive performance
monitoring

Figure 1.2 Key elements of successful health and safety management

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CHAPTER 2
2. OCCUPATIONAL HEALTH AND SAFETY POLICY
2.1 Introduction
Every organization should have a clear policy for the management of health and safety so
that everybody associated with the organization is aware of its health and safety aims and
objectives. For a policy to be effective, it must be honoured in the spirit as well as the letter.
A good health and safety policy will also enhance the performance of the organization in
areas other than health and safety, help with the personal development of the workforce
and reduce financial losses.

2.2 Legal requirements


In some countries, it is a legal requirement for companies and employers satisfying certain
specified criteria to prepare and revise a written health and safety policy regularly.
Therefore, in those countries, organisational having a health and safety policy is not only
out of goodwill but also to obtain the legitimacy to operate. For instance, in the UK, Section
2(3) of the Health and Safety at Work Act and the Employers’ Health and Safety Policy
Statements (Exception) Regulations 1975 require employers, with five or more employees,
to prepare and revise on a regular basis a written health and safety policy together with
the necessary organization and arrangements to carry it out and to bring the statement
and any revision of it to the notice of their employees. Unfortunately, in Ghana we do not
have such legal requirement, largely because we do not have a unified health and safety
regulation.
In countries where the law mandates organisation to have a health and safety policy, the
law specifies that the written health and safety policy should include the following three
sections:
✓ a health and safety policy statement of intent which includes the health and safety
aims and objectives of the organization
✓ the health and safety organization detailing the people with health and safety
responsibilities and their duties
✓ the health and safety arrangements in place in terms of systems and procedures.
These will be discussed in detail in the next sections of this chapter.

2.3 Key elements of a health and safety policy


2.3.1 Policy statement of intent
The health and safety policy statement of intent is often referred to as the health and safety
policy statement or simply (and incorrectly) as the health and safety policy. It should
contain the aims (which are not measurable) and objectives (which are measurable) of the

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organization or company. Aims will probably remain unchanged during policy revisions
whereas objectives will be reviewed and modified or changed each year.
The statement should be written in clear and simple language so that it is easily
understandable. It should also be fairly brief and broken down into a series of smaller
statements or bullet points. The statement should be signed and dated by the most senior
person in the organization. This will demonstrate management commitment to health and
safety and give authority to the policy. It will indicate where ultimate responsibility lies and
the frequency with which the policy statement is reviewed.
The policy statement should be written by the organization and not by external consultants
since it needs to address the specific health and safety issues and hazards within the
organization. In large organizations, it may be necessary to have health and safety policies
for each department and/or site with an overarching general policy incorporating the
individual policies. Such an approach is often used by local authorities and multinational
companies.
The following points should be included or considered when a health and safety policy
statement is being drafted:
✓ the aims should cover health and safety, welfare and relevant environmental issues
✓ the position of the senior person in the organization or company who is responsible
for health and safety (normally the chief executive)
✓ the names of the health and safety adviser and any safety representatives’ duties
towards the wider general public and others (contractors, customers, students, etc.)
✓ the principal hazards in the organization
✓ specific policies of the organization (e.g. smoking policy, violence to staff, etc.)
✓ a commitment to employee consultation possibly using a safety committee or plant
council
✓ duties of employees
✓ specific performance targets for the immediate and long-term future.
Health and safety performance targets are an important part of the statement of intent
because:
✓ they indicate that there is management commitment to improve health and safety
performance
✓ they motivate the workforce with tangible goals resulting, perhaps, in individual or
collective rewards
✓ they offer evidence during the monitoring, review and audit phases of the
management system.
The type of target chosen depends very much on the areas which need the greatest
improvement in the organization. The following list, which is not exhaustive, shows
common health and safety performance targets:
✓ a specific reduction in the number of accidents, incidents and cases of work-related
ill-health (perhaps to zero)

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✓ a reduction in the level of sickness absence


✓ a specific increase in the number of employees trained in health and safety
✓ an increase in the reporting of minor accidents and ‘near miss’ incidents
✓ a reduction in the number of civil claims
✓ no enforcement notices from the regulatory authorities
✓ a specific improvement in health and safety audit scores
✓ the achievement of an internationally recognised health and safety management
standard, such as ISO 45001.
The policy statement of intent should be posted on prominent notice boards throughout
the workplace and brought to the attention of all employees at induction and refresher
training sessions. It can also be communicated to the workforce during team briefing
sessions, at ‘toolbox’ talks which are conducted at the workplace or directly by email,
intranet, newsletters or booklets. It should be a permanent item on the agenda for health
and safety committee meetings where it should be reviewed at each meeting.

2.3.2 Organization of health and safety


This section of the policy defines the names, positions and duties of those within the
organization or company who have a responsibility for health and safety. Therefore,
it identifies those health and safety responsibilities and the reporting lines through the
management structure. This section will include the following groups together with their
associated responsibilities:
✓ directors and senior managers (responsible for setting policy, objectives and targets)
✓ supervisors (responsible for checking day-to-day compliance with the policy)
✓ safety advisers (responsible for giving advice during accident investigations and on
compliance issues)
✓ other specialist, such as an occupational nurse, chemical analyst and an electrician
(responsible for giving specialist advice on particular health and safety issues)
✓ safety representatives (responsible for representing employees during consultation
meetings on health and safety issues with the employer)
✓ employees (responsible for taking reasonable care of the health and safety of
themselves and others who may be affected by their acts or omissions)
✓ fire officers/wardens/marshals (responsible for the safe evacuation of the building
in an emergency)
✓ first aiders (responsible for administering first aid to injured persons)
For smaller organizations, some of the specialists mentioned above may well be employed
on a consultancy basis. For the health and safety organization to work successfully, it must
be supported from the top (preferably at Board level) and some financial resource made
available.
It is also important that certain key functions are included in the organization structure.
These include:

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✓ accident investigation and reporting


✓ health and safety training and information
✓ health and safety monitoring and audit
✓ health surveillance
✓ monitoring of plant and equipment and its maintenance
✓ liaison with external agencies
✓ management and/or employee safety committees – the management committee
will monitor day to day problems and any concerns of the employee health and
safety committee.
The role of the health and safety adviser is to provide specialist information to managers
in the organization and to monitor the effectiveness of health and safety procedures. The
adviser is not ‘responsible’ for health and safety or its implementation; that is the role of
the line managers.
Finally, the job descriptions, which define the duties of each person in the health and
safety organizational structure, must not contain responsibility overlaps or blur chains of
command. Everyone must be clear about his/her responsibilities and the limits of those
responsibilities.

2.3.3 Arrangements for health and safety


The arrangements section of the health and safety policy gives details of the specific
systems and procedures used to assist in the implementation of the policy statement. This
will include health and safety rules and procedures and the provision of facilities such as
a first aid room/box and washrooms. It is common for risk assessments (including manual
handling and PPE assessments) to be included in the arrangements section particularly for
those hazards referred to in the policy statement. It is important that arrangements for fi re
and other emergencies and for information, instruction, training and supervision are also
covered.
The following list covers the more common items normally included in the arrangements
section of the health and safety policy:
✓ employee health and safety code of practice
✓ accident and illness reporting and investigation procedures
✓ emergency procedures, first aid
✓ procedures for undertaking risk assessments
✓ control of exposure to specific hazards (noise, vibration, radiation, manual
handling, hazardous substances etc.)
✓ machinery safety (including safe systems of work, lifting and pressure equipment)
✓ electrical equipment (maintenance and testing)
✓ maintenance procedures
✓ permits to work procedures
✓ use of personal protective equipment
✓ monitoring procedures including health and safety inspections and audits

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✓ procedures for the control and safety of contractors and visitors


✓ provision of welfare facilities
✓ training procedures and arrangements
✓ catering and food hygiene procedures
✓ arrangements for consultation with employees
✓ terms of reference and constitution of the safety committee
✓ procedures and arrangements for waste disposal
The three sections of the health and safety policy are usually kept together in a health and
safety manual.

2.4 Review of health and safety policy


It is important that the health and safety policy is monitored and reviewed on a regular
basis. For this to be successful, a series of benchmarks need to be established. Such
benchmarks, or examples of good practice, are defined by comparison with the health and
safety performance of other parts of the organization. Typical benchmarks include accident
rates per employee and accident or disease causation.
There are several reasons to review the health and safety policy. The more important
reasons are:
✓ significant organizational changes have taken place
✓ there have been changes in personnel
✓ there have been changes in legislation
✓ the monitoring of risk assessments or accident/incident investigations indicate that
the health and safety policy is no longer totally effective
✓ enforcement action has been taken by the regulatory authority
✓ a sufficient period of time has elapsed since the previous review
A positive promotion of health and safety performance will achieve far more than simply
prevent accidents and ill-health. It will:
✓ support the overall development of personnel
✓ improve communication and consultation throughout the organization
✓ minimise financial losses due to accidents and ill-health and other incidents
✓ directly involve senior managers in all levels of the organization
✓ improve supervision, particularly for young persons and those on occupational
training courses
✓ improve production processes
✓ improve the public image of the organization or company.
It is apparent, however, that some health and safety policies appear to be less than
successful. There are many reasons for this. The most common are:
✓ the statements in the policy and the health and safety priorities are not understood
by or properly communicated to the workforce

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✓ minimal resources are made available for the implementation of the policy
✓ too much emphasis on rules for employees and too little on management policy
✓ a lack of parity with other activities of the organization (such as finance and quality
control) due to mistaken concerns about the costs of health and safety and the
effect of those costs on overall performance. This attitude produces a poor health
and safety culture
✓ lack of senior management involvement in health and safety, particularly at board
level
✓ employee concerns that their health and safety issues not being addressed or that
they are not receiving adequate health and safety information. This can lead to low
morale amongst the workforce and, possibly, high absenteeism
✓ high labour turnover
✓ inadequate personal protective equipment
✓ unsafe and poorly maintained machinery and equipment
✓ a lack of health and safety monitoring procedures.
In summary, a successful health and safety policy is likely to lead to a successful
organization or company.

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CHAPTER 3
3. ORGANISING FOR HEALTH AND SAFETY
3.1 Introduction
This chapter is about managers in businesses, or other organizations, setting out clear
responsibilities and lines of communications for everyone in the enterprise. Chapter 2 is
concerned with policy, which is an essential first step. The policy will only remain as words
on paper, however good the intentions, until there is an effective organization set up to
implement and monitor its requirements.
The policy sets the direction for health and safety within the enterprise and forms the
written intentions of the principals or directors of the business. The organization needs to
be clearly communicated and people need to know what they are responsible for in the
day-to-day operations. A vague statement that ‘everyone is responsible for health and
safety’ is misleading and fudges the real issues. Everyone is responsible but management
in particular.
Some policies are written so that most of the wording concerns strict requirements laid on
employees and only a few vague words cover managers’ responsibilities. Generally, such
policies cannot be said to be effective and comprehensive.

3.2 Control
Like all management functions, establishing control and maintaining it day in day out is
crucial to effective health and safety management. Managers, particularly at senior levels,
must take proactive responsibility for controlling issues that could lead to ill-health, injury
or loss. A nominated senior manager at the top of the organization needs to oversee policy
implementation and monitoring. The nominated person will need to report regularly to
the most senior management team.
The purpose of the health and safety organization is to harness the collective enthusiasm,
skills and effort of the entire workforce with managers taking key responsibility and
providing clear direction. The prevention of accidents and ill-health through management
systems of control becomes the focus rather than looking for individuals to blame after the
incident occurs.
The control arrangements should be part of the written health and safety policy.
Performance standards will need to be agreed and objectives set which link the outputs
required to specific tasks and activities for which individuals are responsible. For example,
the objective could be to carry out a workplace inspection once a week to an agreed
checklist and rectify faults within three working days. The periodic, say annual, audit would
check to see if this was being achieved and if not the reasons for non-compliance with the
objective.
People should be held accountable for achieving the agreed objectives through existing or
normal procedures such as:

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✓ job descriptions, which include health and safety responsibilities


✓ performance appraisal systems, which look at individual contributions
✓ arrangements for dealing with poor performance
✓ where justified, the use of disciplinary procedures.
Such arrangements are only effective if health and safety issues achieve the same degree
of importance as other key management concerns and a good performance is considered
to be an essential part of the career and personal development.

3.2 Employers’ responsibilities


Employers have duties under both criminal and civil law. The general duties of employers
relate to the following:
✓ the health, safety and welfare at work of employees and other workers, whether
part-time, casual, temporary, homeworkers, on work experience, that is, anyone
working under their control or direction
✓ the health and safety of anyone who visits or uses the workplace
✓ the health and safety of anyone who is allowed to use the organization’s equipment
✓ the health and safety of those affected by the work activity for example neighbours,
and the general public.

3.3 Employees’ responsibilities


Employees also have specific responsibilities relating to
✓ taking reasonable care for the health and safety of themselves and of other persons
who may be affected by their acts or omissions at work. This involves the same
wide group that the employer has to cover, not just the people on the next desk or
bench
✓ cooperating with employers in assisting them to fulfil their statutory duties
✓ not to interfere with deliberately or misuse anything provided, in accordance with
health and safety legislation, to further health and safety at work

3.4 Role and Functions of Health and Safety and other Advisers
3.4.1 Competent person
One or more competent persons must be appointed to help managers comply with their
duties under health and safety law. The essential point is that managers should have access
to expertise to help them fulfil the legal requirements. However, they will always remain
as advisers and do not assume responsibility in law for health and safety matters. This
responsibility always remains with line managers and cannot be delegated to an adviser
whether inside or outside the organization. The appointee could be:
✓ the employers themselves if they are sure they know enough about what to do.
This maybe appropriate in a small low hazard business

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✓ one or more employees, as long as they have sufficient time and other resources
to do the task properly
✓ someone from outside the organization who has sufficient expertise to help
If an employer decides to seek outside help, they have to ensure that no employees are
competent to assist. Many health and safety issues can be tackled by people with an
understanding of current best practice and an ability to judge and solve problems. Some
help is needed long term, others for a one-off short period.
There are a wide range of experts available for different types of health and safety problem.
For example:
✓ engineers for specialist ventilation or chemical processes
✓ occupational hygienists for assessment and practical advice on exposure to
chemical (dust, gases, fumes, etc.), biological (viruses, fungi, etc.) and physical
(noise, vibration, etc.) agents
✓ occupational health professionals for medical examinations and diagnosis of work-
related disease, pre-employment and sickness advice, health education, etc.
✓ ergonomists for advice on suitability of equipment, comfort, physical work
environment, work organization, etc.
✓ physiotherapists for treatment and prevention of musculoskeletal disorders, etc.
✓ health and safety practitioner for general advice on implementation of legislation,
health and safety management, risk assessment.

3.4.2 Health and safety adviser


Status and competence are essential to the role of health and safety and other advisers.
They must be able to advise management and employees or their representatives with
authority and independence. They need to be able to advise on:
✓ creating and developing health and safety policies. These will be for existing
activities plus new acquisitions or processes
✓ the promotion of a positive health and safety culture. This includes helping
managers to ensure that an effective health and safety policy is implemented
✓ health and safety planning. This will include goalsetting, deciding priorities and
establishing adequate systems and performance standards. Short- and long-term
objectives need to be realistic
✓ day-to-day implementation and monitoring of policy and plans. This will include
accident and incident investigation, reporting and analysis
✓ performance reviews and audit of the whole health and safety management system.

3.5 Contractors
3.5.1 Introduction
The use of contractors is increasing as many companies turn to outside resources to
supplement their own staff and expertise. A contractor is anyone who is brought in to work

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who is not an employee. Contractors are used for maintenance, repairs, installation,
construction, demolition, computer work, cleaning, security, health and safety and many
other tasks. Sometimes there are several contractors on site at any one time. Clients need
to think about how their work may affect each other and how they interact with the normal
site occupier.

3.5.2 Legal considerations


Health and safety regulations requires employers to ensure, so far as is reasonably
practicable, the health and safety of:
✓ their employees
✓ other people at work on their site, including contractors
✓ members of the public who may be affected by their work.
All parties to a contract have specific responsibilities under health and safety laws, and
these cannot be passed on to someone else: Therefore, principles of cooperation,
coordination and communication between organizations underpin the effective
management of Health and Safety at the workplace.

3.5.3 Safety rules for contractors


In the conditions of contract there should be a stipulation that the contractor and all of
their employees adhere to the contractor’s safety rules. Contractor’s safety rules should
contain as a minimum the following points:
✓ health & safety: that the contractor operates to at least the minimum legal standard
and conforms to accepted industry good practice
✓ supervision: that the contractor provides a good standard of supervision of their
own employees
✓ sub-contractors: that they may not use subcontractors without prior written
agreement from the Company
✓ authorization: that each employee must always carry an authorization card (ID
card) issued by the company while on site.

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CHAPTER 4
4. INTRODUCTION TO SAFETY MANAGEMENT SYSTEMS
4.1 Introduction
In recent years, there have been a great deal of research attention to understand how
industrial workplace accidents happen, particularly within the high-risk industries including
transportation, oil and gas, power, construction, manufacturing and mining. It is now
generally accepted that the causes of industrial accident are multiple and interrelated and
does not relate to only human error. Recent studies have observed that the human is only
the last link in the accident chain, and that changing people might not contribute greatly
to preventing accident. On the contrary, addressing the underlying organisational accident
causal factors could greatly improve organisational safety. These observations are
responsible for the emergence of the term “organisational accident” in the 1990, since
most of the links in an accident chain are under the control of the organisation. Since the
greatest threats to workplace safety originate in organisational issues, making the system
even safer will require action by the organisation. After conducting extensive research both
national and international workplace safety regulating bodies have concluded that the
most efficient way to make the workplace even safer will be adoption of a systems
approach to safety management, through the implementation of a safety management
system (SMS).

Whereas safety management is managing business activities and applying principles,


framework, processes to help prevent accidents, injuries and to minimise other risk, a
safety management system is a business-like approach to safety. It is a systematic, explicit
and comprehensive process for managing safety risks. As with all management systems, a
safety management system provides for goal setting, planning, and measuring
performance. A safety management system is woven into the fabric of an organization. It
becomes part of the culture, the way people do their jobs. A safety management system
will provide an organisation with the capacity to anticipate and address safety issues before
they lead to an incident or accident. A safety management system also provides
management with the ability to deal effectively with accidents and near misses so that
valuable lessons are applied to improve safety and efficiency. The safety management
system approach reduces losses and improves productivity.

Implementing safety management systems should not been seen as imposing an additional
layer of regulatory and safety oversight on an organisation/industry. Safety management
systems incorporate the basic safety process, into the management of an organisation. The
traditional safety approach depended on a safety officer (or department in a larger
organization) independent from operations management, but reporting to the Chief
Executive Officer or Chief Operating Officer of the company. The safety officer or
department had, in effect, no authority to make changes that would enhance safety. The
safety officer or department’s effectiveness depended on the ability to persuade
management to act. A safety management system on the other hand holds managers
accountable for safety related action or inaction.

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The safety management system philosophy requires that responsibility and accountability
for safety be retained within the management structure of the organisation. The directors
and senior management are ultimately responsible for safety, as they are for other aspects
of the organisation. This is the logic that underlies recent safety management system
initiatives. This approach requires an organisation to identify its ‘accountable executive’.
This is the person who has financial and executive control over an entity subject to
regulations. The safety management system approach ensures that authority and
accountability co-exist.

4.2 Historical perspective to the development of SMS


This section provides a historical perspective of what the “world before SMS” looked like.
It discusses the safety principles that prevailed and the disciplines that nurtured the
prevailing safety principles, from which SMS would eventually evolve.

4.2.1 System Safety


On May 25, 1961 President John F. Kennedy stood before the United States Congress,
and proposed that the nation should commit itself to achieving the goal of landing a man
on the Moon and returning him safely to Earth before the decade was out. This goal was
ambitious, as the technology necessary to support achievement of the goal was brittle.
From the point of view of technology design, early space exploration in 1950s had built
on the “fly-fix-fly” approach to aircraft design safety then prevalent in aviation: fly the
aircraft, fix aircraft design problems after a safety mishap occurred, and continue flying the
“fixed” aircraft until the next mishap, when the “fix-fly-fix” cycle would be reinitiated thus
engaging in a vicious circle of sorts. President Kennedy’s call allowed a grass roots
movement, incipient among the engineering community in the 1940s and which had
gained momentum during the 1950s, to become established in the aerospace industry in
the early 1960’s. The movement, system safety, was effectively a shift towards designing
and manufacturing safer technology. By applying a formal and proactive approach to
design and manufacture, a major milestone and a turning point in aerospace technology
were achieved.
System safety is an engineering discipline, with the objective of making technical systems
safe by “designing” safety into the technical system during its development: safety is
essentially built into the system to cover the entire system life cycle, including
manufacturing, testing, operations and maintenance. System safety’s credo can be
summarised in three words: safety by design.
The contribution of system safety to the aerospace industry development has been nothing
short of phenomenal. System safety was a major contributor to the realisation of President
Kennedy’s dream of landing humans in the Moon. More relevant to this historical
perspective, system safety became aviation’s safety textbook for the ensuing 30 years, and

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the significant progress in technology accomplished by aviation between the 1960s and
the 1980s was in no small degree due to the contribution of system safety.
System safety did not remain within aviation, and travelled across transportation inter-
modal and inter-industry boundaries, becoming the safety framework for several industries
to the present day. A point of historical perspective relevant to upcoming discussions on
the development of SMS is that the notions of hazard, risk and mishap are a legacy
(perhaps the legacy) of system safety.
System safety proposes a four-step architecture of intervention, based on hierarchical
precedence:

• Design for minimum risk: eliminate the safety concern (the hazard) through design
• If unable, incorporate safety devices: include design that automatically prevents the
safety concern from becoming a mishap.
• If unable, provide warning devices: include devices that alert personnel to the safety
concern in time to take remedial action, and
• If unable, develop procedures and training: provide instructions so that personnel
will use information available to control the safety concern

The first conclusion to draw from this historical perspective is two-fold. Firstly, as an
engineering discipline, system safety was conceived for application to, and improvement
of, technical systems (an aircraft, a ship, an engine, etc.) exclusively. Secondly, within the
strong engineering notion integral to the fabric of system safety, the human operator is
considered a liability to safety, due to the potential for human mishandling or
mismanagement of technology (human error) during actual operations. This is evident in
the hierarchical precedence of the four steps of intervention outlined in the previous
paragraph.

4.2.2 Human Factors


Towards the end of the 1970s, a perception of diminishing returns regarding safety
through design, and system safety’s contribution to further safety improvement, had
established within the aviation industry, and concern about human error in aviation
operations was gaining headlines. Human Factors (with caps), a multi-disciplinary field of
endeavour that had its origins – evolving from ergonomics – after World War II, and that
had so far experienced a lukewarm reception in aviation, became a centrepiece of aviation
safety during the 1980s, the 1990’s and well into the first years to the 21st Century. Like
system safety, Human Factors also travelled across transportation inter-industry
boundaries, and was adopted by other transportation industries, albeit not so quickly,
enthusiastically and broadly as in aviation.
Human Factors is a field of endeavour concerned with optimising the relationship between
people and the operational environment by the systematic integration of human sciences
and systems engineering. It is a scientific approach that deals with what people do in
operational contexts, and aims at optimising operational human performance during

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transportation service delivery activities, thus contributing to the safety and efficiency of
transportation operations.
Four scientific disciplines converge into the core of Human Factors: ergonomics (human-
centred design of displays and controls), systems engineering (integration of system
components, with operators’ requirements as foremost consideration, to generate an
homogeneous and functional entity), physiology (fatigue, stress, noise, temperature,
pressure, vibration and similar human performance related considerations that may affect
transportation operations), and psychology, which branches out into social, organisational
and cognitive psychology.
The second conclusion to draw from this historical perspective is also two-fold. First, as
multidisciplinary field of endeavour, Human Factors was conceived for application to, and
improvement of, socio-technical systems (systems encompassing people and technology,
in which people must actively interact with technology to achieve the system production
goals). Second, within the multi-disciplinary notion of Human Factors, and in particular
under the auspices of organisational and cognitive psychology, the human operator is
considered an asset to safety, due to the ability of humans to “think on their feet” and
provide response to safety deficiencies and operational situations unforeseen by design
and planning. Closely linked to this consideration, human error, which had long been
maligned as “cause” of safety breakdowns and had therefore been the stop point of the
safety investigation, is considered a symptom of deficiencies deep in the architecture of
the system rather than a cause, and is the starting point of the safety investigation. Under
Human Factors, operational error is considered much in the same way as the medical
science considers fever: an indication of problem(s), but never the problem(s) itself.

4.2 3 Business management


A federal law of the United States provides the third and last milestone in this historical
perspective: the Aviation Deregulation Act of 1978, signed by President Jimmy Carter,
which introduced the notion of free market into commercial aviation. Deregulation has
been praised and demonised in similar proportions and with equal fervour and conviction
among different quarters. Whatever the case may be, the historical fact remains that
deregulation is the reason why business management practices were introduced into
aviation safety: organisations that throughout their history had been subsidised by
governments, directly or indirectly, had now “to earn their place under the sun”.
The integration of business management practices into aviation safety forced the safety
community into soul-searching and re-evaluation of long-established safety dogma. So
far, the paradigmatic safety goalpost in aviation (and in all transportation industries) had
been the absence of low frequency, high-severity events: safety was viewed as freedom
from accidents (or freedom from harm). Under the influx of business management
thinking, the safety community began prospecting higher frequency, lower severity events
in search of alternative safety goalposts. Most important, business management led the

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safety community to explore ways to give sense to the safety dollar: was safety truly the
first priority of the organisation, or must the safety return be worth the safety investment?
The third and last conclusion to draw from this historical perspective is also two-fold. First,
the notion that “you cannot manage what you cannot measure” led to the development
of multiple sources of organisation-specific data acquisition during operations. So far, the
limited data points provided by accident investigation (and eventually serious incident
investigation) as sole sources of safety data had generated valuable information for
accident prevention, but did not generate data in volume enough for safety management.
This forced, in the early days of business management, data aggregation (in many cases
at regional and even worldwide level) to obtain data volume, thus removing specificity
and therefore relevance of the data to a single organisation. Second, the fact that data
acquisition must not be random, and that safety data collection must be performed by
reference to defined parameters, which led to the development safety performance
indicators and safety performance targets.
In summary and conclusion, “before SMS”, the safety world of most industries had
progressed along parallel tracks, under the piecemeal guidance provided by three defined
but unmerged interventions: system safety, Human Factors, and business management.
At the dawn of the 21st Century, the three parallel tracks began converging towards an
intersection or point of confluence, and the challenge ahead for industries became the
coordinated integration of the three interventions into a coherent, intact whole. The result
of this integration would be a new discipline named safety management, and the vehicle
for the operationalisation of safety management would be SMS.

4.3 Truth and Misconceptions – What an SMS is and is not


Managing safety is really about managing safety risk, which means trying to prevent bad
things from happening, or if something does go wrong, or slips through the cracks, trying
to minimise the consequences of the event. Safety management is about accepting that
things will go wrong and about reactively, proactively and predictively controlling risks to
a level that is acceptable. It can help you predict potential risks, take appropriate action
and measure how well risk controls are working. It can give you the business information
you would want to manage risks in other areas such as finance or productivity.

SMS implementation will change the way an organisation operates. That is, the main
game will still be operating the business; but SMS provides an underpinning structure
which enables organisations to manage risks in their operation and, when implemented
effectively, improve the effectiveness of the operations. Safety management systems are
not Quality Management Systems (QMS), although they do share many of the same
features and capabilities such as performance targets, reporting, governance and
performance monitoring. The objective of a QMS is the control of processes to achieve
predictable and desirable results that meet with the customer’s and organisation’s
requirements. Whereas the objective of an SMS is to monitor and control operational risks
to improve safety performance.

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If an organisation has a functioning QMS, then its staff will already be familiar with
reporting and feedback and, most importantly, they’ll already be on their way to an
effective reporting and safety culture - which is vital to the implementation and
sustainability of your SMS. Finally, SMS is not a manual, a database, or a reporting
process; these are all tools. It is how safety is managed day to day and becomes part the
organisation’s culture. It penetrates into the organisation’s processes and activities and it
shapes critical management thinking. It is a vital management tool where the staff are the
eyes and ears, the safety group is the heart and management is the decision-making ‘brain’
of the system.

4.4 Why a Safety Management System


For all workers and organisations, safety should be an expressed value. Recent research
indicates that organisations committed to safety excellence achieve success through a
strong SMS. Many benefits are associated with the development and implementation of
an SMS. One of the most important benefit is that, an effective SMS can help prevent
injuries and property loss, reduce costs, and support due diligence. Developing a proactive
approach to safety through an SMS and its essential elements results in long-term financial
and cultural benefits. Generally, organisations adopt an SMS due to three main
imperatives, that is, ethical, legal and financial.
There is an implied moral obligation placed on organisations/employers to ensure that
work activities and the place of work to be safe, there are legislative requirements defined
in just about every jurisdiction on how this is to be achieved and there is a extensive body
of research which demonstrates that effective safety management (which is often
determined through lagging indicators such as the reduction of risk in the workplace) can
reduce the financial exposure of an organisation by reducing direct and indirect costs
associated with accident and incidents.

4.4.1 Moral Obligation


Employers have a moral obligation to keep their employees safe from harm, for the sake
of the employees and their families, as well as for the sake of the continued success of the
organization. After all, organisations rely on people to keep their operations going.
Therefore, organisaions have a moral duty to keep the workplace safe for the employees.
If the workplace is safe and the workers are feeling safe they will love to come to work and
it will be a safer and happy place to work. This will in turn not only create an environment
where everyone wants to come but will also increase the productivity of the workers.

4.4.2 Legal/Regulatory Compliance


National and international occupational health and safety laws require organisations and
employers to provide safe workplaces for their employees and other workers.7
Additionally, implementing and executing an effective SMS assists with meeting this

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obligation as well as standards of “due diligence” - a legal phrase referring to a person’s


duty to take reasonably practicable actions to protect the well-being of others.8 Not being
aware of one’s legal responsibilities and duties is not a defence for non-compliance.9 For
an employer, having an effective, functioning SMS can form the basis for a due diligence
defence when an incident results in loss or harm. A company and its workers can
demonstrate their commitment to health and safety through an effective SMS.

4.4.3 Cost Reduction


An effective SMS can prevent loss and costs from incidents that lead to injuries, illnesses,
or death. Workers’ compensation costs can be significant, along with the other costs
directly and indirectly related to and incurred when an injury or illness occurs. These costs
add directly to operation costs and, in turn, profits.10 As well, a successfully implemented
SMS can prevent loss to property and production, losses from violations of legislation or
regulations, lawsuits and fines. In addition to the monies saved from fewer incidents, an
efficient SMS leads to additional savings from increased productivity by improving
workers’ skills, work practices, and consistency in carrying out critical tasks.

4.4.4 Employee Relations


Commitment to an SMS demonstrates management concern for ensuring safe operations
and thus helps build better employee relations, retain the best employees, and increase
the contributions of these workers in achieving business goals. Ensuring that all workers
return home in the condition in which they came to work, if not better, justifies the
commitment and dedication of resources to an SMS.
Primarily, an organisation’s SMS gives it control over its safety risks. In high risk industries,
including aviation, oil and gas and mining, management of safety risk is a core activity.
Like financial management, senior managers need to control how safety risks are
managed. Many countries have regulations which put senior management in charge of
the safety of their organisation and hold them directly accountable for poor safety
performance. The best organisations however have SMS in place without any requirement
from their authority - because it makes sense and it works.
Profits are made by taking risks. Senior managers are responsible to the shareholders and
other stakeholders to ensure the business is profitable. Senior managers are always risk
managers, but some managers don’t realise that risk management is what they do. Risks
should only be taken if the assessed level of the risk is acceptable and defensible. SMS
provides a framework which supports organisations with their management of risk.
Without a framework, how can an organisation assures itself, and its stakeholders, that the
risks taken are acceptable? How do they know – objectively -when to ‘go’ or ‘not go’?
And how would they defend their operational risk decisions without such a framework?
An effective safety management system provides many other potential benefits, including:

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• The ability to control the potential risky operations faced by the organisation
• A clear and documented approach to achieving safe operations that can be
explained to others
• Active involvement of staff in safety
• Demonstrable control for the authority, customers and other stakeholders that an
organisation’s risks are under control
• Building a positive safety culture
• Reduction or removal of operational inefficiencies
• Decreased insurance costs and improved reputation
• A common language to establish safety objectives and targets and implement and
monitor safety risk controls

4.5 Building a Safety Management System


Management initiatives are not always successful and each time a new idea is introduced
people must ask whether this is a worthwhile initiative, or a fad that will pass soon enough.
Having a good idea does not guarantee success. Many good ideas have failed in practice
because one or more of the three critical elements was missing: commitment, cognisance,
and competence. This by extension means, implementing an SMS in an organisation will
not by itself ensure improvement in organisational safety, unless there is demonstrated
commitment, cognisance and competence to actualizing what has been stipulated in the
SMS. The 3 “C’s” of leadership will determine, in large part, whether safety management
achieves its goals and leads to a pervasive safety culture in an organisation:

• Commitment: In the face of operational and commercial pressures do company


leaders have the will to make safety management tools work effectively?
• Cognisance: Do the leaders understand the nature and principles of managing for
safety?
• Competence: Are safety management policy and procedures appropriate,
understood, and properly applied at all levels in the organisation?

4.6 Components of a Safety Management System


Although several frameworks/models for SMS exist (such as the ILO SMS model), the
universally accepted framework for SMS includes four main components and twelve
elements, as the minimum requirements for an SMS. These minimal requirements of an
SMS have been listed below:
1. Safety policy and objectives
a. Management commitment and responsibility
b. Safety accountabilities
c. Appointment of key safety personnel
d. Coordination of emergency response planning
e. SMS documentation
2. Safety risk management
a. Hazard identification
b. Risk assessment and mitigation

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3. Safety assurance
a. Safety performance monitoring and measurement
b. The management of change
c. Continuous improvement of the SMS
4. Safety promotion
a. Training and education
b. Safety communication
The four main component of an SMS are interrelated and their interrelationships have
been exemplified in Figure 1.1 below and discussed in details in the ensuing subsections.

Figure 4.1 Interrelationships among the four major components of an SMS

4.6.1 Safety Policy and Objectives


The Safety Management Policy is the written foundation of an organisation’s safety
management system. It formally and explicitly commits an organisation to the
development and implementation of the organisational structures and resources necessary
to sustain the safety management processes and activities of an SMS. An effective Safety
Management Policy establishes that an organisation’s top executive is ultimately
accountable for safety management.
The Safety Management Policy component encompasses an agency’s safety objectives
and safety performance targets, and the necessary organizational structures to accomplish
them. It establishes senior leadership and employee accountabilities and responsibilities
for safety management throughout an agency. It also commits senior leadership to the
oversight of an agency’s safety performance through meetings and regular reviews of
activity outputs and discussions of resource allocation with key agency stakeholders. The
Safety Management Policy is implemented in practice though the Safety Management
Policy Statement, which the Accountable Executive formally endorses.

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4.6.2 Safety Risk Management


The Safety Risk Management component is comprised of the processes, activities, and
tools an organisation needs to identify and analyse hazards and evaluate safety risks in
operations and supporting activities. It allows an organisation to carefully examine what
could cause harm, and determine whether sufficient measures have been taken to prevent
the harm, or to mitigate it effects to the barest minimum should the harm occur. Under an
SMS, risk management activities and practices include the use of both proactive (i.e.
employee safety reporting) and reactive (i.e. investigations) sources that are as
comprehensive as necessary for the size and complexity of the organisation. The scope of
the course focuses on the proactive approach, whereas the accident investigation course
deals with the reactive approach to risk management. Through ongoing Safety Risk
Management activities, safety hazards and concerns in organisations are identified,
evaluated, and mitigations are put in place to manage their safety risk.

4.6.3 Safety Assurance


The Safety Assurance component ensures that mitigations are implemented, adhered to,
appropriate, effective and sufficient in addressing the potential consequences of identified
hazards. Mitigations developed under the Safety Risk Management process are “handed-
off” to Safety Assurance analysts reviewing the data to determine if (1) the mitigations are
effective, and (2) that no new risks have been introduced through implementation of the
mitigations. Safety Assurance also ensures that the SMS is effective in meeting an
organisation’s safety objectives and safety performance targets. An organisation assures
its safety objectives are met through the collection and analysis of safety data, including
the tracking of safety risk mitigations. An organisation implements its Safety Assurance
process through the active monitoring of operations, safety reporting systems, routine
workplace observations, inspections, audits, and other activities, designed to support
safety oversight and performance monitoring. An effective employee safety reporting
program is essential to the Safety Assurance function. Safety Assurance also helps an
organisation evaluate whether an anticipated change may affect the safety of operations.
If an anticipated change is determined to introduce safety risk, the organisation would
have to conduct Safety Risk Management activities to minimise the safety risk associated
with the change.

4.6.4 Safety Promotion


Safety Promotion provides visibility of executive management’s commitment to safety,
and fosters improved safety performance by increasing safety awareness through safety
communication and training. Through communication of lessons learned and broader
safety information, employees are made aware of safety priorities and safety concerns at
both the organisational level and as they relate to their own duties and responsibilities.
The appropriate training for all staff, regardless of their level in the agency, provides
visibility for, and knowledge of, the SMS. It ensures employees receive the training they

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need to do their job safely, and gives them shared ownership of organisation’s safety
mission. This training commitment demonstrates management’s commitment to
establishing an effective SMS.

4.7 Practical Implementation of SMS


The Airports Council International (ACI) Safety Management System Handbook is highly
recommended to understand the practical implementation of an SMS. This handbook has
been uploaded as part of the teaching materials shared on the Virtual Learning platform.

Reading Assignment
Airports Council International (ACI) (2016) “Safety Management System Handbook”.
First Edition.
ISO 45001:2018 – Occupational Health and Safety Management Systems – Requirements
with guidance for use
OHSAS 18001:2017 - Occupational Health and Safety Management Systems –
Requirements

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CHAPTER 5
5. HAZARDS AT THE WORKPLACE AND THEIR CONTROLS

5.1 Introduction
The International Board for Certification of Safety Managers (IBFCSM) defines a hazard
as “any solid, gas, or liquid with the potential to cause harm when interacting with an
array of initiating stimuli including human-related factors.” The scope of a hazard can
include any activity, behaviour, error, event, incident, occurrence, operation, process,
situation, substance, or task with potential to cause human harm, property damage, risk
to the environment, or a combination of all three. The board defines hazard closing as the
process of two or more hazards or causal factors attempting to occupy the same space at
the same time. Some hazard control professionals refer to this interaction of causal factors
as the accident generation cycle. This chapter focuses on some common workplace
hazards and how they can be managed.

5.2 Movement of People and Vehicle Hazards and Control


5.2.1 Introduction
People are most often involved in accidents as they walk around the workplace or when
they come into contact with vehicles in or around the workplace. It is therefore important
to understand the various common accident causes and the control strategies that can be
employed to reduce them. Slips, trips and falls account for the majority of accidents to
pedestrians and the more serious accidents between pedestrians and vehicles can often be
traced back to excessive speed or other unsafe vehicle practices, such as lack of driver
training. Many of the risks associated with these hazards can be significantly reduced by
an effective management system.

5.2.2 Hazards to pedestrians


The most common hazards to pedestrians at work are slips, trips and falls on the same
level, falls from height, collisions with moving vehicles, being struck by moving, falling or
flying objects and striking against fixed or stationary objects. Each of these will be
considered in turn, including the conditions and environment in which the particular
hazard may arise.

Slips, trips and falls on the same level


These are the most common of the hazards facing pedestrians and accounted for 30%
each year of all the major accidents and 20% of over three-day injuries globally. It has
been estimated that the annual cost of these accidents in the UK is £750 m and a direct
cost to employers of £300 m.

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Slip hazards are caused by:


✓ wet or dusty floors
✓ the spillage of wet or dry substances – oil, water, flour dust and plastic pellets used
in plastic manufacture
✓ loose mats on slippery floors
✓ unsuitable footwear or floor coverings or sloping floors.
Trip hazards are caused by:
✓ loose floorboards or carpets
✓ obstructions, low walls, low fixtures on the floor
✓ cables or trailing leads across walkways or uneven surfaces. Leads to portable
electrical hand tools and other electrical appliances (vacuum cleaners and
overhead projectors). Raised telephone and electrical sockets are also a serious trip
✓ rugs and mats – particularly when worn or placed on a polished surface
✓ poor housekeeping – obstacles left on walkways, rubbish not removed regularly
✓ poor lighting levels – particularly near steps or other changes in level
✓ sloping or uneven floors – particularly where there is poor lighting or no handrails
✓ unsuitable footwear – shoes with a slippery sole or lack of ankle support.
The vast majority of major accidents involving slips, trips and falls on the same level result
in dislocated or fractured bones.
Fall from work at height
These are the most common cause of serious injury or death in the construction industry.
These accidents are often concerned with falls of greater than about 2 m and often result
in fractured bones, serious head injuries, loss of consciousness and death. Twenty-five per
cent of all deaths at work and 19% of all major accidents are due to falls from a height.
Falls down staircases and stairways, through fragile surfaces, off landings and stepladders
and from vehicles, all come into this category. Injury, sometimes serious, can also result
from falls below 2 m, for example, using swivel chairs for access to high shelves.
Collisions with moving vehicles
These can occur within the workplace premises or on the access roads around the building.
It is a particular problem where there is no separation between pedestrians and vehicles
or where vehicles are speeding. Poor lighting, blind corners, the lack of warning signs and
barriers at road crossing points also increase the risk of this type of accident. Eighteen per
cent of fatalities at work are caused by collisions between pedestrians and moving vehicles
with the greatest number occurring in the service sector (primarily in retail and warehouse
activities).
Being struck by moving, falling or flying objects
This causes 18% of fatalities at work and is the second highest cause of fatality in the
construction industry. It also causes 15% of all major and 14% of over three-day accidents.
Moving objects include, articles being moved, moving parts of machinery or conveyor belt
systems, and flying objects are often generated by the disintegration of a moving part or a
failure of a system under pressure. Falling objects are a major problem in construction

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(due to careless working at height) and in warehouse work (due to careless stacking of
pallets on racking). The head is particularly vulnerable to these hazards. Items falling off
high shelves and moving loads are also significant hazards in many sectors of industry.
Striking against fixed or stationary objects
This accounts for between 1200 and 1400 major accidents each year in the UK. Injuries
are caused to a person either by colliding with a fixed part of the building structure, work
in progress, a machine member or a stationary vehicle or by falling against such objects.
The head
appears to be the most vulnerable part of the body to this particular hazard and this is
invariably caused by the misjudgement of the height of an obstacle. Concussion in a mild
form is the most common outcome and a medical check-up is normally recommended. It
is a very common injury during maintenance operations when there is, perhaps, less
familiarity with particular space restrictions around a machine. Effective solutions to all
these hazards need not be expensive, time consuming or complicated. Employee
awareness and common sense combined with a good housekeeping regime will solve
many of the problems.

5.2.3 Control Strategies for Pedestrian Hazards


Slips, trips and falls on the same level
These may be prevented or, at least, reduced by several control strategies. These and all
the other pedestrian hazards discussed should be included in the workplace risk
assessments by identifying slip or trip hazards, such as poor or uneven floor/pavement
surfaces, badly lit stairways and puddles from leaking roofs. Traffic routes must be so
organized that people can move around the workplace safely.
The key elements of a health and safety management system are as relevant to these as
to any other hazards
✓ planning – remove or minimize the risks by using appropriate control measures and
defined working practices (e.g. covering all trailing leads)
✓ organization – involve employees and supervisors in the planning process by
defining responsibility for keeping given areas tidy and free from trip hazards
✓ control – record all cleaning and maintenance work. Ensure that anti-slip covers
and cappings are placed on stairs, ladders, catwalks, kitchen floors and smooth
walkways. Use warning signs when floor surfaces have recently been washed
✓ monitoring and review – carry out regular safety audits of cleaning and
housekeeping procedures and include trip hazards in safety surveys. Check on
accident records to see whether there has been an improvement or if an accident
black spot may be identified.
Slip and trip accidents are a major problem for large retail stores both for customers
and employees. The provision of non-slip flooring, a good standard of lighting and
minimizing the need to block aisles during the re-stocking of merchandise are typical
measures that many stores use to reduce such accidents. Other measures include the

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wearing of suitable footwear by employees, adequate handrails on stairways, the


highlighting of any floor level changes and procedures to ensure a quick and effective
response to any reports of floor damage or spillages. Good housekeeping procedures
are essential. The design of the store layout and any associated warehouse can also
ensure a reduction in all types of accidents. Many of these measures are valid for a
range of workplaces.
Falls from work at height
These may be controlled by the use of suitable guardrails and barriers and also by the
application of the hierarchy of controls, which is:
✓ remove the possibility of falling a distance that could cause personal injury (e.g.
by undertaking the work at ground level)
✓ protect against the hazard of falling a distance that could cause personal injury
(e.g. by using handrails)
✓ stop the person from falling a distance that could cause personal injury (e.g. by
the provision of safety harnesses)
✓ mitigate the consequences of falling a distance that could cause personal injury
(e.g. by the use of air bags).
The principal means of preventing falls of people or materials includes the use of fencing,
guardrails, toe boards, working platforms, access boards and ladder hoops. Safety nets
and safety harnesses should only be used when all other possibilities are not practical. The
use of banisters on open sides of stairways and handrails fitted on adjacent walls will also
help to prevent people from falling. Holes in floors and pits should always be fenced or
adequately covered.
Collisions with moving vehicles
These are best prevented by completely separating pedestrians and vehicles, providing
well marked, protected and laid out pedestrian walkways. People should crossroads by
designated and clearly marked pedestrian crossings. Suitable guardrails and barriers
should be erected at entrances and exits from buildings and at ‘blind’ corners at the end
of racking in warehouses. Particular care must be taken in areas where lorries are being
loaded or unloaded. It is important that separate doorways are provided for pedestrians
and vehicles and all such doorways should be provided with a vision panel and an
indication of the safe clearance height, if used by vehicles. Finally, the enforcement of a
sensible speed limit, coupled where practicable, with speed governing devices, is another
effective control measure.
Being struck by moving, falling or flying objects
These may be prevented by guarding or fencing the moving part. Both workers and
members of the public need to be protected from the hazards associated with falling
objects. Both groups should be protected by the use of covered walkways or suitable
netting to catch falling debris where this is a significant hazard. Waste material should be
brought to ground level by the use of chutes or hoists. Waste should not be thrown from
a height and only minimal quantities of building materials should be stored on working

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platforms. Appropriate personal protective equipment, such as hard hats or safety glasses,
should be worn at all times when construction operations are taking place.
Striking against fixed or stationary objects
This can be effectively controlled by:
✓ having good standards of lighting and housekeeping
✓ defining walkways and making sure they are used
✓ the use of awareness measures, such as training and information in the form of
signs or distinctive colouring
✓ the use of appropriate personal protective equipment, in some cases, as discussed
previously.

5.2.4 Hazards in vehicle operations


Many kinds of vehicle are used in the workplace, including dumper trucks, heavy goods
vehicles, all-terrain vehicles and, fork-lift truck, among others. Research has indicated that
vehicle accidents in the workplace is major cause of death. There are also over 1000 major
accidents (involving serious fractures, head injuries and amputations) caused by:
✓ collisions between pedestrians and vehicles
✓ people falling from vehicles
✓ people being struck by objects falling from vehicles
✓ people being struck by an overturning vehicle
✓ communication problems between vehicle drivers and employees or members of
the public.
A key cause of these accidents is the lack of competent and documented driver training.
In the UK, analysis of accident data from the construction industry, for example, have
shown that in over 30% of dump truck accidents on construction sites, the drivers had little
experience and no training. Common forms of these accidents include driving into
excavations, overturning while driving up steep inclines and runaway vehicles which have
been left unattended with the engine running.
Risks of injuries to employees and members of the public involving vehicles remains
important due to the following risk factors
✓ collision with pedestrians
✓ collision with other vehicles
✓ overloading of vehicles
✓ overturning of vehicles
✓ general vehicle movements and parking
✓ dangerous occurrences or other emergency incidents (including fi re)
✓ access and egress from the buildings and the site.
There are several other more general hazardous situations involving pedestrians and
vehicles. These include the following:

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✓ reversing of vehicles, especially inside buildings


✓ poor road surfaces and/or poorly drained road surfaces
✓ roadways too narrow with insufficient safe parking areas
✓ roadways poorly marked out and inappropriate or unfamiliar signs used
✓ too few pedestrian crossing points
✓ the non-separation of pedestrians and vehicles
✓ lack of barriers along roadways
✓ lack of directional and other signs
✓ poor environmental factors, such as lighting, dust and noise
✓ ill-defined speed limits and/or speed limits which are not enforced
✓ poor or no regular maintenance checks
✓ vehicles used by untrained and/or unauthorized personnel
✓ poor training or lack of refresher training.
Vehicle operations need to be carefully planned so that the possibility of accidents is
minimized.

5.2.5 Control strategies for safe vehicle operations


Any control strategy involving vehicle operations will involve a risk assessment to ascertain
where, on traffic routes, accidents are most likely to happen. It is important that the risk
assessment examines both internal and external traffic routes, particularly when goods are
loaded and unloaded from lorries. It should also assess whether designated traffic routes
are suitable for the purpose and sufficient for the volume of traffic.The following needs to
be addressed:
✓ traffic routes, loading and storage areas need to be well designed with enforced
speed limits, good visibility and the separation of vehicles and pedestrians
whenever reasonably practicable
✓ environmental considerations, such as visibility, road surface conditions, road
gradients and changes in road level, must also be taken into account
✓ the use of one-way systems and separate site access gates for vehicles and
pedestrians may be required
✓ the safety of members of the public must be considered, particularly where
vehicles cross public footpaths
✓ induction training for all new employees must include the location and
designation of pedestrian walkways and crossings and the location of areas
workplace where pedestrians and earth moving equipment use the same
roadways
✓ the identification of recognized and prohibited parking areas around the site
should also be given during these training sessions.

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5.2.6 The management of vehicle movements


The movement of vehicles must be properly managed, as must vehicle maintenance and
driver training. The development of an agreed code of practice for drivers, to which all
drivers should sign up, and the enforcement of site rules covering all vehicular
movements are essential
for effective vehicle management.
All vehicles should be subject to appropriate regular preventative maintenance
programmes with appropriate records kept and all vehicle maintenance procedures
properly documented. Consideration must be given to driver protection by fitting driver
restraint (seat belts), falling object protective structures (FOPS) and roll-over or tip-
overprotective structures known as ROPS.
Vehicles should be fitted with reversing warning systems as well as being able to give
warning
of approach. Refuges, where pedestrians can stand to avoid reversing vehicles are a
useful safety measure.
5.3 Manual and mechanical hazards and control
5.3.1 Manual handling hazards and injuries
The term ‘manual handling’ is defined as the movement of a load by human effort alone.
This effort may be applied directly or indirectly using a rope or a lever. Manual handling
may involve the transportation of the load or the direct support of the load including
pushing, pulling, carrying, moving using bodily force and, of course, straightforward lifting.
Back injuries due to the lifting of heavy loads is very common and several million working
days are lost each year as a result of such injuries. Typical hazards of manual handling
include (see Figure 5.1):
✓ lifting a load which is too heavy or too cumbersome resulting in back injury
✓ poor posture during lifting or poor lifting technique resulting in back injury
✓ dropping a load, resulting in foot injury
✓ lifting sharp-edged or hot loads resulting in hand injuries.

Figure 5.1 Manual handling – there are many potential

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Injuries caused by manual handling


Manual handling operations can cause a wide range of acute and chronic injuries to
workers. Acute injuries normally lead to sickness leave from work and a period of rest
during which time the damage heals. Chronic injuries build up over a long period of time
and are usually irreversible producing illnesses such as arthritic and spinal disorders. There
is considerable evidence to suggest that modern lifestyles, such as a lack of exercise and
regular physical effort, have contributed to the long-term serious effects of these injuries.
The most common injuries associated with poor manual handling techniques are all
musculoskeletal in nature and are:
✓ muscular sprains and strains – caused when a muscular tissue (or ligament or
tendon) is stretched beyond its normal capability leading to a weakening, bruising
and painful inflammation of the area affected. Such injuries normally occur in the
back or in the arms and wrists
✓ back injuries – include injuries to the discs situated between the spinal vertebrae
(i.e. bones) and can lead to a very painful prolapsed disc lesion (commonly known
as a slipped disc). This type of injury can lead to other conditions known as
lumbago and sciatica (where pain travels down the leg)
✓ trapped nerve – usually occurring in the back as a result of another injury but
aggravated by manual handling
✓ hernia – this is a rupture of the body cavity wall in the lower abdomen causing a
protrusion of part of the intestine. This condition eventually requires surgery to
repair the damage
✓ cuts, bruising and abrasions – caused by handling loads with unprotected sharp
corners or edges
✓ fractures – normally of the feet due to the dropping of a load. Fractures of the hand
also occur but are less common
✓ work-related upper limb disorders (WRULDs) – cover a wide range of
musculoskeletal disorders
✓ rheumatism – this is a chronic disorder involving severe pain in the joints. It has
many causes, one of which is believed to be the muscular strains induced by poor
manual handling lifting technique.
The sites on the body of injuries caused by manual handling accidents are shown in Figure
5.2. In general, pulling a load is much easier for the body than pushing one. If a load can
only be pushed, then pushing backwards using the back is less stressful on body muscles.
Lifting a load from a surface at waist level is easier than lifting from floor level and most
injuries during lifting are caused by lifting and twisting at the same time. If a load must be
carried, it is easier to carry it at waist level and close to the body trunk. A firm grip is
essential when moving any type of load.

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Figure 5.2 Main injury sites caused by manual handling

5.3.2 Manual handling assessments


An assessment ought to be carried out before commencing any manual handling
operation and the assessment should consider four main factors, namely, the task, the
load, the working environment and the capability of the individual who is expected to do
the lifting.
The task
The task should be analysed in detail so that all aspects of manual handling are covered
including the use of mechanical assistance. The number of people involved and the cost
of the task should also be considered. Some or all of the following questions are relevant
to most manual handling tasks:
✓ is the load held or manipulated at a distance from the trunk? The further from the
trunk, the more difficult it is to control the load and the stress imposed on the back
is greater
✓ is a satisfactory body posture being adopted? Feet should be firmly on the ground
and slightly apart and there should be no stooping or twisting of the trunk. It should
not be necessary to reach upwards since this will place additional stresses on the
arms, back and shoulders. The effect of these risk factors is significantly increased
if several are present while the task is being performed
✓ are there excessive distances to carry or lift the load? Over distances greater than
10 m, the physical demands of carrying the load will dominate the operation. The
frequency of lifting, and the vertical and horizontal distances the load needs to be
carried (particularly if it has to be lifted from the ground and/or placed on a high
shelf) are very important considerations

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✓ is there excessive pulling and pushing of the load? The state of floor surfaces and
the footwear of the individual should be noted so that slips and trips may be
avoided
✓ is there a risk of a sudden movement of the load? The load may be restricted or
jammed in some way
✓ is frequent or prolonged physical effort required? Frequent and prolonged tasks
can lead to fatigue and a greater risk of injury
✓ are there sufficient rest or recovery periods? Breaks and/or the changing of tasks
enables the body to recover more easily from strenuous activity
✓ is there an imposed rate of work on the task? This is a particular problem with some
automated production lines and can be addressed by spells on other operations
away from the line
✓ are the loads being handled while the individual is seated? In these cases, the legs
are not used during the lifting processes and stress is placed on the arms and back
✓ does the handling involve two or more people? The handling capability of an
individual reduces when he becomes a member of a team (e.g. for a three-person
team, the capability is half the sum of the individual capabilities). Visibility,
obstructions and the roughness of the ground must all be considered when team
handling takes place.
The load
The load must be carefully considered during the assessment and the following questions
asked:
✓ is the load too heavy? The maximum load that an individual can lift will depend
on the capability of the individual and the position of the load relative to the body.
There is therefore no safe load, but Figure 5.3 is reproduced from the HSE
guidance, which does give some advice on loading levels. It does not recommend
that loads in excess of 25 kg should be lifted or carried by a man (and this is only
permissible when the load is at the level of and adjacent to the thighs). For women,
the guideline figures should be reduced by about one third
✓ is the load too bulky or unwieldy? In general, if any dimension of the load exceeds
0.75 m (2 ft), its handling is likely to pose a risk of injury. Visibility around the load
is important. It may hit obstructions or become unstable in windy conditions. The
position of the centre of gravity is very important for stable lifting – it should be as
close to the body as possible
✓ is the load difficult to grasp? Grip difficulties will be caused by slippery surfaces,
rounded corners or a lack of foot room are the contents of the load likely to shift?
This is a particular problem when the load is a container full of smaller items, such
as a sack full of nuts and bolts. The movement of people (in a nursing home) or
animals (in a veterinary surgery) are loads which fall into this category
✓ is the load sharp, hot or cold? Personal protective equipment may be required

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The working environment


The working environment in which the manual handling operation is to take place, must
be considered during the assessment. The following areas will need to be assessed:
✓ any space constraints which might inhibit good posture. Such constraints include
lack of headroom, narrow walkways and items of furniture
✓ slippery, uneven or unstable floors
✓ variations in levels of floors or work surfaces, possibly requiring the use of ladders
✓ extremes of temperature and humidity. These effects are discussed in detail in
Chapter 15
✓ ventilation problems or gusts of wind
✓ poor lighting conditions.
The capacity individual to lift or carry the load
Finally, the capability of the individual to lift or carry the load must be assessed. The
following questions will need to be asked:
✓ does the task require unusual characteristics of the individual (e.g. strength or
height)? It is important to remember that the strength and general manual handling
ability depends on age, gender, state of health and fitness
✓ are employees who might reasonably be considered to be pregnant or to have a
health problem, put at risk by the task? Particular care should be taken to protect
pregnant women or those who have recently given birth from handling loads.
Allowance should also be given to any employee who has a health problem, which
could be exacerbated by manual handling.
The assessment must be reviewed if there is reason to suspect that it is no longer valid or
there has been a significant change to the manual handling operations to which it relates.

Figure 5.3 HSE guidance for manual lifting – recommended weights

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5.3.4 Reducing the risk of injury


This involves the introduction of control measures resulting from the manual handling risk
assessment. Control measures can be grouped into and these will be discussed briefly
according to their hierarchy of importance and effectiveness.
Mechanical assistance involves the use of mechanical aids to assist the manual handling
operation such as hand-powered hydraulic hoists, specially adapted trolleys, hoists for
lifting patients and roller conveyors.
The task can be improved by changing the layout of the workstation by, for example,
storing frequently used loads at waist level. The removal of obstacles and the use of a
better lifting technique that relies on the leg rather than back muscles should be
encouraged. When pushing, the hands should be positioned correctly. The work routine
should also be examined to see whether job rotation is being used as effectively as it could
be. Special attention should be paid to seated manual handlers to ensure that loads are
not lifted from the floor while they are seated. Employees should be encouraged to seek
help if a difficult load is to be moved so that a team of people can move the load. Adequate
and suitable personal protective equipment should be provided where there is a risk of
loss of grip or injury. Care must be taken to ensure that the clothing does not become a
hazard in itself (e.g. the snagging of fasteners and pockets).
The load should be examined to see whether it could be made lighter, smaller or easier to
grasp or manage. This could be achieved by splitting the load, the positioning of
handholds or a sling, or ensuring that the centre of gravity is brought closer to the handler’s
body. Attempts should be made to make the load more stable and any surface hazards,
such as slippery deposits or sharp edges, should be removed. It is very important to ensure
that any improvements do not, inadvertently, lead to the creation of additional hazards.
The working environment can be improved in many ways. Space constraints should be
removed or reduced. Floors should be regularly cleaned and repaired when damaged.
Adequate lighting is essential and working at more than one level should be minimized so
that hazardous ladder work is avoided. Attention should be given to the need for suitable
temperatures and ventilation in the working area.
The capability of the individual is the fifth area where control measures can be applied to
reduce the risk of injury. The state of health of the employee and his/her medical record
will provide the first indication as to whether the individual is capable of undertaking the
task. A period of sick leave or a change of job can make an individual vulnerable to manual
handling injury.

5.3.5 Manual handling training


Training alone will not reduce manual handling injuries – there still need to be safe systems
of work in place and the full implementation of the control measures highlighted in the
manual handling assessment. The following topics should be addressed in a manual
handling training session:

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✓ types of injuries associated with manual handling activities


✓ the findings of the manual handling assessment
✓ the recognition of potentially hazardous manual handling operations
✓ the correct use of mechanical handling aids
✓ the correct use of personal protective equipment
✓ features of the working environment which aid safety in manual handling
operations
✓ good housekeeping issues
✓ factors which affect the capability of the individual
✓ good lifting or manual handling technique as shown in Figure 5.4
Finally, it needs to be stressed that if injuries involving manual handling operations are to
be avoided, planning, control and effective supervision are essential.

Reading assignments
Reading on the “Safety in the use of lifting and moving equipment” and the “Types of
mechanical handling and lifting equipment, together with their safety considerations”

Figure 5.4 Elements of a good lifting technique

5.4 Psychosocial Hazard


5.4.1 Introduction

Hazards that affect the mental well-being/health of the worker. These may have physical
effects by overwhelming the individual coping mechanisms and impacting the workers’
ability to work in a healthy and safe manner. The hazards are generally not from physical
things one can see but rather as a result of interactions with others. There are often no

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obvious outward signs of the effects of exposure. The methods to control these hazards
are somewhat different than methods used to control other traditional workplace hazards.
It is only really in the last 20 years that psychological hazards have been included among
the occupational health hazards faced by many workers. This is now the most rapidly
expanding area of occupational health, and includes topics such as mental health and
workplace stress (as well as violence to staff and substance abuse).

5.4.1 Contributing factors

• Maladjustment with work environment.


• Lack of job satisfaction
• Insecurity
• Emotional tension
• Poor human relationships

5.4.2 Signs and symptoms of Psychosocial Hazard

• Anxiety/Depression
• Sickness absentees
• Irritability
• Tiredness
• Giddiness

5.4.3 Effects of Psychosocial Hazard

• Reduced decision-making ability


• Reduced ability to do complex planning
• Increased incident rates
• Health problems which include fatigue, headache, hypertension, heart disease,
peptic ulcer.

5.4.4 Control of Psychosocial Hazards

• Good induction program


• Management by participation
• Establishment of Proper communication channel
• Establishment of Healthy personnel policies
• Establishment of healthy HR relationship
• Regular stress management programme

Reading Assignment

Read this research papers on physical and psychosocial hazards in the Ghanaian mining
industry for discussion.

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Amponsah-Tawiah, K., Jain, A., Leka, S., Hollis, D. and Cox, T., (2013), "Examining
Psychosocial and Physical Hazards in the Ghanaian Mining Industry and Their
Implications for Employees’ Safety Experience", Journal of safety research, Vol. 45, pp.
75-84.

Amponsah-Tawiah, K., Leka, S., Jain, A., Hollis, D. and Cox, T., (2014), "The Impact of
Physical and Psychosocial Risks on Employee Well-Being and Quality of Life: The Case
of the Mining Industry in Ghana", Safety Science, Vol. 65, pp. 28-35.

5.5 Biological Hazards


5.5.1 Introduction

They are organic substances that pose a threat to the heath of humans and other living
organisms. These include pathogenic micro-organisms, virus, toxins (from biological
sources, spores, fungi and bio-active substances). Exposure to infective and parasitic
agents can be through Insect bite, dog bite, snake bite.

5.5.2 Effects of Biological Hazards

The effects on health of hazardous substances may be either acute or chronic.

Acute effects are of short duration and appear fairly rapidly, usually during or after a single
or short-term exposure to a hazardous substance. Such effects may be severe and require
hospital treatment but are usually reversible. Examples include asthma-type attacks,
nausea and fainting.

Chronic effects develop over a period of time which may extend to many years. The word
‘chronic’ means with time’ and should not be confused with ‘severe’ as its use in everyday
speech often implies. Chronic health effects are produced from prolonged or repeated
exposures to hazardous substances resulting in a gradual, latent and often irreversible
illness, which may remain undiagnosed for many years. Many cancers and mental diseases
fall into the chronic category. During the development stage of a chronic disease, the
individual may experience no symptoms.

5.5.3 Biological Hazards Control

• Practice good personal hygiene (e.g., regular hand washing)


• Clean and disinfect work surfaces often
• Handle and dispose of all bio-hazardous waste materials safety
• Ensure that any equipment that might harbour bio-hazards (e.g., fans, ventilation
system) is regularly maintained, cleaned and sterilized
• Use of personal protective equipment

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5.6 Electrical Hazards


5.6.1 Introduction

Electricity is a widely used, efficient and convenient but potentially hazardous method of
transmitting and using energy. It is in use in every factory, workshop, laboratory and office
in the country. Any use of electricity has the potential to be very hazardous with possibly
fatal results. Electrical hazards are hazards associated with the use of energy
source/electricity.

5.6.2 Common Electrical hazards

• Improper grounding
• Exposed electrical parts
• Inadequate wiring
• Damaged Insulations
• Damaged Insulations
• Overloaded Circuits
• Overhead Power lines
• Wet Conditions
• Damaged Tools and Equipment

5.6.3 Effects of Electrical Hazards

• Injury from direct contact


o Injury by shock
o Injury from internal burns
• Injury without current flow through body
• Direct burns from electrical arcs
• Radiation burns from very heavy arcs
• Injury from fire & explosion from electrical arc
• Physical injury from false starting of machinery, failure of controls
• Eye injury from electrical arc welding

5.6.4 Electrical Hazards Control

• Inspect tools and cords completely before using


• OSHA requires the use of GFCIs (a fast-acting circuit breaker) on all construction
sites. Notably, GFCI senses small imbalances in the circuit caused by current
leakage to ground
• Workers must ensure electricity is off and “locked-out” before work is performed.
• The use of suitable personal protective equipment

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5.7 Mechanical Hazard

These are hazards associated with moving machinery. Mechanical hazards can occur in
three basic areas;

• At the point where work is performed: work points include areas where cutting,
boring, shaping and forming take place
• In power transmission apparatus: power transmission areas are flywheels, belt,
pulleys, couplings, connecting rods, chains and gears.
• In other moving parts: other moving parts of machinery consist of rotating,
reciprocating, transversing and feeding mechanisms

5.7.1 Mechanical hazards control /prevention

• Installation of physical barriers and guards such as fences, screens or fixed panels
of various materials
• Protection using minimum gap between the moving components
• Protection by reducing the force and energy levels of moving components
• Preventive maintenance
• Adequate job training
• Ensuring safe working environment
• Establishment of safety department with qualified safety engineer
• Periodic survey for finding out hazards
• Application of ergonomics

5.8 Chemical Hazards

A chemical hazard is a type of occupational hazard caused by exposure to chemicals in


the workplace. Exposure to chemicals in the workplace can cause acute or long-term
detrimental health effects. There are many types of hazardous chemicals, including

• Neurotoxins (e.g., Lead, Ethanol)


• Immune agents
• Dermatologic agents,
• Carcinogens (e.g., alcoholic beverages, asbestos)
• Reproductive toxins
• Systemic toxins (e.g., mercury)
• Asthmagens, pneumoconiosis agents, and sensitizers.

These hazards can cause physical and/or health risks. Depending on the chemical, the
hazards involved may be varied, thus it is important to know and apply the PPE especially
during the lab. Exposure to chemicals in the workplace can cause acute or long-term
detrimental health effects. Long term exposure to chemicals such as silica dust, engine

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exhausts, tobacco smoke, and/or lead have been shown to increase risk of heart disease,
stroke, and high blood pressure.

5.8.1 Types of chemical hazards

• Liquids like cleaning products, paints, acids, solvents – especially if chemicals are
in an unlabelled container
• Vapours and fumes that come from welding or exposure to solvents
• Gases like acetylene, propane, carbon monoxide and helium
• Flammable materials like gasoline, solvents, and explosive chemicals.
• Pesticides

5.8.2 Effects of Chemical Hazards

• Asphyxiation
• Systematic intoxication
• Pneumoconiosis
• Carcinogens
• Irritation
• Mutagenicity

5.8.3 Routes of Entry into the Body

There are four main routes by which hazardous chemicals enter the body.

• Inhalation (through the nose)


• Skin absorption (on the skin)
• Ingestion (through the mouth)
• Injection (into the skin and the blood)

5.8.4 Chemical Hazard Control

There are thousands of chemical compounds, which presents some form of hazards
either major or minor incidents usually termed as chemical accidents. Ways to control
chemical accidents and chemical hazard include:

• Read carefully the instructions and warnings on the packaging before using a
chemical product.
• Knowledge of operator of chemicals.
• Only buy and stock the quantities required in the near future.
• Dust control- this can be achieved through proper ventilation, exhaust, enclosed
apparatus, good housekeeping.
• Personnel protection: Mask, clothing, cloves, apron, boots barrier cream etc.
• Personal hygiene.

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• Health education about respiratory evolvement and personal protection.


• Medical control: Periodic medical check-up for early detection.

5.8 Personal Protective Equipment

Personal protective equipment (PPE) should only be used as a last resort – wherever
possible use engineering controls and safe systems of work instead. If PPE is still needed
it must be provided free by the employer. When selecting PPE, there is the need to
consider

✓ who is exposed and to what?


✓ how long are they exposed for?
✓ how much are they exposed to?

5.8.1 Maintenance
Equipment must be properly looked after and stored when not in use, e.g. in a dry,
clean cupboard. If it is reusable it must be cleaned and kept in good condition. For
effective maintenance, the following must be noted:

✓ using the right replacement parts which match the original, eg respirator filters;
✓ keeping replacement PPE available;
✓ who is responsible for maintenance and how it is to be done;
✓ having a supply of appropriate disposable suits which are useful for dirty jobs
where laundry costs are high, e.g. for visitors who need protective clothing.
✓ Employees must make proper use of PPE and report its loss or destruction or any
fault in it.

5.8.1 Monitor and review


✓ There should be regular checks that PPE is used or find out why not.
✓ Safety signs can be a useful reminder to ensure PPE is used.
✓ Take note of any changes in equipment, materials and methods – you may
need to update what you provide.

5.8.1 Eyes
Hazards
Chemical or metal splash, dust, projectiles, gas and vapour, radiation.
Options
Safety spectacles, goggles, face screens, face shields, visors.

NB: Make sure the eye protection chosen has the right combination of impact/dust/
splash/molten metal eye protection for the task and fits the user properly.

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5.8.2 Head and neck


Hazards
Impact from falling or flying objects, risk of head bumping, hair entanglement, chemical
drips or splash, climate or temperature.

Options
Industrial safety helmets, bump caps, hairnets and firefighters’ helmets.

NB: Some safety helmets incorporate or can be fitted with specially-designed eye or
hearing protection. Don’t forget neck protection, e.g. scarves for use during welding.
Replace head protection if it is damaged.
5.8.3 Ears
Hazards
Impact noise, high intensities (even if short exposure), pitch (high and low frequency).

Options
Earplugs or earmuffs.

NB: Earplugs may fit into or cover the ear canal to form a seal. Earmuffs are normally
hard plastic cups which fit over and surround the ears. They are sealed to the head by
cushion seals. Take advice to make sure they reduce noise to an acceptable level. Fit only
specially-designed earmuffs over safety helmets.
5.8.4 Hands and arms
Hazards
Abrasion, temperature extremes, cuts and punctures, impact, chemicals, electric shock,
skin irritation, disease or contamination.

Options
Gloves, gloves with a cuff, gauntlets and sleeving which covers part of or the whole of the
arm.

NB: Don’t wear gloves when operating machines such as bench drills where the gloves
might get caught. Some materials are quickly penetrated by chemicals – take care in
selection. Use skin-conditioning cream after work with water or fat solvents. Barrier creams
are unreliable and are no substitute for proper PPE. Disposable or cotton inner gloves can
reduce the effects of sweating.
5.8.4 Feet and legs
Hazards
Wet, hot and cold conditions, electrostatic build-up, slipping, cuts and punctures, falling
objects, heavy loads, metal and chemical splash, vehicles.

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Options
Safety boots and shoes with protective toe caps and penetration-resistant midsole,
wellington boots and specific footwear, e.g. foundry boots and chainsaw boots.

NB: Footwear can have a variety of sole patterns and materials to help prevent slips in
different conditions, can have oil or chemical-resistant soles, and can be anti-static,
electrically conductive or thermally insulating. There is a variety of styles including
‘trainers’ and ankle supports. Avoid high-heeled shoes and open sandals. Consider the
comfort factor for the wearer.
5.8.5 Lungs
Hazards
Oxygen-deficient atmospheres, dusts, gases and vapours.

Options
There are respirators that rely on filtering contaminants from workplace air. These include
simple filtering facepieces and respirators and power-assisted respirators. In addition,
there are types of breathing apparatus, which give an independent supply of breathable
air, for example fresh-air hose, compressed airline and self-contained breathing
apparatus. You will need to use breathing apparatus in a confined space or if there is a
chance of an oxygen deficiency in the work area.

NB: The right type of respirator filter must be used as each is effective for only a limited
range of substances. Filters have only a limited life. Where there is a shortage of oxygen
or any danger of losing consciousness due to exposure to high levels of harmful fumes,
use only breathing apparatus.
5.8.6 Whole body
Hazards
Heat, cold, bad weather, chemical or metal splash, spray from pressure leaks or spray
guns, contaminated dust, impact or penetration, excessive wear or entanglement of own
clothing.
Options
Conventional or disposable overalls, boiler suits, aprons, chemical suits, thermal clothing.

NB: The choice of materials includes flame retardant, anti-static, chain mail, chemically
impermeable, and high visibility. Don’t forget other protection, like safety harnesses or life
jackets.

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CHAPTER 6
6. RISK MANAGEMENT
6.1 Understanding the Importance of Risk Management

The business environment of today is quite dynamic, increasing competitive and


becoming more interconnected internationally. Sustaining operational prosperity in this
rapidly changing and increasing complex environment is dependent on successful
management of risks and uncertainties that can impact an organisations objective. The
importance of risk management is highlighted in the following:

✓ “Today’s complex environment requires an even stronger capability to master and


optimize risk management” - KPMG2
✓ “Since 2004, the Excellence in Risk Management survey has clearly shown an ever-
increasing organizational focus on risk management. The drivers have included
regulatory and rating agency requirements, emerging risks, and a geopolitical
landscape fraught with greater uncertainty. The annual report has pointed out new
and refined best practices, tools, and trends, as well as the widening divergence
between risk management as traditionally practiced and the growing expectations
from senior management and their boards of directors as to what it should provide.
The result has been more pressure on risk professionals to become increasingly
strategic in support of organizational prosperity.” Marsh and RIMS 3
✓ “A paradigm shift in risk management is beginning, which 1) is tied to the
increasingly complex world in which companies now operate, 2) is based on the
awareness that uncertainty is embedded in ( and impacts) everything we do, and
3) is focused on both capturing upside opportunities as well as protecting the
business.” Ernst & Young4

But what is risk management? What does risk management mean? There are various
definitions of risk management.

Activity
What does the term ‘risk’ mean to you?

2 KPMG (2013) Expectations of risk management outpacing capabilities - It’s time for action, KPMG International. The full report can be
downloaded from https://www.kpmg.com/Global/en/issuesandinsights/articlesPublications/risk-management-outpacing-
capabilities/documents/expectations-risk-management-survey.pdf
3 Marsh and RIMS (2014), Special report: Excellence in Risk Management XI-Risk management and organizational alignment: A strategic focus,

Marsh and McLennan Group: USA. The full report can be downloaded from: http://www.mmc.com/content/dam/mmc-web/Files/risk
management and organizational alignment.pdf
4 Ernst & Young (2014), Expecting more from risk management: Drive business results through harnessing uncertainty, Ernst & Young Global

Limited: UK The full report can be downloaded from: https://www.ey.com/Publication/vwLUAssets/EY_-


_Expecting_more_from_risk_management/$FILE/EY-expecting-more-from-risk-management.pdf

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6.2 Key Concepts of Risk Management


From the information we have reviewed so far, we can see that the key concepts of risk
management can be summarised by Hillson (2010, p 153)5 into the following 6 concepts:
1) Risk is ‘uncertainty that matters’ – but different things matter to different people to
a different extent in different circumstances.
2) Risk includes both downside (threats) and upside (opportunities) – both types of
risk need to be addressed proactively, in order to minimise threats and maximise
opportunities.
3) ‘Zero risk’ is unachievable and undesirable – all aspects of life (including business
and projects) involve risk, so some degree of risk-taking is inevitable, but we should
only take appropriate risks in relation to the level of return we expect or require.
4) Risk has two key dimensions – uncertainty can be expressed as ‘probability’ or
‘frequency’, and how much it matters can be called ‘impact’ or ‘consequence’.
5) Risk management requires an understanding of both dimensions – if the uncertain
event is very unlikely or it would have negligible effect, it requires less attention.
6) Risk management is affected by perception – answers to the questions “How
uncertain is it?” and “How much does it matter?” are subjective.
6.3 Humans and Risk
When it comes to managing risk in industry, humans take a number of roles:
✓ Risk analyser: The people who identify and assess risks and determine the controls
needed to manage risk
✓ Risk controller: The people who are exposed to the risk and have to manage it
✓ Risk perceiver: The stakeholders who consider and hold a view about a risk.
For risk analysers – Risk analysers are the people who apply risk management principles
and processes to identify and determine ways of addressing the uncertainties that matter
to a business. Some organisations have dedicated risk professionals, some organisations
leave risk analysing to subject-matter specialists (e.g. environmental engineers, safety
specialists etc), some organisations make risk analysing to a core component of key
leadership and technical roles, some organisations outsource the risk analysing and some
organisations do a combination.
In the resources industry, recent research suggest that we could be doing a better job at
identifying and assessing risks and risk controls. For example, the International Council on
Mining and Metals (ICMM) found:
Analysis by some mining and metals companies suggests that the top factors for why
fatalities, serious injuries, serious diseases and high potential incidents occur are due to
people not properly identifying risks, controls not being in place, or the controls not
being effectively implemented or maintained. (ICMM 2013 Requests for proposals)

5 Hillson, D., (2010) Exploiting Future Uncertainty: Creating value from risk, Gower, Surrey UK

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Activity
Who does the risk analysing in your organisation. Do you agree with the ICMM? Do you
think organisations can better identify and control health and safety risks and/or other risks
– i.e. community/social risk, human well-being risks, asset security risks, environmental
risks, economic risks, and technical risks? Why/why not?

Risk controller - There are two perspectives of humans and risk. There is the perspective
that humans are the source of risk within industry. The other perspective on humans and
risk is that humans are the adaptable resource that keeps control of risk in real time, most
of the time.
Risk perceiver – As mentioned previously, risk perceivers are stakeholders who consider
and hold a view about a risk or a number of risks. Their point of view is often referred to
as their “risk perception. The concept of risk perception is discussed in detail next.
6.4 Risk Communication
Risk communication involves the exchange of information about risk and risk perception.
Risk communication can be formal or information. It can occur across the many modes of
communication including face-to-face discussions, printed material, online materials,
social media communications. There is growing recognition that risk communication
needs to extend beyond the technical calculations of probability × consequence ×
exposure type information to incorporate risk perception and risk appetite aspects of risk.
6.5 Risk Identification
Risk identification can be defined as shown in Table 6.1. However, in this course we
define risk as the uncertainty that matters because it can have an impact on objectives.
Risk identification is about trying to identify the uncertainties that matter. Uncertainty can
be caused by variability, known and unknown threats and opportunities and incomplete
knowledge, uncertainty can be associated with the present and the future.

Table 6.1 Definitions for Risk Identification

DEFINITION FROM
PLAIN ENGLISH DEFINITION
ISO31000:2009
Process of finding, ‘Risk identification’ is the process of identifying the
recognizing and describing opportunities or hazards (sources of harm) and describing
risks. the types of credible risks that could affect your organisation.
It involves a thorough examination of your organisation’s
activities and the potential events that could occur and those
that have occurred in similar circumstances. These events
can be planned or unplanned.

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This results in a comprehensive list of well-defined risks,


although there may be some uncertainties and ambiguities,
unique to your organisation and its operational environment.

Risk identification should involve looking for uncertainty that derives from current and
future variability, threats and potential threats, opportunities and potential opportunities,
and incomplete knowledge. Risk identification activities should also refer to the past to
identify historically the variability, threats, opportunities, and knowledge issues that have
impacted objectives and for these risks to be monitored and managed into the future in
ways that prevent reoccurrences of unwanted events.

Risk identification activities can be formal, informal, or a combination of the both as


shown in Figure 6.1. The activity of risk identification should be regular and ongoing, and
linked to the rate of change experienced, and management of change processes,
associated with an entity.

Figure 6.1 Approach to risk identification

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6.5 Risk Analysis Theory


Risk analysis can be defined as shown in Table 6.2. As the information in Table 6.2
highlights risk analysis is often done using likelihood and consequence. It can sometimes
be based on just one assessment of a consequence. It can also involve an assessment of
exposure. Likelihood is the probability that an uncertainty might eventuate in the future.
Consequence is the impact or outcomes that might result should the uncertainty
eventuate. Consequences can be positive, negative, or both. Exposure is how many
people and/or entities could be impacted if the risk eventuates.

Table 6.2 Definitions of Risk analysis

DEFINITION FROM
PLAIN ENGLISH DEFINITION
ISO31000:2009
Process to comprehend the ‘Risk analysis’ is the process of determining the
nature of risk and to determine relative effect individual risks are likely to exert on
the level of risk. your organisation/role.

Risks to your organisation are analysed in terms of


the likelihood of the event(s) occurring (e.g. ranging
from rare to almost certain) and consequence(s) if
the event occurs (e.g. ranging from minor to
catastrophic). Events can be planned or unplanned.

This results in data that can then be used to prioritise


risk for management action as part of ‘risk
evaluation’.

Risk analysis can, and often does, involve using a matrix. The two industry matrices
shown in Figures 6.2 and 6.3 are quite simple. These matrices have different attributes.
Figure 6.2 provides descriptors for the range of consequences – people, assets,
environment, reputation – that relate to organisational objectives. Figure 6.2 also provides
basic guidance on actions to take when the risk is assessed as having a certain
consequence and likelihood rating.

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Figure 6.2 Risk matrix

Source: http://www.eimicrosites.org/heartsandminds/ram.php

Figure 6.3 extends the range of consequences even further and provides more guidance
on assessing likelihood. The output from using a matrix like Figure 6.3 is a number. This
number can be used to rank risks from highest to lowest thereby allowing people to focus
on the highest risks first.
These matrices can help people assess and prioritise risk. However, one of the lessons
learned in using these matrices is that the high consequence, low likelihood events can
often get overlooked. Events such as dust explosions, successful anti-mining campaigns,
tailings dam overflow/failures might not get the priority, or attention, they deserve because
some matrix rank them as low[er] risk.

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Figure 6.3 Risk matrix

6.6 Risk evaluation and the concepts of tolerable risk and ALARP
Once a risk has been analysed, an entity (person or organisation) needs to evaluate it.
The formal definitions for Risk Evaluation are shown in Table 6.3. Risk evaluation is
conducted to determine whether that risk will be accepted as is or whether it needs to be
proactively managed in a way that reduces it to an acceptable level. Risk acceptability is
often judged using terms like tolerability and As Low As Reasonably Practicable (ALARP).
Understanding the concepts of risk tolerability and ALARP can be challenging.

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Table 6.3 Definitions of risk analysis6

DEFINITION FROM
PLAIN ENGLISH DEFINITION
ISO31000:2009
Process of comparing the Risk evaluation’ is the process of comparing estimated levels
results of risk analysis with of risk against the criteria defined earlier when establishing the
risk criteria to determine context. It then considers the balance between potential
whether the risk and/or its benefits and adverse outcomes, to determine if the risk is
magnitude is acceptable or acceptable or tolerable based on the quality of the controls in
tolerable. place.

This results in decisions being made about the current


and potential future risk mitigation strategies and their
priorities to ‘as low as reasonably practicable’
principles.

Figure 6.4 Risk intolerability and ALARP

Source: http://www.hse.gov.uk/foi/internalops/hid_circs/permissioning/spc_perm_37/,
http://www.jakeman.com.au/media/alarp-as-low-as-reasonably-practicable

A good explanation of the concepts is as follows and as shown in Figure 6.4.


Intolerable Risk
Clearly, if the risk is in this region then ALARP cannot be demonstrated and action must
be taken to reduce the risk almost irrespective of cost.
“Tolerable if ALARP” Risk

6Health and Safety Executive, Guidance on ALARP Decisions in COMAH, British Government, London,
http://www.hse.gov.uk/foi/internalops/hid_circs/permissioning/spc_perm_37

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If the risks fall in this region then a case specific ALARP demonstration is required. The
extent of the demonstration should be proportionate to the level of risk.

Broadly Acceptable Risk:


If the risk has been shown to be in this region, then the ALARP demonstration may be
based on adherence to codes, standards and established good practice. However, these
must be shown to be up-to-date and relevant to the operations in question.
A good description of ALARP is shown in box 1 below. As mentioned, ALARP is a legal
term. It is most commonly used when assessing safety and/or fatality risks. However,
the principles underlying tolerability and ALARP are applicable to environmental,
social, financial, and technology risks. They are also linked to risk perception and risk
appetite making them important concepts to understand.

Box 1 8 Definition of ALARP

Source: http://www.nopsema.gov.au/assets/Guidance-notes/N-04300-GN0166-
ALARP.pdf

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6.7 Risk assessment tools and techniques


Many risk assessment tools and techniques exist, as shown in Table 6.4.

Table 6.4 Range of possible decision-making strategies (Hassall and Sanderson, 2011)

APPROACH
DESCRIPTION
/SOURCES
SWOT analysis Commonly used as a planning tool for analysing a business, its
(Strength, resources and its environment by looking at internal strengths and
Weakness, Opportunity weaknesses; and opportunities and threats in the external
Threats) environment.
PESTLE (Political, Commonly used as a planning tool to identify and categorise
Economic, Sociological, threats in the external environment (political, economic, social,
Technological, Legal, technological, legal, environmental).
Environmental)
Brainstorming Creative technique to gather risks spontaneously by group
members. Group members verbally identify risks in a ‘no wrong
answer’ environment. This technique provides the opportunity for
group members to build on each other’s ideas.
Scenario analysis Uses possible (often extreme) future events to anticipate how
threats and opportunities might develop.
Surveys/Questionnaires Gather data on risks. Surveys rely on the questions asked.
One-on-one interviews Discussions with stakeholders to identify/explore risk areas and
detailed or sensitive information about the risk.
Stakeholder analysis Process of identifying individuals or groups who have a vested
interest in the objectives and ascertaining how to engage with
them to better understand the objective and its associated
uncertainties.
Working groups Useful to surface detailed information about the risks, ie. source,
causes, consequences, stakeholder impacted, existing controls.
Corporate knowledge History of risks provide insight into future threats or opportunities
through:
Experiential knowledge – collection of information that a person
has obtained through their experience.
Documented knowledge – collection of information or data that
has been documented about a particular subject.
Lessons learned – knowledge that has been organised into
information that may be relevant to the different areas within
the organisation.
Process analysis An approach that helps improve the performance of business
activities by analysing current processes and making decisions on
new improvements.

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Other jurisdictions Issues experienced and risks identified by other jurisdictions should
be identified and evaluated. If it can happen to them, it can happen
here.

Some techniques are general – for example Brainstorming, Event inventories and loss
event data Interviews and self-assessment, Facilitated workshops, SWOT analysis, Risk
questionnaires and risk surveys. Some techniques have been tailored to achieve specific
objectives.
In selecting a technique, it is important to understand the objective and scope of the
assessment before selecting techniques to help achieve that objective. Good critiques of
the techniques exist (for example, Tworek, 20107) and it is also important to understand
the pitfalls and how to overcome them with good process.

6.8 Risk Treatment


The outcome of the risk assessment processes is a list of risks that are acceptable, and a
list of risks that are unacceptable and need to be controlled. Depending on the nature of
the risk assessment activities, these risks can be articulated as risks, threats, opportunities,
and/or unwanted event scenarios. In determining the best way to treat a risk, it is often
useful to identify the unwanted events that can lead to the unacceptable risks.

6.8.1 Identification of Unwanted Events


The identification of unwanted events can come from brainstorming exercises,
benchmarking exercises, reviews of past events, and expert forecasting exercises. Some
examples of unacceptable risks and unwanted events from the resources industry are
listed in Table 6.5. As discussed above, the output of risk assessment process is a
prioritised list of the risks and/or unwanted events which may be ranked from highest to
lowest risk based on an assessment of the severity of the consequence and sometimes
the likelihood of the outcome. This ranking can help a business prioritise resources and
effort on treating the risks that have the most potential to seriously harm the business, or
the most potential to deliver significant benefit/opportunities to the business.

7 Tworek, P. (2010) ‘Methods of Risk Identification In Companies’ Investment Projects’, Proceedings of the 5th International Conference Management and
Modelling of Financial Risk, Technical University of Ostrava, Czech Republic, 8-9 September 2010

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Table 6.5 Examples of unacceptable risks and unwanted events from the resources
industry

UNACCEPTABLE RISK EXAMPLES OF UNWANTED EVENTS


Unsafe operation of a vehicle, loss of control of strata,
Human fatalities
ignition of gas underground gas, fall from heights, etc.
Permanent and disabling Diesel emissions above specified limits, undetected
health issues depression in employees, etc.
Loss/suspension of license to operate, failure/delay to get
Community protests permits approved, community blockage of accessways,
etc,
Air/noise over license limits, uncontrolled release of
Environment damage
contaminated water, tailings leak, etc.
Strata failure, loss of supply of key components, loss of
Business disruption
transport routes, etc.
Failure to exploit new markets, failure to met/exceed
Lost opportunities local supplier targets, failure to adopt beneficial
technology.

When describing the unwanted event, ideally the description of the unwanted event
should describe the point at which an opportunity is lost, or a system has gone from
being “in control” to being “out of control”. In terms of safety this can be expressed as
follows and as highlighted in Figure 6.5. The same logic should be applicable to other
types of unwanted events (e.g. environmental, financial, production losses, community
protests, etc.)
The description should be of the system state and not a description of the reasons
why the system state has gone into the unsafe region. In some case it is clear what
the description should be. For example, the fuel leak from a bulk fuel storage area
(loss of fuel containment) could become the description of an unwanted event,
rather than the subsequent fire, explosion or pollution which should be
considered as a consequence. However, in other cases it may not be clear what
the description should be. In these instances, discussion and discretion will be
required to determine the most appropriate description for the unwanted event.
It may be helpful to think about describing the unwanted event as the situation
which represents the last opportunity to intervene and prevent an accident.8
The most effective way to manage unwanted events is to eliminate the hazard
that can cause unwanted events. If elimination is not an option then substituting
the hazard with something that has less risk and minimising exposures should be
the next area to focus on to reduce risk levels. If elimination, substitution and
reducing exposure levels do not reduce the risks to a tolerable level then the next

8 Hassall, M., Joy, J., Doran, C., & Punch, M. (2015) Selection and optimisation of risk controls, (ACARP report C23007). Available from
http://www.acarp.com.au/reports.aspx

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option involves identifying the unwanted events that can emerge from the hazard
and selecting and optimising controls that help ensure effective protection of
people, assets, and the environment.9

Figure 6.5 Safe/unsafe operating zone diagram (from Hassall et al, 2015)

The risk treatment options summarised in Figure 6.6 are consistent with the Hierarchy of
Controls.

9 Ibid

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Figure 6.6 Approach to risk identification

6.8.2 Selection and Optimisation of Risk Controls


Risk controls are the interventions taken to manage risk to an acceptable level. The ISO
31000 standard defines risk control as a “measure that is modifying risk”. 10 This
definition is quite abstract and many things could be interpreted as controls. In research
work funded by Australia Coal Association Research Program (ACARP), it was found
that a more stringent definition of control could lead to better selection of controls that
directing impact risk. The proposed definition is:
“A control is an object and/or human action that of itself will arrest or mitigate an
unwanted event sequence. Arresting controls are used to reduce the likelihood of
unwanted events occurring. Mitigating controls limit the adverse effects of an
unwanted event if it does occur”.11
This definition is shown as a decision tree in Figure 6.7.

Figure 6.7 Defining a control (from Hassall et al, 2015)

The proposed definition of control was derived to address operational risks and therefore
focuses on what controls are needed by frontline staff and supervisors to effectively
manage risks at the operational interface. Other risks, such as social risks, economic risks,
and political risks are typically managed higher up in a business. The definition of control
should still apply to the management of external threats and opportunities.

10 AS/NZS ISO 31000:2018 Risk management - Guidelines. The standard is available to UQ students via the SAI Global database in the library
11 Hassall, M., Joy, J., Doran, C., & Punch, M. (2015) Selection and optimisation of risk controls, (ACARP report C23007). Available from
http://www.acarp.com.au/reports.aspx

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The identification of risk controls can be done by brainstorming, focus groups,


benchmarking, getting expert advice, etc. Risk controls can then be documented in the
risk register. It can also be done in a more formal way through bowtie analysis.

6.9 Management of Controls: Monitoring and Review, and Verification Activities


In the resources industry, we still experience unwanted events. The International Council
of Mining and Metals (ICMM) looked at fatality related events and found:
“The top factors for … incidents are people not properly identifying risks,
controls not being in place, or the controls not being effectively
implemented or maintained”. (ICMM 2013)
This statement highlights that just doing the analysis to determine effective risk treatments
is not sufficient – treatments need to be effectively implemented and maintained over
time. The ICMM produced guidelines that recommend extra verification on those
controls that are critical for preventing significant unwanted events.

Reading Assignment
International Council of Mining and Metals (2015) Health and Safety Critical Control
Management - Good Practice Guide, International Council of Mining and Metals,
London

6.10 Communication and Consultation


An important part of the risk assessment and risk treatment process involves
communication and consultation. Risk communication needs to 1) be used to inform risk
assessment and risk treatment exercises, and 2) communicate the findings or outcomes
from risk assessment and risk treatment exercises as shown in Figure 6.8.

Figure 6.8 Traditional view of risk management

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CHAPTER 7
7. ACCIDENTS AND EMERGENCIES
7.1 Managing Workplace Emergencies
7.1.1 Emergency procedures
Special procedures are necessary for emergencies such as serious injuries, explosion,
flood, poisoning, electrocution, fire, release of radioactivity and chemical spills. Quick and
effective action by people may help to ease the situation and reduce the consequences.
However, in emergencies people are more likely to respond reliably if they are well trained
and competent, take part in regular and realistic practice, and have clearly agreed,
recorded and rehearsed plans, actions and responsibilities. Write an emergency plan if a
major incident at your workplace could involve risks to the public, rescuing employees or
co-ordination of the emergency services.

7.1.2 Points to include in emergency procedures


The following should be considered in when developing an emergency procedure

• Consider what might happen and how the alarm will be raised. Don’t forget night
and shift working, weekends and times when the premises are closed, eg holidays.
• Plan what to do, including how to call the emergency services. Help them by clearly
marking your premises from the road. Consider drawing up a simple plan showing
the location of hazardous items.
• Provide emergency lighting if necessary
• You must make sure there are enough emergency exits for everyone to escape
quickly, and keep emergency doors and escape routes unobstructed and clearly
marked.
• Nominate competent persons to take control.
• Decide who are the other key people, such as a nominated incident controller,
someone who is able to provide technical and other site-specific information if
necessary, or first-aiders?
• Plan essential actions such as emergency plant shut-down, isolation or making
processes safe. Clearly identify important items like shut-off valves and electrical
isolators etc.
• Everyone must be trained in emergency procedures. Don’t forget the needs of
people with disabilities.

7.1.3 Chain of command


The employer should designate an emergency response coordinator and a backup
coordinator. The coordinator may be responsible for plantwide operations, public
information and ensuring that outside aid is called. Having a backup coordinator ensures
that a trained person is always available. Employees should know who the designated
coordinator is. Duties of the coordinator and employer include:

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• Determining what emergencies may occur and seeing that emergency procedures
are developed to address each situation.
• Directing all emergency activities including evacuation of personnel.
• Ensuring that outside emergency services are notified when necessary.
• Directing the shutdown of plant operations when necessary.

7.1.4 Emergency response team


Emergency response team members should be thoroughly trained for potential crises and
physically capable of carrying out their duties. Team members need to know about toxic
hazards in the workplace and be able to judge when to evacuate personnel or when to
rely on outside help (e.g., when a fire is too large to handle). One or more teams must be
trained in:
✓ Use of various types of fire extinguishers.
✓ First aid, including cardiopulmonary resuscitation (CPR) and self-contained
breathing apparatus (S CBA).
✓ Shutdown procedures.
✓ Chemical spill control procedures.
✓ Search and emergency rescue procedures.
✓ Hazardous materials emergency response.

7.1.5 Emergency response activities


Effective emergency communication is vital. An alternate area for a communication centre
other than management offices should be established in the plans, and the emergency
response coordinator should operate from this centre. Management should provide
emergency alarms and ensure that employees know how to report emergencies. An
updated list of key personnel and off-duty telephone numbers should be maintained.
Accounting for personnel following evacuation is critical. A person in the control centre
should notify police or emergency response team members of persons believed missing.

Effective security procedures can prevent unauthorized access and protect vital records
and equipment. Duplicate records of essential accounting files, legal documents and
lists of employee relatives – to be notified in case of emergency – can be kept at off-site
locations.

7.1.6 Training
Every employee needs to know details of the emergency action plan, including
evacuation plans, alarm systems, reporting procedures for personnel, shutdown
procedures, and types of potential emergencies. Any special hazards, such as flammable
materials, toxic chemicals, radioactive sources or water-reactive substances, should be

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discussed with employees. Drills should be held at random intervals, at least annually,
and should include outside police and fire authorities.

Training must be conducted at least annually and when employees are hired or when
their job changes. Additional training is needed when new equipment, materials or
processes are introduced, when the layout or design of the facility changes, when
procedures have been updated or revised, or when exercises show that employee
performance is inadequate.

7.1.7 Personal protection


Employees exposed to or near accidental chemical splashes, falling objects, flying
particles, unknown atmospheres with inadequate oxygen or toxic gases, fires, live
electrical wiring, or similar emergencies need appropriate personal protective equipment.

7.1.8 Medical treatment


First aid must be available within 3 to 4 minutes of an emergency. Worksites more than
3 to 4 minutes from an infirmary, clinic, or hospital should have at least one person on-
site trained in first aid (available all shifts), have medical personnel readily available for
advice and consultation, and develop written emergency medical procedures.

It is essential that first aid supplies are available to the trained first aid providers, that
emergency phone numbers are placed in conspicuous places near or on telephones, and
prearranged ambulance services for any emergency are available. It may help to
coordinate an emergency action plan with the outsider responders such as the fire
department, hospital emergency room, EMS providers and local HAZMAT teams.

7.2 Accident at the Workplace


In any business or organisation things don’t always go to plan. There is therefore the need
to prepare to deal with unexpected events in order to reduce their consequences. Workers
and managers will be more competent in dealing with the effects of an accident or
emergency if there are effective plans in place that are regularly tested.

There is the also the need to monitor and review any measures put in place to help control
risk and prevent accidents and incidents from happening. Findings from accident and
incidents investigations can form the basis of action to prevent the accident or incident
from happening again and to improve an organisation’s overall risk management. This
will also point to areas of the risk assessments that need to be reviewed.

An effective investigation requires a methodical, structured approach to information


gathering, collation and analysis.

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7.2.1 Why investigate?


Health and safety investigations form an essential part of the monitoring process that you
are required to carry out. Incidents, including near misses, can tell you a lot about how
things actually are in reality.

✓ Investigating your accidents and reported cases of occupational ill health will help
you uncover and correct any breaches in health and safety legal compliance you
may have been unaware of
✓ The fact that you thoroughly investigated an incident and took remedial action to
prevent further occurrences would help demonstrate to a court that your company
has a positive attitude to health and safety
✓ Your investigation findings will also provide essential information for your insurers
in the event of a claim

An investigation can help you identify why the existing risk control measures failed and
what improvements or additional measures are needed. It can:

✓ provide a true snapshot of what really happens and how work is really done
(workers may find short cuts to make their work easier or quicker and may ignore
rules - you need to be aware of this)
✓ improve the management of risk in the future
✓ help other parts of your organisation learn
✓ demonstrate your commitment to effective health and safety and improving
employee morale and thinking towards health and safety

Investigating near misses and undesired circumstances, where no one has been harmed,
is as useful as, and may be easier than, investigating accidents. In workplaces where a
trade union is recognised, appointed health and safety representatives have the right to:

✓ investigate potential hazards and dangerous occurrences in the workplace


✓ examine causes of workplace accidents

7.2.2 Who should do the investigating?


Ideally, an investigation would be conducted by someone or a group of people who are:

✓ experienced in incident causation models,


✓ experienced in investigative techniques,
✓ knowledgeable of any legal or organizational requirements,
✓ knowledgeable in occupational health and safety fundamentals,
✓ knowledgeable in the work processes, procedures, persons, and industrial relations
environment for that particular situation,
✓ able to use interview and other person-to-person techniques effectively (such as
mediation or conflict resolution),
✓ knowledgeable of requirements for documents, records, and data collection; and
✓ able to analyse the data gathered to determine findings and reach
recommendations.

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Some jurisdictions provide guidance such as requiring that the incident must be conducted
jointly, with both management and labour represented, or that the investigators must be
knowledgeable about the work processes involved.
Members of the team can include:
✓ employees with knowledge of the work
✓ supervisor of the area or work
✓ safety officer
✓ health and safety committee
✓ union representative, if applicable
✓ employees with experience in investigations
✓ "outside" experts
✓ representative from local government or police

Note: In some cases, other authorities may have jurisdiction, such as if a serious injury or
fatality occurred. Your organization should establish, implement, and maintain a
procedure to coordinate managing incidents with the authority having jurisdiction (e.g.,
police, OH&S inspectors, etc.). This coordination may include the authority taking control
of the incident scene.

7.3.3 Should the immediate supervisor be on the team?


The advantage is that this person is likely to know most about the work and persons
involved and the current conditions. Furthermore, the supervisor can usually take
immediate remedial action. The counter argument is that there may be an attempt to gloss
over the supervisor’s shortcomings in the incident. This situation should not arise if the
incident is investigated by a team of people, and if the worker representative(s) and the
investigation team members review all incident investigation findings and
recommendations thoroughly.

7.2.4 Why look for the root cause?


An investigator or team who believe that incidents are caused by unsafe conditions will
likely try to uncover conditions as causes. On the other hand, one who believes they are
caused by unsafe acts will attempt to find the human errors that are causes. Therefore, it
is necessary to examine all underlying factors in a chain of events that ends in an incident.
The important point is that even in the most seemingly straightforward incidents, seldom,
if ever, is there only a single cause. For example, an "investigation" which concludes that
an incident was due to worker carelessness, and goes no further, fails to find answers to
several important questions such as:

✓ Was the worker distracted? If yes, why was the worker distracted?
✓ Was a safe work procedure being followed? If not, why not?
✓ Were safety devices in order? If not, why not?
✓ Was the worker trained? If not, why not?

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An inquiry that answers these and related questions will probably reveal conditions that
are more open to correction.

7.2.5 What are the steps involved in investigating an incident?


First:

✓ Report the incident occurrence to a designated person within the organization.


✓ Provide first aid and medical care to injured person(s) and prevent further injuries
or damage.

The incident investigation team would perform the following general steps:

✓ Scene management and scene assessment (secure the scene, make sure it is safe
for investigators to do their job).
✓ Witness management (provide support, limit interaction with other witnesses,
interview).
✓ Investigate the incident, collect data.
✓ Analyze the data, identify the root causes.
✓ Report the findings and recommendations.

The organization would then:

✓ Develop a plan for corrective action.


✓ Implement the plan.
✓ Evaluate the effectiveness of the corrective action.
✓ Make changes for continual improvement.

As little time as possible should be lost between the moment of an incident and the
beginning of the investigation. In this way, one is most likely to be able to observe the
conditions as they were at the time, prevent disturbance of evidence, and identify
witnesses. The tools that members of the investigating team may need (pencil, paper,
camera or recording device, tape measure, etc.) should be immediately available so that
no time is wasted.

7.2.6 What should be looked at as the cause of an incident?


Causation Models
Many models of causation have been proposed, ranging from Heinrich's domino theory
to the sophisticated Management Oversight and Risk Tree (MORT). The simple model
shown in Figure 7.1 attempts to illustrate that the causes of any incident can be grouped
into five categories - task, material, environment, personnel, and management. When this
model is used, possible causes in each category should be investigated. Each category is
examined more closely below. Remember that these are sample questions only: no
attempt has been made to develop a comprehensive checklist.

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Figure 7.1 Incident Categories

Task
Here the actual work procedure being used at the time of the incident is explored.
Members of the investigation team will look for answers to questions such as:

✓ Was a safe work procedure used?


✓ Had conditions changed to make the normal procedure unsafe?
✓ Were the appropriate tools and materials available?
✓ Were they used?
✓ Were safety devices working properly?
✓ Was lockout used when necessary?

For most of these questions, an important follow-up question is "If not, why not?"
Material
To seek out possible causes resulting from the equipment and materials used, investigators
might ask:

✓ Was there an equipment failure?


✓ What caused it to fail?
✓ Was the machinery poorly designed?
✓ Were hazardous products involved?

✓ Were they clearly identified?


✓ Was a less hazardous alternative product possible and available?
✓ Was the raw material substandard in some way?
✓ Should personal protective equipment (PPE) have been used?
✓ Was the PPE used?
✓ Were users of PPE properly educated and trained?

Again, each time the answer reveals an unsafe condition, the investigator must
ask why this situation was allowed to exist.

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Work environment
The physical work environment, and especially sudden changes to that environment, are
factors that need to be identified. The situation at the time of the incident is what is
important, not what the "usual" conditions were. For example, investigators may want to
know:

✓ What were the weather conditions?


✓ Was poor housekeeping a problem?
✓ Was it too hot or too cold?
✓ Was noise a problem?
✓ Was there adequate light?
✓ Were toxic or hazardous gases, dusts, or fumes present?

Personnel
The physical and mental condition of those individuals directly involved in the event must
be explored, as well as the psychosocial environment they were working within. The
purpose for investigating the incident is not to establish blame against someone but the
inquiry will not be complete unless personal characteristics or psychosocial factors are
considered. Some factors will remain essentially constant while others may vary from day
to day:

✓ Did the worker follow the safe operating procedures?


✓ Were workers experienced in the work being done?
✓ Had they been adequately educated and trained?
✓ Can they physically do the work?
✓ What was the status of their health?
✓ Were they tired?
✓ Was fatigue or shiftwork an issue?
✓ Were they under stress (work or personal)?
✓ Was there pressure to complete tasks under a deadline, or to by-pass safety
procedures?

Management
Management holds the legal responsibility for the safety of the workplace and therefore
the role of supervisors and higher management and the role or presence of management
systems must always be considered in an incident investigation. These factors may also be
called organizational factors. Failures of management systems are often found to be direct
or indirect causes. Ask questions such as:

✓ Were safety rules or safe work procedures communicated to and understood by all
employees?
✓ Were written procedures and orientation available?
✓ Were the safe work procedures being enforced?
✓ Was there adequate supervision?
✓ Were workers educated and trained to do the work?
✓ Had hazards and risks been previously identified and assessed?
✓ Had procedures been developed to eliminate the hazards or control the risks?
✓ Were unsafe conditions corrected?

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✓ Was regular maintenance of equipment carried out?


✓ Were regular safety inspections carried out?
✓ Had the condition or concern been reported beforehand?
✓ Was action taken?

This model of incident investigation provides a guide for uncovering all possible causes
and reduces the likelihood of looking at facts in isolation. Some investigators may prefer
to place some of the sample questions in different categories; however, the categories are
not important, as long as each question is asked. Obviously, there is considerable overlap
between categories; this overlap reflects the situation in real life. Again, it should be
emphasized that the above sample questions do not make up a complete checklist, but
are examples only.

7.2.7 How are the facts collected?


The steps in the investigation are simple: the investigators gather data, analyze it,
determine their findings, and make recommendations. Although the procedures are
seemingly straightforward, each step can have its pitfalls. As mentioned above, an open
mind is necessary in an investigation: preconceived notions may result in some wrong
paths being followed while leaving some significant facts uncovered. All possible causes
should be considered. Making notes of ideas as they occur is a good practice but
conclusions should not be made until all the data is gathered.
Physical evidence
Before attempting to gather information, examine the site for a quick overview, take steps
to preserve evidence, and identify all witnesses. In some jurisdictions, an incident site must
not be disturbed without approval from appropriate government officials such as the
coroner, inspector, or police. Physical evidence is probably the most non-controversial
information available. It is also subject to rapid change or obliteration; therefore, it should
be the first to be recorded. Based on your knowledge of the work process, you may want
to check items such as:

✓ positions of injured workers


✓ equipment being used
✓ products being used
✓ safety devices in use
✓ position of appropriate guards
✓ position of controls of machinery
✓ damage to equipment
✓ housekeeping of area
✓ weather conditions
✓ lighting levels
✓ noise levels
✓ time of day

You may want to take photographs before anything is moved, both of the general area
and specific items. A later study of the pictures may reveal conditions or observations that
were missed initially. Sketches of the scene based on measurements taken may also help

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in later analysis and will clarify any written reports. Broken equipment, debris, and samples
of materials involved may be removed for further analysis by appropriate experts. Even if
photographs are taken, written notes about the location of these items at the scene should
be prepared.
Witness accounts
Although there may be occasions when you are unable to do so, every effort should be
made to interview witnesses. In some situations, witnesses may be your primary source of
information because you may be called upon to investigate an incident without being able
to examine the scene immediately after the event. Because witnesses may be under severe
emotional stress or afraid to be completely open for fear of recrimination, interviewing
witnesses is probably the hardest task facing an investigator.
Witnesses should be kept apart and interviewed as soon as possible after the incident. If
witnesses have an opportunity to discuss the event among themselves, individual
perceptions may be lost in the normal process of accepting a consensus view where doubt
exists about the facts.
Witnesses should be interviewed alone, rather than in a group. You may decide to
interview a witness at the scene where it is easier to establish the positions of each person
involved and to obtain a description of the events. On the other hand, it may be preferable
to carry out interviews in a quiet office where there will be fewer distractions. The decision
may depend in part on the nature of the incident and the mental state of the witnesses.
Interviewing
The purpose of the interview is to establish an understanding with the witness and to
obtain his or her own words describing the event:
DO...

✓ put the witness, who is probably upset, at ease


✓ emphasize the real reason for the investigation, to determine what happened and
why
✓ let the witness talk, listen
✓ confirm that you have the statement correct
✓ try to sense any underlying feelings of the witness
✓ make short notes or ask someone else on the team to take them during the
interview
✓ ask if it is okay to record the interview, if you are doing so
✓ close on a positive note

DO NOT...

✓ intimidate the witness


✓ interrupt
✓ prompt
✓ ask leading questions
✓ show your own emotions
✓ jump to conclusions

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Ask open-ended questions that cannot be answered by simply "yes" or "no". The actual
questions you ask the witness will naturally vary with each incident, but there are some
general questions that should be asked each time:

✓ Where were you at the time of the incident?


✓ What were you doing at the time?
✓ What did you see, hear?
✓ What were the work environment conditions (weather, light, noise, etc.) at the
time?
✓ What was (were) the injured worker(s) doing at the time?
✓ In your opinion, what caused the incident?
✓ How might similar incidents be prevented in the future?

Asking questions is a straightforward approach to establishing what happened. But, care


must be taken to assess the accuracy of any statements made in the interviews.
Another technique sometimes used to determine the sequence of events is to re-enact or
replay them as they happened. Care must be taken so that further injury or damage does
not occur. A witness (usually the injured worker) is asked to reenact in slow motion the
actions that happened before the incident.
Other Information
Data can be found in documents such as technical data sheets, health and safety
committee minutes, inspection reports, company policies, maintenance reports, past
incident reports, safe-work procedures, and training reports. Any relevant information
should be studied to see what might have happened, and what changes might be
recommended to prevent recurrence of similar incidents.

7.2.8 What should I know when making the analysis and recommendations?
At this stage of the investigation most of the facts about what happened and how it
happened should be known. This data gathering has taken considerable effort to
accomplish but it represents only the first half of the objective. Now comes the key question
- why did it happen?
Keep an open mind to all possibilities and look for all pertinent facts. There may still be
gaps in your understanding of the sequence of events that resulted in the incident. You
may need to re-interview some witnesses or look for other data to fill these gaps in your
knowledge.
When your analysis is complete, write down a step-by-step account of what happened
(the team’s conclusions) working back from the moment of the incident, listing all possible
causes at each step. This is not extra work: it is a draft for part of the final report. Each
conclusion should be checked to see if:

✓ it is supported by evidence
✓ the evidence is direct (physical or documentary) or based on eyewitness accounts,
or
✓ the evidence is based on assumption.

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This list serves as a final check on discrepancies that should be explained.


7.2.9 Why should recommendations be made?
The most important final step is to come up with a set of well-considered recommendations
designed to prevent recurrences of similar incidents. Recommendations should:

✓ be specific
✓ be constructive
✓ identify root causes
✓ identify contributing factors

Resist the temptation to make only general recommendations to save time and effort.
For example, you have determined that a blind corner contributed to an incident. Rather
than just recommending "eliminate blind corners" it would be better to suggest:

• install mirrors at the northwest corner of building X (specific to this incident)


• install mirrors at blind corners where required throughout the worksite (general)

Never make recommendations about disciplining a person or persons who may have been
at fault. This action would not only be counter to the real purpose of the investigation, but
it would jeopardize the chances for a free flow of information in future investigations.
In the unlikely event that you have not been able to determine the causes of an incident
with complete certainty, you probably still have uncovered weaknesses within the process,
or management system. It is appropriate that recommendations be made to correct these
deficiencies.

7.2.10 The written report


The prepared draft of the sequence of events can now be used to describe what happened.
Remember that readers of your report do not have the intimate knowledge of the incident
that you have so include all relevant details, including photographs and diagrams. Identify
clearly where evidence is based on certain facts, witness accounts, or on the team’s
assumptions.
If doubt exists about any particular part of the event, say so. The reasons for your
conclusions should be stated and followed by your recommendations. Do not include
extra material that is not required for a full understanding of the incident and its causes
such as photographs that are not relevant and parts of the investigation that led you
nowhere. The measure of a good report is quality, not quantity.
Always communicate your findings and recommendations with workers, supervisors and
management. Present your information 'in context' so everyone understands how the
incident occurred and the actions needed to put in place to prevent it from happening
again.
Some organizations may use pre-determined forms or checklists. However, use these
documents with caution as they may be limiting in some cases. Always provide all of the

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information needed to help others understand the causes of the event, and why the
recommendations are important.

7.2.11 How should follow-up be done?


Management is responsible for acting on the recommendations in the investigation report.
The health and safety committee or representative, if present, can monitor the progress of
these actions.
Follow-up actions include:

• Respond to the recommendations in the report by explaining what can and cannot
be done (and why or why not).
• Develop a timetable for corrective actions.
• Monitor that the scheduled actions have been completed.
• Check the condition of injured worker(s).
• Educate and train other workers at risk.
• Re-orient worker(s) on their return to work.

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CHAPTER 8
8. MONITORING, REVIEW AND AUDIT
8.1 Introduction
This chapter concerns the monitoring of health and safety performance, including both
positive measures like inspections and negative measures like injury statistics. It is about
reviewing progress to see if something better can be done and auditing to ensure that what
has been planned is being implemented.
Measurement is a key step in any management process and forms the basis of continuous
improvement. If measurement is not carried out correctly, the effectiveness of the health
and safety management system is undermined and there is no reliable information to show
managers how well the health and safety risks are controlled.
Managers should ask key questions to ensure that arrangements for health and safety risk
control are in place, comply with the law as a minimum, and operate effectively.
Proactive monitoring, by taking the initiative before things go wrong, involves routine
inspections and checks to make sure that standards and policies are being implemented
and that controls are working.
Reactive monitoring, after things go wrong, involves looking at historical events to learn
from mistakes and see what can be put right to prevent a recurrence.
Globally, it has been observed that organizations find health and safety performance
measurement a difficult subject. They struggle to develop health and safety performance
measures which are not based solely on injury and ill-health statistics.

8.2 The Traditional Approach to Measuring Health and Safety Performance


Senior managers often measure company performance by using, for example, percentage
profit, return on investment or market share. A common feature of the measures would
be that they are generally positive in nature – which demonstrates achievement – rather
than negative, which demonstrates failure.
Yet, if senior managers are asked how they measure their companies’ health and safety
performance, it is likely that the only measure would be accident or injury statistics. While
the general business performance of an organization is subject to a range of positive
measures, for health and safety it too often comes down to one negative measure, injury
and ill-health statistics, that is, measures of failures.
Health and safety differs from many areas measured by managers because improvement
in performance means fewer outcomes from the measure (injuries or ill-health) rather than
more. A low injury or ill-health rate trend over years is still no guarantee that risks are
being controlled and that incidents will not happen in the future. This is particularly true
in organizations where major hazards are present but there is a low probability of
accidents.

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There is no single reliable measure of health and safety performance. What is required is
a ‘basket’ of measures, providing information on a range of health and safety issues.
There are some significant problems with the use of injury/ill-health statistics in isolation:
✓ there may be under-reporting - focusing on injury and ill-health rates as a measure,
especially if a reward system is involved, can lead to non-reporting to keep up
performance
✓ it is often a matter of chance whether a particular incident causes an injury, and
they may not show whether or not a hazard is under control. Luck or a reduction
in the number of people exposed, may produce a low injury/accident rate rather
than good health and safety management
✓ an injury is the particular consequence of an incident and often does not reflect the
potential severity. For example, an unguarded machine could result in a cut finger
or an amputation
✓ people can be absent from work for reasons which are not related to the severity
of the incident
✓ there is evidence to show that there is little relationship between ‘occupational’
injury statistics (e.g. slips, trip and falls) and the reasons for the lack of
control of major accident hazards (e.g. loss of containment of flammable or toxic
material)
✓ a small number of accidents may lead to complacency
✓ injury statistics demonstrate outcomes not causes.
Due to the potential shortcomings related to the use of accident/injury and ill-health data
as a single measure of performance, more proactive or ‘up stream’ measures are required.
These require a systematic approach to deriving positive measures and how they link to
the overall risk control process, rather than a quick-fix based on things that can easily be
counted, such as the
numbers of training courses or numbers of inspections, which has limited value. The
resultant data provide no information on how the figure was arrived at, whether it is
‘acceptable’ (i.e. good/bad) or the quality and effectiveness of the activity. A more
disciplined approach to health and safety performance measurement is required. This
needs to develop as the health and safety management system develops.

8.3 Why Measure Performance?


8.3.1 Introduction
You can’t manage what you can’t measure – Drucker
Measurement is an accepted part of the ‘plan-do-check act (PDCA)’ management process.
Measuring performance is as much part of a health and safety management system as
financial, production or service delivery management. The main purpose of measuring
health and safety performance is to provide information on the progress and current status
of the strategies, processes and activities employed to control health and safety risks.

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Effective measurement not only provides information on what the levels are but also why
they are at this level, so that corrective action can be taken.
8.3.2 Answering questions
Health and safety monitoring or performance measurement should seek to answer such
questions as:
✓ where is the position relative to the overall health and safety aims and objectives?
✓ where is the position relative to the control of hazards and risks?
✓ how does the organization compare with others?
✓ what is the reason for the current position?
✓ is the organization getting better or worse over time?
✓ is the management of health and safety doing the right things?
✓ is the management of health and safety doing things right consistently?
✓ is the management of health and safety proportionate to the hazards and risks?
✓ is the management of health and safety efficient?
✓ is an effective health and safety management system in place across all parts of the
organization?
✓ is the culture supportive of health and safety, particularly in the face of competing
demands?
These questions should be asked at all management levels throughout the organization.
The aim of monitoring should be to provide a complete picture of an organization’s health
and safety performance.

8.3.3 Decision making


The measurement information helps in deciding:
✓ where the organization is in relation to where it wants to be
✓ what progress is necessary and reasonable in the circumstances
✓ how that progress might be achieved against particular restraints (e.g. resources or
time)
✓ priorities – what should be done first and what is most important
✓ effective use of resources.

8.3.4 Addressing different information needs


Information from the performance measurement is needed by a variety of people. These
will include directors, senior managers, line managers, supervisors, health and safety
professionals and employees/safety representatives. They each need information
appropriate to their position and responsibilities within the health and safety management
system.

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For example, what the chief executive officer of a large organization needs to know from
the performance measurement system will differ in detail and nature from the information
needs of the manager of a particular location/unit/department.
A coordinated approach is required so that individual measuring activities fit within the
general performance measurement framework.
Although the primary focus for performance measurement is to meet the internal needs of
an organization, there is an increasing need to demonstrate to external stakeholders
(regulators, insurance companies, shareholders, suppliers, contractors, members of the
public, etc.) that arrangements to control health and safety risks are in place, operating
correctly and effectively.
7.4
8.4 What To Measure
8.4.1 Introduction
In order to achieve an outcome of no injuries or work-related ill-health, and to satisfy
stakeholders, health and safety risks need to be controlled. Effective risk control is founded
on an effective health and safety management system. This is illustrated in Figure 8.1.

Figure 8.1 Health and safety management system

8.4.2 Effective risk control


The health and safety management system comprises three levels of control (see Figure
8.1):
✓ level 3 – effective workplace precautions provided and maintained to prevent harm
to people who are exposed to the risks
✓ level 2 – risk control systems (RCSs): the basis for ensuring that adequate workplace
precautions are provided and maintained
✓ level 1 – the key elements of the health and safety management system: the
management arrangements (including plans and objectives) necessary to organize,
plan, control and monitor the design and implementation of RCSs.
The health and safety culture must be positive to support each level. Performance
measurement should cover all elements of Figure 8.1 and be based on a balanced
approach which combines:

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✓ input: monitoring the scale, nature and distribution of hazards created by the
organization’s activities - measures of the hazard burden
✓ process: active monitoring of the adequacy, development, implementation and
deployment of the health and safety management system and the activities to
promote a positive health and safety culture – measures of success
✓ outcomes: reactive monitoring of adverse outcomes resulting in injuries, ill-health,
loss and accidents with the potential to cause injuries, ill-health or loss – measures
of failure

8.5 Measuring Failure – Reactive Monitoring


So far, this chapter has concentrated on measuring activities designed to prevent the
occurrence of injuries and work-related ill-health (active monitoring). Failures in risk
control also need to be measured (reactive monitoring), to provide opportunities to check
performance, learn from failures and improve the health and safety management system.
Reactive monitoring arrangements include systems to identify and report:
✓ injuries and work-related ill-health
✓ other losses such as damage to property
✓ incidents, including those with the potential to cause injury, ill-health or loss (near
misses)
✓ hazards and faults
✓ weaknesses or omissions in performance standards and systems, including
complaints from employees and enforcement action by the authorities.

8.6 Active Monitoring – How to Measure Performance


8.6.1 Introduction
The measurement process can gather information through:
✓ direct observation of conditions and of people’s behaviour (sometimes referred to
as unsafe acts and unsafe conditions monitoring)
✓ talking to people to elicit facts and their experiences as well as gauging their views
and opinions
✓ examining written reports, documents and records.
These information sources can be used independently or in combination. Direct
observation includes inspection activities and the monitoring of the work environment
(e.g. temperature, dust levels, solvent levels, noise levels) and people’s behaviour. Each
risk control system should have a built-in monitoring element that will define the frequency
of monitoring; these can be combined to form a common inspection system.

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8.6.2 Inspections
General
This may be achieved by developing a checklist or inspection form that covers the key
issues to be monitored in a particular department or area of the organization within a
particular period. It might be useful to structure this checklist using the ‘four Ps’ (note that
the examples are not a definitive list):
✓ premises, including:
o access/escape
o housekeeping
o services like gas and electricity
o working environment
o fire precautions
✓ plant and substances, including:
o machinery guarding
o tools and equipment
o local exhaust ventilation
o use/storage/separation of materials/chemicals
✓ procedures, including:
o safe systems of work
o permits to work
o use of personal protective equipment
o procedures followed
✓ people, including:
o health surveillance
o people’s behaviour
o training and supervision
o appropriate authorized person.
It is essential that people carrying out an inspection do not in any way put themselves or
anyone else at risk. Particular care must be taken with regard to safe access. In carrying
out these safety inspections, the safety of people’s actions should be considered, in
addition to the safety of the conditions they are working in – a ladder might be in perfect
condition, but it has to be used properly too.
Observation techniques
In addition, to become a good observer, a person must:
✓ stop for 10 to 30 seconds before entering a new area to ascertain where
employees are working
✓ be alert for unsafe practices that are corrected as soon as you enter an area
✓ observe activity – do not avoid the action
✓ remember ABBI – look Above, Below, Behind, Inside
✓ develop a questioning attitude to determine what injuries might occur if the
unexpected happened and how the job might be accomplished more safely. Ask
‘why?’ and ‘what could happen if …?’

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✓ use all senses: sight, hearing, smell, touch


✓ maintain a balanced approach. Observe all phases of the job
✓ be inquisitive/curious
✓ observe for ideas – not just to determine problems
✓ recognize good performance.
Daily/weekly/monthly safety inspections
These will be aimed at checking conditions in a specified area against a fixed checklist
drawn up by local management. It will cover specific items, such as the guards at particular
machines, whether access/agreed routes are clear, whether fire extinguishers are in place,
etc. The checks should be carried out by staff of the department who should sign off the
checklist. It should not last more than half an hour, perhaps less. This is not a specific
hazard spotting operation, but there should be a space on the checklist for the inspectors
to note down any particular problems encountered.
Reports from inspections
Some of the items arising from safety inspections will have been dealt with immediately,
other items will require action by specified people. Where there is some doubt about the
problem, and what exactly is required, advice should be sought from the site safety adviser
or external expert. A brief report of the inspection and any resulting action list should be
submitted to the appropriate office responsible for safety. While the safety office may not
have the time available to consider all reports in detail, it will want to be satisfied that
appropriate action is taken to resolve all matters; it will be necessary for the safety office
to follow up the reports until all matters are resolved.

8.7 Who Should Monitor Performance?


Performance should be measured at each management level from directors downwards.
It is not sufficient to monitor by exception, where unless problems are raised, it is assumed
to be satisfactory. Senior managers must satisfy themselves that the correct arrangements
are in place and working properly. Responsibilities for both active and reactive monitoring
must be laid down and managers need to be personally involved in making sure that plans
and objectives are met and compliance with standards is achieved. Although systems may
be set up with the guidance of safety professionals, managers should be personally
involved and given sufficient training to be competent to make informed judgements about
monitoring performance.
Other people like safety representatives will also have the right to inspect the workplace.
Each employee should be encouraged to inspect their own workplace frequently to check
for obvious problems and rectify them if possible or report hazards to their supervisors.

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8.8 Frequency of Monitoring and Inspections


This will depend on the level of risk and any statutory inspection requirement. Directors
may be expected to examine the premises formally at an annual audit, while departmental
supervisors may be expected to carry out inspection each week. Senior managers should
regularly monitor the health and safety plan to ensure that objectives are being met and
to make any changes to the plan as necessary.
Data from reactive monitoring should be considered by senior managers at least once a
month. In most organizations serious events would be closely monitored as they happen.

8.9 Report Writing


There are three main aims to the writing of reports, and they are all about
communication. A report should aim to:
✓ get a message through to the reader
✓ make the message and the arguments clear and easy to understand
✓ make the arguments and conclusions persuasive.
Communication starts with trying to get into the mind of the reader, imagining what would
most effectively catch the attention, what would be most likely to convince, what will make
this report stand out among others. A vital part of this is presentation; so while a
handwritten report is better than nothing if time is short, a well-organized, typed report is
very much clearer. To the reader of the report, who may well be very busy with a great
deal of written information to wade through, a clear, well presented report will produce a
positive attitude from the outset, with instant benefit to the writer. Five factors which help
to make reports effective:
✓ structure
✓ presentation of arguments
✓ style
✓ presentation of data
✓ how the report itself is presented.

8.10 Review and Audit


8.10.1 Audits – purpose
The final steps in the health and safety management control cycle are auditing and
performance review. Organizations need to be able to reinforce, maintain and develop the
ability to reduce risks. The ‘feedback loop’ produced by this final stage in the process
enables them to do this and to ensure continuing effectiveness of the health and safety
management system. Audit is a business discipline which is frequently used, for example,
in finance, environmental matters and quality. It can equally well be applied to health and
safety. The term is often used to mean inspection or other monitoring activity. Auditing in
terms of health and safety can be defined as:

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The structured process of collecting independent information on the efficiency,


effectiveness and reliability of the total health and safety management system and
drawing up plans for corrective action.
Over time, it is inevitable that control systems will decay and may even become obsolete
as things change. Auditing is a way of supporting monitoring by providing managers with
information. It will show how effectively plans and the components of health and safety
management systems are being implemented. In addition, it will provide a check on the
adequacy and effectiveness of the management arrangements and risk control systems
(RCSs).
Auditing is critical to a health and safety management system, but it is not a substitute for
other essential parts of the system. Companies need systems in place to manage cash flow
and pay the bills – this cannot be managed through an annual audit. In the same way,
health and safety needs to be managed on a day-to-day basis and for this organizations
need to have systems in place. A periodic audit will not achieve this. The aims of auditing
should be to establish that the three major components of a safety management system
are in place and operating effectively. It should show that:
✓ appropriate management arrangements are in place
✓ adequate risk control systems exist, are implemented, and consistent with the
hazard profile of the organization
✓ appropriate workplace precautions are in place.
Where the organization is spread over a number of sites, the management arrangements
linking the centre with the business units and sites should be covered by the audit. There
are a number of ways in which this can be achieved and some parts of the system do not
need auditing as often as others. For example, an audit to verify the implementation of
risk control systems would be made more frequently than a more overall audit of the
capability of the organization or of the management arrangements for health and safety.
Critical risk control systems, which control the principal hazards of the business, would
need to be audited more frequently. Where there are complex workplace precautions, it
may be necessary to undertake technical audits. An example would be chemical process
plant integrity and control systems.
A well-structured auditing programme will give a comprehensive picture of the
effectiveness of the health and safety management system in controlling risks. Such a
programme will indicate when and how each component part will be audited. Managers,
safety representatives and employees, working as a team, will effectively widen
involvement and cooperation needed to put together the programme and implement it.
The process of auditing involves:
✓ gathering information from all levels of an organization about the health and safety
management system
✓ making informed judgements about its adequacy and performance.

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8.10.2 Gathering information


Decisions will need to be made about the level and detail of the audit before starting to
gather information about the health and safety management of an organization. Auditing
involves sampling, so initially it is necessary to decide how much sampling is needed for
the assessment to be reliable. The type of audit and its complexity will relate to its
objectives and scope, to the size and complexity of the organization and to the length of
time that the existing health and safety management system has been in operation.
Information sources of interviewing people, looking at documents and checking physical
conditions are usually approached in the following order:

Preparatory work
✓ meet with relevant managers and employee representatives to discuss and agree
the objectives and scope of the audit
✓ gather and consider documentation
✓ prepare and agree the audit procedure with managers.
On-site
✓ interviewing
✓ review and assessment of additional documents
✓ observation of physical conditions and work activities.
Conclusion
✓ assemble the evidence
✓ evaluate the evidence
✓ write an audit report.

8.10.3 Making judgements


It is essential to start with a relevant standard or benchmark against which the adequacy
of a health and safety management system can be judged. If standards are not clear,
assessment cannot be reliable. Audit judgements should be informed by legal standards,
HSE guidance and applicable industry standards.
Auditing should not be seen as a fault-finding activity. It should make a valuable
contribution to the health and safety management system and to learning. It should
recognize achievement as well as highlight areas where more needs to be done.
Scoring systems can be used in auditing along with judgements and recommendations.
This can be seen as a useful way to compare sites or monitor progress over time. However,
there is no evidence that quantified results produce a more effective response than the use
of qualitative evidence. Indeed, the introduction of a scoring system can, have a negative
effect as it may encourage managers to place more emphasis on high scoring questions

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which may not be as relevant to the development of an effective health and safety
management system.
To achieve the best results, auditors should be competent people who are independent of
the area and of the activities being audited. External consultants can be used or staff from
other areas of the organization. An organization can use its own auditing system or one of
the proprietary systems on the market or, since it is unlikely that any ready made system
will provide a perfect fit, a combination of both. With any scheme, cost and benefits have
to be taken into account. Common problems include:
✓ systems which are too general in their approach. These may need considerable
work to make them fit the needs and risks of the organization
✓ systems which are too cumbersome for the size and culture of the organization
✓ scoring systems may conceal problems in underlying detail
✓ organizations may design their management system to gain maximum points
rather than using one which suits the needs and hazard profile of the business.

8.10.4 Performance review


When performance is reviewed, judgements are made about its adequacy and decisions
are taken about how and when to rectify problems. The feedback loop is needed by
organizations so that they can see whether the health and safety management system is
working as intended. The information for review of performance comes from audits of risk
control systems and workplace precautions, and from the measurement of activities. There
may be other influences, both internal and external, such as re-organization, new
legislation or changes in current good practice. These may result in the necessity to
redesign or change parts of the health and safety management system or to alter its
direction or objectives.
Performance standards need to be established which will identify the systems requiring
change, responsibilities, and completion dates. It is essential to feed back the information
about success and failure so that employees are motivated to maintain and improve
performance.
In a review, the following areas will need to be examined:
✓ the operation and maintenance of the existing system
✓ how the safety management system is designed, developed and installed to
accommodate changing circumstances.
Reviewing is a continuous process. It should be undertaken at different levels within the
organization. Responses will be needed as follows:
✓ by first-line supervisors or other managers to remedy failures to implement
workplace precautions which they observe in the course of routine activities
✓ to remedy sub-standard performance identified by active and reactive monitoring
✓ to the assessment of plans at individual, departmental, site, group or organizational
level

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✓ to the results of audits.


The frequency of review at each level should be decided upon by the organization and
reviewing activities should be devised which will suit the measuring and auditing activities.
The review will identify specific remedial actions which establish who is responsible for
implementation and set deadlines for completion.

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