“MSME and CGDs play a very important role in the growth of the nation.

For sustainable growth, the sector should also be socially responsible for its
stakeholders. Safety of its employees, visitors, customers and consumers is
very important for a socially responsible enterprise. The authors of this book
have very ably highlighted various facets of industrial and occupational
safety that an enterprise must address while carrying out its business. For the
success of a safety program in any organisation, there must be a commitment
of top management or owners, clearly defined safety policies and
procedures, training and awareness building drives and full dedication,
supportive behaviours and involvement of the workforce in the safety efforts
of the organisation. This book throws light on all of these essential elements.
I wish a great success to this work and I am sure it will be a very useful
read.”

Lalit Gabhane

Director General
National Safety Council of India
“Besides MAH industrial units there are large numbers of MSME and GCDs
which have potential to cause major accidents and disasters.Existing Factory
act and MSIHC

rules lay down safety mechanism for MAH units but does not address for the
MSMEs and GCDs.

Authors have very lucidly explain to build robust and successful safety
management system encompassing all the elements needed for perfect safety
mechanism”

Lt. Gen. (Dr) JR Bhardwaj

Formerly Member, National Disaster Management Authority, Govt of

India

Director General of Armed Forces Medical Services ( i)

“The handbook is very useful to the entities in MSME

and CGD Sectors to understand the Safety Management Systems governing

the respective sector at a single place. The statutory compliances are
mandatory for any entity for which the book provides guidance. A great
book to practitioners ”

M. V. Ravi Someswarudu,

Chief Executive Officer,

GAIL Gas Limited
Safety is not optional extra ! It is a business case for sustainable
organization. Safety Management Systems for MSMEs provide a key mantra
for organizational resilience and aids prosperity in the societies we live in.
Simplicity is the key for success and this aspect is well demonstrated by the
authors of the book.

Dr Mahesh Murthy, Senior Manager, SABIC, Saudi Arabia

Government is giving due attention to MSME and CGD industry to enhance

productivity and to increase gas consumption in Indian energy basket from
present 6.5 % to 15% by Yr 2025. This will require high standard of safety
in this sector. I knew all the three writers are having rich industry experience
and are expert in this field.

In present scenario, there is need to develop every work man as safety

person. This can be easily done by practising different techniques given in
this handbook. I am sure this book will leave permanent impact on the minds
of workman ( ii) and shall help in developing safety culture.
Dr Narendra Kumar
Ex- Managing Director, Indraprastha Gas Ltd.

I am very happy to know that three senior Industry professionals have come
together and shared their vast knowledge on the subject of “Safety
Management System”

through this book “How to set up a “Safety Management System” in 91

days!”

I am aware that many hardships prevails with MSMEs and CGDs to remain
competitive in the business. Good Safety is Good Business. This book shall
be very handy in implementing the Safety Management System, in a very
simple and cost effective way.

I strongly recommend this book to set up a good Safety Management System

in smaller organizations to create a safe work environment, instill work
confidence among the workforce, prevent safety incidents and achieve
increased productivity.”

Surendra Jagtap
Group HSE Head
L&T Hydrocarbon Engineering

The global pandemic has sensitized organizations on the need for resilient
and safe operational practices to protect lives, livelihood and facilities.
While this is a challenge in organizations of all sizes, it is particular
significant in small and medium enterprises who may not have the internal
resources and expertise to put in place “smart” safety ( iii) management
systems to address the challenge. This book distils the vast practical
experience of the authors and makes it a handy solution for enterprises who
need a no-nonsense time-bound road map for deployment of safety practices
in their organizations. The authors should be complimented for directing this
book at those who need it and at a time when it is most needed.
JC Sekar
Co-Founder & CEO
AcuiZen Technologies Singapore Pte. Ltd.
My compliments to you for this wonderful work. I’m sure the fraternity
would be benefited immensely, Also, this would set up pace for thinking in
right direction. Truly a professional work.

Kind Regards
Dr G C Misra
Former Director (Delhi Fire Services) I am extremely happy at the
publishing of this book specially curated for that industrial sector in our
country which matters the most. And considering the vast experience of the
authors in the industrial safety and their dedication to the subject, this book
promises to be a wonderful guide for the MSMEs and CGDs. If
implemented, these guidelines will definitely help in not only developing a
safe working environment, but also to boost the morale and productivity of
the workplace. My sincere congratulations to Dr S.P.Garg, Mr. K.K.Gupta
and Mr. Rajat Tewari for their endeavor, ( iv) and I strongly recommend
everyone in the industry to read this book. I’m sure it will help in altering the
mindset of the organizations towards safety, when they begin to appreciate
how “doable” it is to develop an effective Safety Management system for
themselves.

Hemant Sapra, President SAMA (Safety appliances manufacturer’s

association)

The book “How to build a ‘Safety Management System’

in 91 days” written by highly experienced professionals and practitioners,

will guide CGD companies and MSMEs to establish a robust mechanism,
which will not only help them in statutory compliances but to set up an
effective Safety management system, which would be a highly beneficial
investment in the long run.

H K Srivastava, Managing Director, Avantika gas Limited

“At Energos, Safety of our people matters as much as results. This book is
an excellent guide to imbibe the right safety practice within your company
culture. It also underscores the importance of leadership communication on
bringing safety at the core of everything you do in your business. Best
wishes!
Rajesh Solanki
Founder & CEO
Energos
( v)

“Great work done. This is needed for the Society from our fraternity.
Congratulations”.
Pranvendra Kumar Rao
(Former Director, U.P. Fire Service) President, Institution of Fire
Engineers (India)

"This book is very well researched and written, keeping in mind the
resources and needs of the MSMEs and CGDS

in the area of Safety. The simple, adaptive and implementable process will
be very useful for all who need to bring Safety into their workplace. I wish
the best of success to this book!
Shashi Shekhar
CEO- Camfil India

Good Safety Management Systems and Procedures can lead to greater

productivity, efficiency and savings. Is your safety management system as
effective as it could be? You will find answer to this question and many
more in this handbook - “How to set up a ‘Safety Management System’ in 91
days!”

This handbook will assist MSMEs and CGDs in developing an effective

Safety Management System and learning how to implement, improve, and
revitalize their safety practices.

It will be helpful to all concerned; to overcome the barriers they face and
increase the level of Safety in their companies and workplaces through
improved safety management and following the best safety practices
possible. Dr. R.K.Sharma, Head-Sustainability; India Glycols Ltd.

( vi)

Having spent more than four decades in the Hospitality Industry, I can truly
appreciate the relevance of this book. It brings a simple approach to Safety
for small organisations which do not have resources for elaborate and
expensive safety management systems. Congratulations to the authors for
writing on a very relevant topic for today's times."

Naveen Jain

Managing Director
Nouvelle Knowledge Services
Ex CEO, DUET Hotels

( vii)

HOW TO SET UP

SAFETY

MANAGEMENT SYSTEM

IN 91 DAYS

A Safety Management Handbook

for MSMEs and CGDs

Dr. S P Garg

K K Gupta
Rajat Tewari
Published By
Invincible Publishers
Published by
Invincible Publishers
201A, SAS Tower, Sector 38, Gurugram – 122003

Phone: +91-124-4034247, +91 9599667779

www.invinciblepublishers.com

Sales: Office No. 8, Street No. 19, Near Radha Madhav Mandir, Ansari
Road, Daryaganj. Delhi-110002

Phone: +91-11-40198405

Email: invinciblepublishers@gmail.com Although the publisher and the

author have made every effort to ensure that the information in this book
was correct at press time and while this publication is designed to provide
accurate information in regard to the subject matter covered, the publisher
and the author assume no responsibility for errors, inaccuracies, omissions,
or any other inconsistencies herein and hereby disclaim any liability to any
party for any loss, damage, or disruption caused by errors or omissions,
whether such errors or omissions result from negligence, accident, or any
other cause.

First edition – 2021

Copyright © 2021 by Dr. S P Garg, K K Gupta and Rajat Tewari ISBN: 978-
93-90542-06-2

All rights reserved.

The moral right of the author has been asserted.

This book or any portion thereof may not be reproduced or used in any
manner whatsoever without the express written permission of the author
except for the use of brief quotations in a book review of a scholarly journal.
This book is sold subject to the condition that it shall not, by way of trade or
otherwise, be lent, resold, hired out, or otherwise circulated, without the
publisher’s prior consent, in any form of binding or cover other than that in
which it is original y published.

Dedicated to:

All the Safety professionals working hard to keep others safe everyday

( xi)

Acknowledgement

Writing this book has been a labour of love, as Industrial Safety is a topic
close to our hearts. Our experience of the last four decades has shown us the
criticality of Safety and importance of inculcating it in every organisation
and worker, so that each worker and employee can go home safely at the end
of the day.

We would like to acknowledge the support of our families, who supported us

fully in this endeavour. Further, our colleagues and friends who spent time in
discussing the topic, adding their valuable feedback and helping us to
improve the quality of our humble offering.

Finally, we would like to acknowledge the learning that we have gained in

various roles in our organisations over the last four decades.

( xiii)
Foreword
( xv)

Preface

The MSME (Micro, Small and Medium Enterprises) market has been
growing at a rapid pace in India. Today there are more than 6.34 crore
MSMEs as per Annual Report 2019-20 of GOI Ministry of MSMEs, which
are further expected to clock a yearly growth of 10% in the next five years.

Similar is the story of CGDs (City Gas Distribution) companies in India.

Approximately 70% of India’s geographical areas getting covered by CGDs
to supply PNG

(Piped Natural Gas) and CNG (Compressed Natural Gas), after the tenth
round of bidding of different Geographical Areas by PNGRB (Petroleum
and Natural Gas Regulatory Board).

In the stiff competitive landscape, the MSMEs and CGDs struggle to sustain
a profitable business. They have relatively lesser funds and run their
businesses on faster turnarounds and frugality. Many of them have an
attitude of just maintaining compliance in the government led rules and
regulations. Whether it is in the space of HR, workplace environment or
Safety Management, these smaller enterprises try to just maintain the basic
norms as demanded by government or industry policy.

In this scenario, among others, “Safety” is usually found seriously

compromised in these organisations. First, the leadership generally do not
place “Safety” anywhere close to the high priority areas, what to talk about
considering it, as ( xix) core value. The basic assumption is that compliance
to safety regulations is sufficient to maintain “safety” at installations/

work places. Second, they may not have any/sufficient Safety professionals,
or if there is someone, they would not have the competency to develop a
proper “Safety Management System.”
Industrial accidents have been the largest reason for disability and deaths in
India. Every day, 47 factory workers are injured and three die in accidents.
Data from the Labour and Employment Ministry reveal that in three years
(2014-2016), 3,562 workers lost their lives while 51,124 were injured in
accidents that occurred in factories across the country.

Due to the relatively higher neglect and ignorance of Safety in the fast
growing MSME sector, it would stand out as the largest area of concern
related to Occupational Safety and Health.

Many of these smaller organisations are unable to jumpstart a Safety

program as they think it will require investment, people and time. The
worrying thought is that unless expensive consultants are not taken on board,
the right Safety system will not be implemented. This delays the process
while the risks and hazards keep multiplying as the organisation is growing.
The leaders do not know or realise that a Safety Management program is a
simple, common sensical and in-expensive initiative, if done smartly and
with the right context related to the workplace hazards and risks.

The consequences of not having a structured Safety Management System

can, at worst, be horrendous, causing ( xx)

fatalities, economic losses or legal issues. Ironically, though MSMEs and

some CGDs tend to neglect Safety issues, in case there is a serious accident
demanding time and resources, the organisation may not have the deep
pockets to survive them. Thus, it is more important for smaller organisations
to set up a useful Safety system, which would be a highly beneficial
investment in the long future.

The authors of the book “How to set up Safety management system in

91days” have engaged themselves with many MSMEs and CGDs, as part of
their years of experience and rich interaction, and felt the strong need for a
simple and effective process which can quickly build a Safety Management
system and protect the employees and co-workers and make it a sustainable
organisation.

This book talks about nine broad areas which are the building blocks of a
Safety Management System, keeping in mind the constraints of time, budget
and other resources of a MSME and CGD company. These areas are as
follows: a. Health and Safety Policy: This is the broad overall policy that
the management decides to build for ensuring optimal Health and Safety
System in the organisation.

b. Safety Management System (SMS): A SMS consisting of 12 Elements

has been recommended for this sector, to cover Safety aspects of entire
business, right from design stage to construction, commissioning, operation
and maintenance.

c. Standard Operating Procedure (SOP): There is always a need to write

down detailed Standard Operating ( xxi) Procedures(SOP) for all activities,
so as to avoid shortcuts and to achieve safe work completion. This includes
all the operational details, emergency procedures, all day-to-day procedures
including need of safety equipment and PPEs.

d. Safety Governance Mechanism: This is the overall structure of Safety

governance through various Leadership positions, committees and sub-
committees having top and middle level leadership involvement.

Structured mechanism ensures that there are regular reviews, flow of

communication, decision on action to be taken, approvals and progress on
Safety standards and Safety Management System.

e. Capturing best practices from other organisations: This is how the

organisation can learn from others and share knowledge for everyone to
become safer and to remain relevant with time.

f. BBS integration into the Organisation: How to bring in the concept of

BBS (Behaviour Based Safety) and integrate it into the organisation with
minimal disruption of work, to ensure demonstration of desired safe
behaviours.

g. Digitalisation of Safety Processes: What are the different digital tools

which could be useful for implementing safety processes in a relatively
smaller organisation. How would the organisation get true value out of the
investment, without overspending on the same?

( xxii)
h. Safety Leadership and Culture Building: Leadership plays a key role in
driving such cultural or strategic changes in the organisation. How would the
leaders behave and communicate to get a Safety culture in the organisation?
Communication is the ‘circulatory system’

of any organisation’s Cultural and decision-making process. If

communication is used effectively, it can transform the ‘Safety Culture’ of
the organisation.

i. Safety as a core value in the Mission and Vision statements: A core

value is different from just an organisational ‘priority.’ It is a central
perspective for the organisation and is inviolable. Every strategy or decision
is subordinate to the core values and needs to be aligned to them before
implementation. Having ‘Safety’ as a core value, ensures that over time the
organisation would achieve a matured approach to “Safety Management.”

A structured approach, which incorporates these nine aspects in a systematic

order, as detailed out by authors in the book, can quickly install a good and
effective Safety Management System for a MSME or CGD organisation in
91 days. This book helps the stakeholders to understand the key concepts
and focus on the practical aspects of setting up “Safety Management
System” in the organisation, creating safe work environment and reducing
the chances of undesired events of accidents/incidents. This way
organisations can benefit, in the long run, establishing a robust Safety
Management system, without burning a hole in the pocket.

We would like to thank all the Leaders and Safety Professionals whom we
met over the years and who shared ( xxiii)

their real-life situations, challenges and practical suggestions to solve the

Safety issues. This book is dedicated to them.

References:

1. https://www.livemint.com/news/india/msmes-the-growth-engines-of-the-
indian-economy-11597923225239.html 2.
https://ijaems.com/upload_images/issue_files/5-IJAEMS-JUL-2018-9-
GrowthandFuture.pdf 3. https://www.cii.in/Sectors.aspx?
enc=prvePUj2bdMtgTmvPwvisY

H+5EnGjyGXO9h LECvTuNuXK6QP3tp4gPGuPr/xpT2f 4.
conomictimes.indiatimes.com/small-biz/sme-sector/msme-sector-poised-for-
mega-transformation-in-2020/articleshow/73028478.

cms?from=mdr

5. https://www.thehindu.com/data/industrial-accidents-claimed-over-6300-
lives-between-2014-and-2017/article32040544.ece 6.
https://thewire.in/labour/labour-law-reforms-industrial-accidents) ( xxiv)

Contents

Acknowledgement

xiii

Foreword

xv
Preface
xix
Chapter 1: Introduction
1

Chapter 2: Evolution of Safety Management System 5

Chapter 3: Safety Policy (7 days)

20

Chapter 4: Safety Management System (7 days) 32

Chapter 5: SOP for SMS and Awareness 85

(21 days+ 8 days)

Chapter 6: Setting up the Safety Governance 95

Mechanism (7 days)

Chapter 7: BBS Integration into the Organisation 105

(7 days)

Chapter 8: Digitalisation of Safety Processes (7 days) 128

Chapter 9: Safety Culture and Leadership (15 days) 138

Chapter 10: Safety as a Core value (5 days) 162

Chapter 11: Communication to drive a Safety Culture 175

(7 days)
Chapter 12: Conclusion
182

Annexures

185

( xxv)

Introduction

Chapter 1:
Introduction
“A Stitch in time saves nine”

Having “Safety Management System” is an essential requirement to operate

Industries in an optimal manner, so as to get best of efficiency and
productivity, leading to sustainable operations and profits. Every industry
has inherent hazards, which are required to be understood, risks identified in
a systematic manner and recorded, thereafter measures and resources are
required to be deployed, to mitigate those risks which exist in the system.
Experts knowledgeable on the subject of Safety Management System, should
become part of the Operation, Maintenance and Project teams to strategize,
plan, monitor and mitigate the risks, bringing down the same to the ALARP,
as low as reasonably practicable levels, for ensuring safe operations.

What is Safety management system? It is one of the management systems to

handle all Safety related issues 1

How to Set Up Safety Management System in 91 Days in a structured

manner, as per the Safety Policy of the organisation. It may have many
elements defined as part of the Safety management system, so as to
strategize, implement and monitor all activities related to different business
verticals, which have varied degree of risks involved, at different stages.
Generally, one writes objective of each defined element, its purpose and
management technique, to elaborate on the subject. Each element has certain
numbers of Standard Operating procedures, work instructions, and
implementation formats associated with that element. An effective “Safety
Management System” provides enough signals and warnings, so as to
initiate corrective measures, to prevent major incidents and to eliminate or
mitigate their consequences, if at all they happen. The “Safety Management
System” puts emphasis on the application of management controls to take
care of the risks associated with construction, operation and maintenance
and supports empowerment of employees in preventive activities and
monitoring implementation of safe work practices for continual
improvement in performance.
Industries operating without any structured Safety Management System,
may face surprises in the form of accidents, incidents, fires, explosions, etc.
leading to injuries and fatalities, in addition to property loss and outage of
production. Such surprises bring a lot of discomfort and at times, shock to
the management, since they were not prepared to handle such situations.
Accidents and incidents bring down morale of the work force to a large
extent, besides direct losses of lives and property. Lower morale affects
production badly. Sometimes, it leads to shut down of facilities, due to
commotion and agitation amongst workers 2

Introduction

on account of loss of life, inadequate compensation, unsafe working

conditions or poor management response to such situations, due to
unsatisfactory preparedness.

Safety Leadership

and Culture Building

Communication

Capturing best

practices from

other
organizations
Standard Operating

Procedure (SOP)

Safety Governance

Mechanism

Digitalization of Safety

Processes

BBS integration into

the Organization

Safety Management System (SMS)

Health and Safety Policy

Safety as a core value
The overall structure of the Safety Management system can be explained by
the above figure.

The supporting foundation: The SMS structure is based on the following

‘foundations’ which ensure strength and sustainability:

a. Health and Safety Policy

b. Safety as a core value

The pillars of the Safety Management System are the following areas:

a. Safety Governance Mechanism

b. Standard Operating Procedures

c. Digitalisation of the Safety procedures d. BBS integration into the

organisation.

How to Set Up Safety Management System in 91 Days A critical area would

be to continually take best practices from other organisations and keep
improving the SMS

structure.
The whole structure is driven by the leadership demonstrated by building
and sustaining a Safety Culture.

We would be going through each of these areas in the book to explain how
they help in setting up the Safety Management System.

As the dear reader may note, against each Chapter heading, no. of days have
been mentioned in the bracket.

Authors have tried to recommend adequate time- frame for taking-up each
activity proposed in the book, for achieving a goal of setting up an effective
“Safety Management System”

in an organization within 91 days. In case, the reader wishes to spend more

time on any specific activity, beyond the suggested timeline in the book, one
is welcome to do so. It would definitely strengthen the process.

The idea behind suggesting these time lines was also to advice readers about
varied time periods required against the activities. e.g. writing down “Safety
Policy” may take 7 days time but writing down SOPs for various operation
& maintenance activities may take 21 days, a long drawn process. Further,
building awareness on SOPs amongst employees and contract workers may
require another 8 days time. Accordingly, timelines have been suggested.

4
Evolution of Safety Management Systems Chapter 2:

Evolution of Safety
Management Systems
“An Accident is just the tip of the iceberg… a sign of a much larger problem
below the surface” – Don Brown In order to successfully design and manage
an effective Safety Management System, it is necessary to understand what
causes the accident. During the early industrial revolution, workers who
were injured in factories, so reasoned factory managers, were hurt because
they weren’t “careful.” That was a comfortable approach for managers to
take because it was obviously unnecessary for them to do anything about
accidents since it was believed that it is up to the people to protect
themselves. Accidents were considered a natural side effect of production
and there was no need to worry about them since as everyone knew, there
was no way to change human nature- “people always had been and always
would be careless”.

How to Set Up Safety Management System in 91 Days A natural side

“Acts of

effect fo production

God”

Accidents

“The

People

number is

errors

up” approach
“Carelessness”
HEINRICH DOMINO THEORY OF ACCIDENT
CAUSATION:

Heinrich was the pioneer in the Accident causation theories. He described

the accidents causation theory, man and machine relationship, frequency and
severity relation, unsafe acts reasons, management role in accident
prevention, costs of accidents and the impact of safety on efficiency.

According to statistics on accident’s reports, Heinrich deduced that 88

percent of accidents are due to unsafe act of workers, 10 percent due to
unsafe conditions, and 2 percent of all accidents are associated with act of
God such as natural disasters. According to his analysis, Heinrich defined
accident as ‘an unplanned and uncontrolled event in which the action or
reaction of an object, substance, person, or radiation results in personal
injury or the probability thereof.’ Heinrich (1959) described the accidents
causation theory, man and machine relationship, frequency and severity
relation, unsafe acts reasons, management role in accident prevention, costs
of accidents and the impact of safety on efficiency.

6
Evolution of Safety Management Systems Act

Unsafe

Accident

Injury

Fauk of Person

Social Environment

Timeline

Social

Fault of the

Unsafe Act

Environment

person

or

Accident

Injury
and Ancestry

Carelessness

Condition

Multiple Causation Model (Petersen, 1971; Non-Domino-Based Model):

The Heinrich domino theory is structured on the theory that an accident is

caused by a single cause. Petersen (1971) developed a model based on
management system rather than individual. Petersen believed that there are
two major features of the events which lead to an accident, namely an unsafe
act and an unsafe condition. However, there are more than single cause
which contribute or lead to both unsafe act and unsafe condition and finally
occurrence of an accident. Unlike the simplified theory of domino, there are
causes and sub-causes when an accident happens. Through identification of
these multiple contributing causes of accident, the unsafe acts and unsafe
conditions should be prevented from arising.

Sub-causes

Cause A

Cause B

Unsafe act

Injury

Cause C

Accident

Damage

Cause D

Cause E
Unsafe condition

Near miss

Cause F

How to Set Up Safety Management System in 91 Days Updated Domino

Sequence (Bird, 1974; Domino-Based Model) Bird and Loftus (1974)
updated the “Domino theory”

in order to reflect the role of management system in the sequence of accident

causes defined by Heinrich (Domino-based model). The updated and
modified sequence of events is:

Lack of control/management (inadequate program, inadequate program

standard, inadequate compliance to standard)

Basic causes/origins (basic causes: 1-personal factors, 2-job factors)

Immediate causes/Symptoms (sub-standard act and condition)

Incident (contact with energy and substance) O

Loss (property, people, process)

The updated domino sequence can be used and applied to all types of
accidents and is fundamental in loss control management.

Lack of Contro

(Management)

Incident (Contact)

Immediate Causes

(Symptoms

Basic Causes (Origins)

People-Property (Loss)

Evolution of Safety Management Systems Behaviour Models:

Behaviour models blame humans for occurrence of accidents. Errors in this

approach are likely to be done by humans in different environmental
conditions. Humans are blamed just for their unsafe behaviour. Rigby (1970)
defined human error as ‘anyone set of human actions that exceed some limit
of acceptability.’ Behaviour models are mostly based on the accident
proneness theory indicating that some people have specific characteristics
which make them more susceptible of having accidents. Many behaviour
models have been developed by researchers in order to describe the reasons
for accidents repeaters such as the ‘Goals freedom alertness theory’ (Kerr
1957) and the ‘Motivation reward satisfaction model’ (Petersen 1975).

Ferrel Theory:
Doctor Russel Ferrel (1997) developed his theory of accidents based on a
chain of human factor causes. He believed that the human errors are the
main causes of accidents occurrence and they are caused by the following
factors:

Overload; the overload factor reflects the incompatibility between the load
and the capability of the human. The result of this mismatch is anxiety,
pressure, fatigue and emotions that can be intensified by physical
environment such as dust, light, noise, fumes, etc. where the person is
working.

Incorrect response; the incorrect response by the person is caused by the

incompatible situation where he/she is 9

How to Set Up Safety Management System in 91 Days working in.

O
Improper activity; the person performs the activity improperly either due to
lack of knowledge of appropriate way of performing the activity, or
intentionally taking the risk.

The ‘Swiss Cheese’ Model:

Reason’s early work in the field of psychological error mechanisms was

important in this discussion on complexity of accident causation. By
analysing everyday slips and lapses, he developed models of human error
mechanism. Reason went on to address the issue of two kinds of error:
Active Errors and Latent Errors. Active errors were those ‘where the effect is
felt almost immediately’ and latent errors ‘tended to lie dormant in the
system largely undetected until they combined with other factors to breach
system defenses.’ In the Swiss cheese model, an organisation’s defenses
against failure are modelled as a series of barriers, represented as slices of
cheese. The holes in the slices represent weaknesses in individual parts of
the system and are continually varying in size and position across the slices.

10

Evolution of Safety Management Systems Defenses

The Swiss Cheese Model of
DANGER

Losses
Accident Causation
Hazards

Some holes due

to active failures

Hazards

Causes

Latent

condition

Unsafe acts

Investigation

Other holes due to

pathways

Losses

latent conditions

Local workplace factors

Successive layers of defenses,

barriers, & Safegaurds

Organizational factors
Swiss Cheese Model
The Swiss cheese model of accident causation is a model used in risk
analysis and risk management, including aviation safety, engineering,
healthcare, emergency service organisations, and as the principle behind
layered security, as used in computer security and defense in depth.

The Safety Management Theory and Application “Mark II model” was

developed by James Reason in the early to mid-1990s. Through a construct,
James Reason described co-relation of three different factors: the
organisation, workplace/condition/environment and person or individual in a
‘Safety Management System,’ as shown below: Reason: A later variant
Organization

Workplace

Person

Defences

Management

Error

decisions

producing

Errors

Organizational

conditions

processes

Corporate
Violation

culture, etc.

producing

Violations

conditions

Latent failure pathway

11

PDCA Cycle

How to Set Up Safety Management System in 91 Days The organisation

‘box’ included “Corporate culture,”

“Organisational processes” as well as “Management decision.”

This was a time when the impact of ‘Safety Culture’ was becoming more
and more evident. The model described that no single failure, ‘human’ or
‘technical,’ was sufficient to cause an accident. Rather, it involved the
unlikely and often unforeseeable conjunction of several contributing factors
arising from different levels of the system. The theory given by James
Reason became very popular and seemed relevant in all aspects of business,
at all times.

Prof. Patrick Hudson (2003) in his research study aims to examine briefly
the history of safety management system.

N. McDonald, S. Corrigan, C. Daly & S. Cromie (2000) in their research

described a self-regulatory model to examine how organisation manages
“safety” with particular emphasis on organisational and human aspects.
Safety policy, safety standards, planning and organisation of work, normal
operating practices, monitoring, feedback and changes are seven integral
elements of the model, which sought to integrate the main features of a
safety management system, developed as a practical guide for management
and an effective tool to analyse salient features of an organisation’s Safety
Management System.

Kathryn Mearns, Sean Whitaker, RhonaFlin, Rachael Gordon and Paul

O’Connor (2003), in their paper focused on ‘Human Factors into Safety.’
The overall aim of the project was to understand human and organisational
factors in safety, continual improvements in safety, and improved safety
culture. They suggested establishing effective incident/

12

Evolution of Safety Management Systems accident reporting system to

improve accident analysis and to learn from previous incidents, taking
account of Human Factor.

Dr. R. Karuppasamy & C. Arul Venkadesh (2011) described about safety

management system and implementation methods in their paper. They
further elaborated on 11 fundamental attributes which includes SMS
Management Plan, Safety Promotion, Document and Data Information
Management, Hazard Identification and Risk Management, Occurrence and
Hazard Reporting, Occurrence Investigation and Analysis, Safety Assurance
Oversight Programs, Safety Management Training Requirements,
Management of Changes, Emergency Preparedness and Response,
Performance Measurement and Continuous Improvement.

A M Makin & C Winder (2007) provided a new conceptual framework to

improve the application of occupational health and safety management
system. They described application of Safe System, Safe Place & Safe
Person as a systematic approach to safety.

Later, a generic “Safety Management System” was also established based on

the PDCA cycle. When applied to OHS,

“Plan” involves the setting up of an OHS policy, planning including the

allocation of resources, provision of skills and organisation of the system,
hazard identification and risk assessment. The “Do” step refers to actual
implementation and operation of OHS plan. The “Check” step is devoted to
measuring both the active and reactive performance. Finally, the “Act” step
closes the cycle with a review of the system 13

How to Set Up Safety Management System in 91 Days in context of

continual improvement and the priming of the system for the next cycle.

Act

Revie Management

Pla

Performanc

Measuremen

&

ID t

Safety Leadership

Ass’

Audit

Hazar

y
&

Risk

Evaluation

Monitorin

Reglator

Compliance

VISION

Incident

Planning

PRINCIPLES

Management

ACTION

System

Train

ing,

wareness,

Compelence
Employe

Coordinatio

Contractors

Involvemen

of

Document

Contro

Emergenc

Preparednes

Response

&

OperationalControls
PDCA Cycle
The first safety management system applications were based on the
Occupational Health and Safety Management System (BS 8800) and the
Dutch Safety Checklist for Contractors (SCC) Standard. In addition, the
International Labour Organisation (ILO) published instructions on
Occupational Health and Safety Systems (ILO OHS 2001).

In India, OISD Standard 206 on “Safety Management System” came up in

the year 2001. Safety Management System is correlated with various other
Systems like Integrity Management System, Quality Management System
and Risk Management System, etc. which have the focus on minimization of
risks to the organisation.

Safety Management System as per OISD: The Ministry of Petroleum and

Natural Gas technical 14

Evolution of Safety Management Systems arm, Oil Industry Safety

Directorate, OISD writes technical standards pertaining to various
Operations, Maintenance, construction, layout, management, etc. for entire
Oil and Gas sector in India. One of the standards is dedicated to the
guidelines on Safety Management System, called OISD

STD 206. As per the standard, there should be following elements in a

Safety management system of an organisation: 1. Safety Organisation

2. Employees Participation

3. Process Safety Information

4. Process Hazard Analysis

5. Operating Procedures

6. Training

7. Contractors

8. Pre-Start up Safety Review

9. Mechanical Integrity

10. Work Permit

11. Management of Change

12. Incident Investigation and Analysis 13. Emergency Planning and

Response

14. Compliance Audit

15. Occupational Health

16. Off-the job Safety

17. Customers and Products

15

How to Set Up Safety Management System in 91 Days 18. Road

Transportation

19. Trade Secrets

However, based on our experience, we recommend that in a newly

established CGD or MSME organisation, one could have following elements
in the Safety Management System:

1. Leadership and Commitment

2. Employees/Workers Engagement

3. Standard Operating Procedures

4. Work Permit System

5. Pipeline/Plant Integrity Management 6. Pre-start up review

7. Management of Change

8. Emergency Planning and response

9. Training

10. Occupational Health

11. Environment management

12. Compliance audits

Against each element one should write down Scope, Objective and
Procedure. It should be clearly written down, that what were the
expectations/objective of having particular ‘element?’ For example, while
detailing down the element ‘Pipeline/Plant Integrity Management,’ it was
very obvious that at all times, it was intended to maintain the 16

Evolution of Safety Management Systems Integrity of a particular Pipeline

or Plant/Facility. For that purpose, various maintenance philosophies or
procedures need to be spelt out. One must have Preventive and Predictive
Maintenance policies, instead of only having Breakdown policies, which
could be very costly, at times.

In case of a cross-country Pipeline, the ‘Integrity management’ takes a still

bigger role, as the integrity of entire length of the pipeline is necessary to
meet the intended purpose of safe transportation of the intended
hydrocarbons.

As such, very elaborate planning and resource allocation and layout are
necessary. In fact, in case of Hydrocarbon Pipelines there is regulatory
requirement to have such ‘Integrity management plan’ in place and to seek
regulatory authority approval for the same.
Pipeline Threats
Defective pipe seam

External corrasion

Defective pite

Time Dependent

Internal corrasion

Stress corrasion cracking

Manufacturing related defects

Stable

Welding/fabrication related

Equipment

Third party/mechanical

damage

Time Independent

Incorrect operational

procedure

Weather/related and outside

force

Besides the above, certain other threats may be applicable based upon the
land pattern i. Creek area effects ii Muddy land effects & iii. River bed
movements 17

How to Set Up Safety Management System in 91 Days Integrity

Management Tools

Inline Inspection

Cathodic Protection

Surveillance

Pigging

Direct Assessment &

Evaluations

Pressure Testing

Thickness Assessment

and Periodic Reviews

References for this chapter:

Heinrich, (1959): Domino theory of accident causation O James Reason,

(1999): Achieving a Safe Culture: theory and practice.

O J Reason, (2004): Beyond the organisational accident: the need for

‘ error wisdom’’ on the frontline

O Autro Kuuusisto (2000); Safety Management System – Audit tool and

reliability of auditing.

O A.M. Makin, C. Winder (2007): A new conceptual framework to improve

the application of occupational health and safety management systems

O Dr. R Karuppasamy, Mr. C Arul Venkadesh (2012): Mitigation Strategies

for Safety Management

O Dr. R Karuppasamy, Mr. C Arul Venkadesh (2011): Safety Management

Systems (SMS) and its Implications O Dr. R Karuppasamy, Mr. C Arul
Venkadesh (2011): Safety Management Measures in India for Major Threats
and Hazards 18

Evolution of Safety Management Systems O Kathryn Mearns, Sean M.

Whitaker, Rhona Flin (2003): Safety climate, safety management practice
and safety performance in offshore environments

O N. McDonald *, S. Corrigan, C. Daly, S. Cromie (2000): Safety

Management Systems and Safety Culture in aircraft maintenance
organisations.

O Prof. Patrock Hudson (2009): Safety Management and Safety Culture –

The Long, Hard and Winding Road.

O Standards from Oil Industry Safety Directorate, http://oisd.nic.in/

index.htm#

O Petersen,(1971): Non domino based model O Bird and Loftus,(1974) :

Updated Domino Sequence O Kerr,(1957): Goals freedom alertness theory
O Petersen,(1975) : Motivation reward satisfaction model O Doctor Russel
Ferrel,(1997) : Ferrel Theory O Regulations of Petroleum & Natural Gas
Regulatory Board, www.

pngrb.gov.in

O Dr S.P.Garg,(2019) : Study of Safety management system of GPUs and

Refineries in India

19
How to Set Up Safety Management System in 91 Days Chapter 3:
Safety Policy
(7 days)

“Our Goals can only be reached through the vehicle of a plan.. there is no
other way to success” – Pablo Picasso In any organisation, the main driving
force is top management. It is therefore imperative that top management has
to make Safety Policy commensurate with activities related to the business,
implement the same and monitor its effectiveness and take accountability
with appropriate steps to maintain it in all the activities. Often HSE (Health,
Safety and Environment policy) and Safety policy are interchangeably used
conveying same connotation.

Normally the Safety policy should contain and commit the following:

People join the organisations for earning their livelihood.

So the top management commitment is essential starting point to provide

safe and healthy work environment to avoid any injury or illness to the
people.

20

Safety Policy (7 days) O

All business operations and decisions should consider

“safety” as value as an integral part.

Commitment that all legal requirements of the law of the land will be met.
O

To ensure that hazard and risk assessment is done and all steps are taken to
eliminate/minimize the safety risks.

To ensure involvement of all the concerned workers’

representatives while carrying out above assessments.

Feedback mechanism ensures continual improvements.

So management must ensure that feedback of all concerned is taken from

time to time in a structured manner to meet this objective.

Management must ensure to create awareness, impart knowledge, skill and

ability for appropriate outcome commensurate with Safety policy.

Safety policy must be communicated to all concerned like employees,

outsourced agencies, customers, all agencies, etc. Steps should be taken to
influence/ impact them to adopt the company’s safety policy and practices.
O

Safety policy of the company should be approved by the highest authority.

Safety policy of the company should be available in public domain.

Management needs to mention this aspect in the annual report of the
company.

Safety policies of some organisations picked up from public domain are

given below for reference: 21

How to Set Up Safety Management System in 91 Days

Safety, Health & Environment Policy of Indian Oil Corporation Ltd.:

Indian Oil Corporation is committed to conduct business with strong

environment conscience ensuring sustainable development, safe workplaces
and enrichment of quality of life of Employees, Customers and the
Community.

We, at Indian Oil, believe that good Safety, Health & Environment (SH&E)
performance is an integral part of efficient and profitable business
management. We shall: X

Establish and maintain good standards for safety of the people, the processes
and the assets.

Comply with all Rules and Regulations on Safety, Occupational Health and
Environmental Protection.
X

Plan, design, operate and maintain all facilities, processes and procedures to
secure sustained SH&E Protection.

Remain trained, equipped and ready for effective and prompt response to
accidents and emergencies.

Welcome audit of our SH&E conduct by external body, so that stakeholder

confidence is safeguarded.

Adopt and promote industry best practices to avert accidents and improve
our S, H&E performance.

Remain committed to be a leader in Safety, Occupational Health and

Environment Protection through continuing improvement.

Make efforts to preserve ecological balance and heritage.

22
Safety Policy (7 days)

Safety, Health & Environment Policy of Reliance Industrial

Infrastructure Limited (RIIL): (Reference: http://www.riil.in/pdf/health-
safety-and-environment-policy.pdf) 23
How to Set Up Safety Management System in 91 Days

Safety, Health & Environment Policy of GAIL

(India) Ltd.:

(Reference: 1. https://gailcgd.gail.co.in/CGD/pdf/HSE-Policy.pdf?AspxA
utoDetectCookieSupport=1

2. https://gailcgd.gail.co.in/CGD/entry/HSE_Policy) 24

Safety Policy (7 days)

Safety, Health & Environment Policy of Bharat Petroleum Corporation

Limited (BPCL): Together, we have the highest concern and commitment
for protecting the Health and Safety of all employees, contractors, customers
and the communities in which we operate and for conservation of the
Environment.

(a) We will comply with all Statutory Regulations and may even go beyond
these for the benefit of our environment.

(b) We consider Health, Safety and Environmental aspects are an integral

part of our business planning and operation processes.

POLICY

Based on these guiding principles, we shall Demonstrate our commitment

by:
X

Providing and maintaining safe facilities and working conditions.

Recognising that all employees have responsibility for their own safety and
actions which could affect the safety of others.

Adoption of appropriate technologies to minimise the impact of our

activities on the Environment.

Establish clear Objectives and Targets to: X

Improve continuously for prevention of accidents occupational illnesses and

minimizing any impact of our activities on the environment.

25

How to Set Up Safety Management System in 91 Days X

Promote learning through training and sharing of experiences and best

practices; including with contractors, customers and the public, wherever
required.

Inculcate values and attitudes conducive to achieve excellence in Health,

Safety and Environmental performance.

Provide means to achieve our mission by: X

Assigning clear roles and responsibilities at all levels and periodically
reviewing and recognising contribution to HSE objectives.

Allocating adequate resources.

Fostering a spirit of participation by all employees in Health, Safety and

Environmental conservation efforts.

Creating appropriate forums for deliberations on Health, Safety and

Environmental issues.

Monitor performance by:

Periodically auditing work processes, systems practices and promptly

correcting deficiencies.

Incorporating HSE performance as a parameter for assessing the overall

performance of Employees, Business Units, Contractors and Business
Associates.
(Reference: https://www.bharatpetroleum.com/health-safety-security.

aspx)

26

Safety Policy (7 days)

Safety, Health & Environment Policy of Indraprastha Gas Limited:

The management accepts the responsibility for safety, Health, and

environment management of the company.

The subject being a line responsibility, every employee has been made
responsible and accountable for the protection of Safety, Health, and
Environment. The policy of company is as follows:

To give top most priority to safety & health of all the personnel, property
and protect environment.

To follow all applicable codes, standards and safety practices in design,

operation, maintenance and modifications to ensure HSE protection.

All planning, decisions and actions confirm our commitment towards safety,
health and environment protection aspects.
X

Safety audit is carried out yearly and the findings are documented for follow
up actions so as to restore safe condition.

Each employee is fully informed for strict compliance of safety orders/rules

issued by the management.

Health checks of each employee and done annually.

To train all employees in their respective areas of activities.

Engineer-in-charges of projects ensure compliance of safety orders/rules and

statutory requirements by 27

How to Set Up Safety Management System in 91 Days contractor,

transporters, visitors and other agencies related to contracts.

X
Environment aspect audit once in a year, con-firmatory and observation
redressed immediately.

Emergency drills are conducted every six months.

Each employee is to abstain from unsafe acts and prevent unsafe conditions.

It is compulsory for all the employees to take active part on safety, health &
environment related activities on and off the job. Compliance of observation
is done in most effective manner.

To ensure compliance of work permit system.

Use of personnel protective equipment is compulsory while at work.

Quality maintained in all areas of activities.

X

To adopt such systems and methods so as to ensure continual improvement.

Management ensures that efforts of each employee are directed to contribute

for achieving excellence in safety, health, environment, quality and
productivity.

(Reference: https://iglonline.net/english/Default.aspx?option=article&type

=single&id=71&mnuid=169&prvtyp=site).

28
Safety Policy (7 days)

Safety, Health & Environment Policy of Tata Consultancy Services:

29
How to Set Up Safety Management System in 91 Days (Reference: 1.
https://tcsbi.com/wp-content/uploads/Work-Health-Safety-Policy_TCS-
BI.pdf

2. https://www.tcs.com/content/dam/tcs/pdf/discover-tcs/corporate-
sustainability/Occupational-Health-and-Safety-Policy.pdf) 30
Safety Policy (7 days)

Safety, Health & Environment Policy of PACT

Construction:

(Reference: https://www.pactconstruction.com.au/app/uploads/ 2019/ 07/

Occupational-Health-and-Safety-Policy.pdf) 31

How to Set Up Safety Management System in 91 Days Chapter 4:

Safety Management
Systems (7 days)

“It does not help to leave a live dragon out of your calculations, if you live
near one.” – JRR Tolkien An effective Safety Management System helps in
identifying and preventing hazards, incidents and eliminating or mitigating
their consequences. It is well known that employees get exposed to various
kinds of hazards in their workplace on a day-to-day basis.

Therefore, it is vital for an organisation to effectively manage Safety of all

their workforce through a well-defined Safety Management System. The
cost of any incident or plant interruption is very high in an economic
environment of rising cost of various inputs to the industry, in the form of
man, material, machine, increasing cost of health care and stringent
environmental regulations.

To meet this objective, the organisation should have Standard Operating

Procedures (SOPs) in the system, which 32

Safety Management Systems (7 days) should necessarily be followed by all

the workforce. Any change in the system should be authorised by a
competent person in hierarchy.

The following elements form the basic requirements of a good safety

Management System:

Element 1: Leadership and Commitment.

Element 2: Employees/Workers Engagement.

Element 3: Standard Operating Procedures (SOPs).

Element 4: Work Permit System.

Element 5: Pipeline/Plant Integrity Management.

Element 6: Pre-start up review.

Element 7: Management of Change.

Element 8: Emergency Planning and response.

Element 9: Training.

Element 10: Occupational Health.

Element 11: Environment Management.

Element 12: Compliance Audits.

Let us explore importance of these elements one by one:

Element 1: Leadership and Commitment

Leadership and its commitment plays an important/

pivotal role in shaping the safety culture in the organisation and its continual
improvement. Leadership must address all internal and external stakeholders
and provide all resources and conducive environment for implementing
safety policy of the organisation.

Leadership focuses on sound and integrated planning, implemented

systematically and ensures carrying out 33

How to Set Up Safety Management System in 91 Days regular assessments

and proper implementation of learning points for improving the safety
management system. Important points in this regard are as under: a)
Formulation of Safety Policy reflecting management commitment towards
Safety during various construction, operation and maintenance activities.
b) Safety policy of the company should be approved by the highest authority.

c) Accountability should be built by assigning roles/

responsibilities to all concerned.

d) Structured safety management review through various committees.

e) Take command. Lead by example and demonstrate following of all safety

practices envisaged in safety management system.

f) Create a climate of trust encouraging 2-way communication, controlling

safety risks, encouraging people to follow safety practices, encourage
reporting of unsafe behaviours/unsafe conditions, near miss incidents, safety
suggestions, ensure practice of Job safety analysis, Tool Box Talks before
start of work, etc.

g) Give empowerment to the people to stop any activity which is unsafe to

carry out and address the safety issues with a win-win solution.

h) Give time to your people and listen to them attentively to

understand/solve their safety concerns.

i) All safety communications should cover “Why the particular activity is to

be carried out, How it should be 34
Safety Management Systems (7 days) carried out and What the company
wants to achieve.”

j) Ensure that hazard assessment/risk analysis is carried out for all

construction, operation, maintenance and associated activities and conveyed
to all concerned.

Necessary training and skill development should be ensured in order to

achieve desired outcome on safety.

k) Ensure that all legal and statutory requirements are complied.

l) Conduct surprise safety visits as required. Also ensure verification and

validation of all safety suggestions implemented.

m) Ensure participation of workforce representatives in various safety

programs/committees.

n) All incidents must be investigated in a time bound manner and all lessons
learnt should be shared/

implemented.

o) Ensure continual improvement in safety management system to contribute

to improving quality of life of the work force.

An incident:
The incident relates to a heavy rainfall that happened in Mumbai on 26th
July 2005 which recorded 944 mm rainfall in 24 hours. This was an
unprecedented rain which flooded entire Mumbai and all the life came to a
standstill. One of the authors of this book was posted as GM (Quality
Control and Safety & Environment) in Marketing Division of IndianOil
Corporation Ltd.

Office located at Bandra (East) in Mumbai. Since the water level and water
flow/current was high, employees 35

How to Set Up Safety Management System in 91 Days of most of the

offices/installations stayed back overnight where they were and hoped to
venture out next day on foot amidst knee/waist deep water in restricted way
to their homes. The marketing division 9 –storey Highrise building came to
stand still. In such high-rise buildings, the deep basement of the building has
a large area where the facilities like drinking water system, fire water system
with all related facilities, sewage water treatment plant, air-conditioning
system with all associated facilities, telecommunication system are set up.
Additionally, large number of cars were parked and also a lot of records of
various departments were stored there. This basement got filled with water
and all these facilities set up remained submerged in water for about 4 days.
The water from the basement was evacuated by deploying powerful pumps
procured from Navy. The electric sub-station on ground floor had to be shut
down as its bus bars located towards ground had got submerged in water. All
basement chambers of the lifts were also full of water. No lifts/electric
supply/

drinking water, etc. were available in the office building deploying over 450
people. It was a new challenging situation where the office building was to
be made functional in a time bound manner with all safety precautions. The
author was made team leader for this project by Director (Marketing). In
short the following activities were carried out to make this office building
operational again:

Made a detailed plan with work breakdown structure, sequencing various

activities including manpower planning involving executives, non-36
Safety Management Systems (7 days) executives, out sourced agencies,
limited manpower as available, all materials requirements keeping in view
that entire Mumbai was facing difficulty in getting these resources.

Carried out Hazard Identification and Risk Assessment, Mitigation

measures, Awareness among all involved; accidental electrocution was one
of the major hazards.

Ensured positive electric isolation of all facilities and equipment.

Cleaning mud deposits in basement floor, walls, roof, all equipment, things
with high pressure water jet and Cleaning with disinfectants.

Switched on electrical power after ensuring healthy working of earth leakage

protection breakers, ensured avoidance of joints or properly insulated joints,
an exclusive team was monitoring all such joints in temporary supplies
required for various jobs e.g. large numbers of halogen lamps were deployed
for drying wet surfaces in the basement and various equipment, megger,
testing of all cables/breakers after drying & cleaning, LT bus bars were
specially opened at all joints, cleaned and reassembled all equipment as per
requirements, all LT motors were sent for drying in the electric oven for
removal of moisture from the windings for insulation improvement to make
them operational.
X

It was worth noting that few fittings of IP65 rating which were installed for
some control circuits had their circuits in neat and clean position as they
were found properly closed.

37

How to Set Up Safety Management System in 91 Days X

Sequentially first electric sub-station was restored after thorough checking,

then electric supply to the building was resumed, then water supply, then
sewage system, then fire water system, parallelly air-conditioning system,
and electric lifts.

Telecommunication system was irreparable, so a new one installed on

ground floor.

All restorable records were kept safe at other place, about 70 cars in the
basement which remained submerged in water for 4 days were repaired by
respective owners.

Finally, entire system was revived in around seven days with extended
working hours after pumping out water from the basement.

X
Learning points which helped: Trust of the leader on its people, careful
planning, regular rounds by the leader with encouraging interactions, HIRA
and its mitigation measures, SOPs, training and awareness, short tool box
talks, creating an environment of openness where any worker can raise any
query and discuss for the solution, encourage suggestions and implementing
the same, giving proper time for the work, negligible near miss situations, no
fatality, high accountability shown by one and all, reviving with limitations
and urgent actions to replace identified equipment on priority, regular
feedback to senior management on work finished during the day and
planning for next day, working with the people not over the people, Reward
and recognition of all concerned in a special function by Director
(Marketing).

38

Safety Management Systems (7 days) X

Overall, it was an experience worth remembering for the author.

Element 2: Employee/Workers Engagement/

Involvement
Employers have responsibility to provide safe work places to their
employees, make them aware of various risks in their work area with
protection measures provided in the system, train them to overcome such
risks if they encounter the same. Equally employee/workers engagement is
an essential requirement for effective implementation of the Safety
management system and its continual improvement. It is simply a two-way
process where employers and workers discuss and share their safety
concerns/facilitate better safety decisions together which helps in increasing
trust, respect, co-operation among them for enhancing safety at work place
and increase in all round productivity. It is well understood that workers who
carry out their jobs day in and out have deep knowledge and experience
about it and know how unsafe environment can affect them. So, their active
involvement definitely helps in improving /making safety system effective in
their/other areas of work where they are able to take care of their own safety
as well as safety of their co-workers As a self-check, a small questionnaire
given below would help in knowing the status of safety management system
at the work place: 39

How to Set Up Safety Management System in 91 Days Employee/Workers

Engagement/Involvement assessment S.No.

Description

Yes No

Are Employees/out sourced agency workers given safety training in

identified areas regularly in the language they understand 2

Are employees aware of the concept of unsafe acts/unsafe conditions/ Near

misses/incidents and report the same as and when they notice these

3
Are employees involved in Hazard Identification and Risk Assessment
process of normal facility/any changes in the facility

Are competent employees encouraged to share their good safety experiences

/safe behaviours with other co-employees

Are employees involved while preparing SOPs/ critical procedures for

various identified works in the plant

Are employees/workers empowered to stop any work being done in unsafe

manner. Are there any past instances where they have stopped any unsafe
work?

Are employees /workers aware of PPEs required for doing work safely and
use the same as per work requirements

Are competent employees/workers involved in carrying out internal safety

audits/safety committee meetings

Are safety suggestions encouraged/rewarded in the system?

10

Do the Management and the employees believe that all accidents are
preventable If answers to some of above questions are in negative then one
is required to look into /review the safety 40
Safety Management Systems (7 days) management system practiced
presently for the necessary corrections/improvements

To address the same and to improve it further, Facility Head in due

consultation with the Top Management shall develop the written procedure/
action plan duly approved by the management to encourage employees/

Workers participation in all Safety matters addressing above areas of safety

where answer is “partially yes”

or “No” and also covering additionally the following suggested areas:

1. Formation of a Safety Committee with appropriate representation of

workman to review the safety related issues of the facility. Giving chance to
other employees from various departments by their regular rotation in Safety
Committee Meeting.

2. National Safety Week, Fire Services Week, World Environment Day etc.
should be celebrated with a view to promote to promote
awareness/knowledge/skill/

ability in these related areas

3. The employees should be given training on ‘Know your plant’ covering

its process, equipment, chemicals used with their MSDS

4. Displaying of safety banners with various theme topics at the prominent

location of the plant. Safety slogan competition should be organised and
winning slogans should be given priority for display 5. Relevant
leaflets/handouts on various relevant safety themes may be made and
distributed among workers.

41

How to Set Up Safety Management System in 91 Days Also screening of

Video Films covering practical/

relevant safety topic related to the plant works should be encouraged

6. Safety at plant has a strong relationship with safety mind set at home
which makes both safe including their safety on road. Training & Quiz
competition on safety for family members of employees, Poster/Drawing
competition among children should be encouraged.

7. To motivate contract employees, competition on Safety slogan writing

/find the hazard/use of safety equipment etc. should be organized time to
time with suitable rewards 8. Employees/contract employees shall be
rewarded for reporting best near misses, unsafe condition & unsafe act etc.

9. The members of safety committee shall typically include: a. A plant senior

official shall head the safety committee

b. A safety officer if available/a nominated plant officer shall be the

secretary of the committee.

c. The safety committee shall have a representative each from the plant,
maintenance, contract, material procurement, security and HR

department.

d. One or two workers’ representative(s) from various departments in plant

by rotation should be included

42

Safety Management Systems (7 days) e.

For addressing any occupational health related issue, services of a Doctor

may be taken as and when required
f. Tenure of the safety committee may be one/two years.

10. Typical agenda of Safety Committee Meeting generally covers the

following:

a. Discussion on small /near miss incidents that had potential to cause

accident or substantial damage

/learning points on incidents from other similar plants should get first
priority in the meeting for awareness/sharing lessons learnt to avoid their
repetition/happening again in the work area b. Past Accident/Incident
investigation recommendations-status of implementation in the plant should
be discussed

c. For safety of plant certain Safety Trainings need to be essentially imparted

to all concerned. Status of implementation of all such trainings should be
discussed for any help that may be required from the concerned department/
management

d. Safety initiatives implemented by various departments should be

discussed /appreciated.

Feasible suggestions should be encouraged for implementation by the other

departments e. Every plant should encourage Safety Suggestions by the
employees/all concerned. All such suggestions should be discussed for
proper review/implementation/appreciation 43

How to Set Up Safety Management System in 91 Days f. Review validation

of Safety Audit points implemented and pending for implementation for
necessary actions

g. Legal Compliances as applicable to the facility/

plant should be reviewed for timely actions h. Last Safety Committee

Meeting points pending for actions should be reviewed
i. If any other point is to be discussed, permission of the person chairing the
meeting may be taken for discussing the point

j. MOM should be sent to all members and to the management for their
information.

This meeting should preferably be held monthly.

Element 3: Standard Operating Procedures There is always a need to

write down detailed Standard Operating Procedures (SOP) for all activities,
so as to avoid shortcuts and to achieve safe work completion.

This includes all the operational details, emergency procedures, all day-to-
day procedures including need of safety equipment and PPEs.

Standard operating procedures (SOPs) give step-by-step instructions that act

as guidelines for employees to handle various job activities effectively and
safely.

While writing SOPs you may give numbers to the steps, use flow charts, use
figures depicting various steps, etc.

It needs involvement of knowledgeable and experienced workers who carry

out various activities to give inputs for writing SOPs properly. For critical
steps, if missed, hazard/risk involved may be mentioned so that no one 44

Safety Management Systems (7 days) takes a short cut or misses the critical
step. Acceptability of such SOPs is high among employees, and you can
expect consistent and predictable performance.

Good standard operating procedures and work instructions help in effective

communication and practices within the organisation. Their importance/
role is described as under:

GOOD procedures enhance Positive Safety Culture…

Save time and avoids mistakes.

Makes training effective and reduces its costs.

Ensure consistent and desired results.

Provides empowerment and motivates the workforce to do things “Right.”

Workers like to read and it helps in avoiding short cuts.

Helps in achieving quality goals.

X

Enhances proper delegation of work.

Helps in increasing productivity.

Helps in evaluating employees’ performance.

Good workers can be shifted to new work situations without much fear.

Helps in increasing accountability and peer coaching.

On the other hand,

BAD procedures retard the process of building Positive Safety

Culture…
X

Erodes trust in workers and can cause avoidable incidents.

45

How to Set Up Safety Management System in 91 Days X

Makes training ineffective and increases its cost.

Efforts, time and money spent on work gets wasted.

Obstruct in achieving quality goals.

Workers don’t like to read them again or use in their work.

Workers may start using dangerous shortcuts.

Immediate repercussions could lead to such questions in mind e.g.:

Would you like to work in a plant where you know that the
employees/workers are not trained, checklists are not used for jobs assigned,
SOPs are not there for various activities, safety is not given importance, etc.?
Would a patient like to get operated from a surgeon who is known to be not
following certain standards and procedures?

Probably one would like to avoid such situations.

Good SOPs are therefore the essential requirement in any organisation to

achieve desired productivity in a safe manner.

Element 4: Work Permit System In industries various types of new

construction works/

maintenance jobs are carried out by the regular employees as well as

outsourced agencies with their workmen under various departments. To
ensure that all works are carried out in safe manner, permit to work system is
adopted which is issued by designated person having knowledge of the
plant/work area. The equipment/facility is properly isolated by the
authorized operating personnel /safety instructions are explained/

46

Safety Management Systems (7 days) mentioned on the permit etc. with the
signature of such person. Such permits help in protecting assets, fire, injury
to the working personnel etc. The work permit system shall deal separately
with different types of work as briefly explained below: Type of Permit
Type of work

Cold Work

Opening a pump/motor, maintenance

Permit
of valve, painting works, civil works, fixing/ tightening of flanges, cable
laying, inspection etc.

Hot Work

Soldering/ brazing, open fire works,

Permit

burning, metal cutting using gas, welding work, grinding, shot blasting on

metal surfaces , hot works near flam-

mable storages, any work in hazardous area/environment etc.

Excavation

It is generally experienced that when-Work permit

ever excavation works are carried out one comes across various facilities

underground like HT/LT cables, tele-

phone cables, certain service pipelines, gas pipe lines etc.

For the safety of the workmen, it is

necessary that work execution depart-

ment /agency informs/obtains the

necessary permission/work permit so

that all necessary precautions are taken as advised by the concerned

department. In case it is felt that presence of concerned department is
required for
some time same may be requested. Af-

ter completion of work site should be restored to normal and all concerned

should be informed accordingly.

47

How to Set Up Safety Management System in 91 Days d

Confined Space Many a time works are carried out in Work Permit

confined/enclosed spaces having lim-

ited entry area/manhole covers like various types of bigger storage vessels,
storage tanks, boiler drums, boiler furnaces, large CNG compressor enclo-

sures, underground sewage tanks, large diameter pipes, narrow / deep

excava-tions/ pits/trenches more than 1.2 meters etc.

In such cases one experiences oxygen

deficiency ( 21 % oxygen level is considered normal, 19.5% is minimum

acceptable , 15-19% results in poor

mental coordination, 12-14% poor

judgment, 8-12% respiration difficulty/

mental failure, 4-8% results in fatality/coma), toxic gases, falling objects ,

developing of flammable environment

etc.

So, while carrying out work in confined spaces proper work permit should
be

taken and all defined SOP measures

should be followed including training of all concerned persons, proper tool
box talk and monitoring of work area

continuously by designated supervisor.

Working at

Fall of a person working at height more Height Permit

than 1.8 meters is considered danger-

ous as it may cause fracture/break-

ing of bones/ serious injury/fatality if head injury takes place. So for all such
works at height permit should be taken and proper SOP /instructions at site

like proper metal scaffolding, wearing safety harnesses/ safety shoes/ safety
helmets etc. should be followed

48

Safety Management Systems (7 days) f

Vehicle Entry

Whenever any vehicle enters the plant Permit

premises the driver of the vehicle

should be issued vehicle entry permit with instructions to limit the speed

inside the plant below 15 km/hr for

safety of moving persons on road and

also other related safety precautions to be observed related to the plant safety
g
Radiography

Many a time in new/existing plant ra-

jobs Permit

diography jobs are carried out to know that welding work has been done in

sound manner on pipe joints, tank/

vessel plate joints which would en-

sure reliability /longevity of the same.

For this purpose, radioactive source is used and for safety all persons,
defined SOP must be followed and generally

late evening/early morning time/some

other time is considered when person-

nel presence is minimum and also area is properly cordoned off. Permit for

such works is generally issued under

hot work permit.

Electrical work Electricity is an essential part for op-permit

eration of various equipments, main-

tenance activities, control circuit/lighting requirements etc. in the plants. For

working on various electrical equipments like HT/LT supply system, gen-

erators, cables, transformers, motors etc. one must ensure discharging of

HT/LT cable, earthing as required and positive isolation of the electrical

system. If electrical system like motors is coupled to the mechanical
equipment

the same shall also be positively isolated with display of danger boards at all
such isolation points till the completion of work. Qualified/duly trained/

49

How to Set Up Safety Management System in 91 Days authorized list of

electrical personnel should be available along with required testing
equipments, HT/LT megger, earthing arrangement etc. For all such works
proper Electrical work permit

with signature of the authorized electrical person is generally issued.

For electrical safety , Central Electricity Authority(Measures Relating to

Safety and Electrical Supply) Regula-

tions 2010 should be followed

Other permits

Other suitable permits may also be

considered as required for carrying

out work safely inside the plant so as to avoid any hurt/injury to regular/

contract workmen /any other person

nearby

Necessary work permit format for each type of permit shall be developed for
issuance by the authorized signatories of the plant. A system shall be in
place to inform all the concerned department/section about the completion of
work and proper handing over of the area after clearing the same of
unwanted materials/debris/
any unsafe condition, etc. The operation person should thoroughly check the
handed over system before taking the same back into operation

It is required that a one-day training/workshop should be arranged for all

concerned to create awareness on following proper work permit system for
various types of work to avoid any untoward incident/accident Element 5:
Pipeline/ Plant Integrity Management System Let us begin with some
definitions related to Asset integrity:

50
Safety Management Systems (7 days)

Asset means – All physical facilities required for the operation of the
facility.

Asset Integrity – means the ability of the asset to perform its required
function effectively and efficiently throughout the asset life cycle protecting
health, safety and environment.

Design integrity – means the facilities are designed, constructed and

commissioned according to governing standards and specified operating
conditions.

Operational integrity – means appropriate knowledge, skill, ability,

competence and decision-making data to operate the plant reliably meeting
quality processes throughout the life cycle of the asset.

Technical integrity – means adopting appropriate maintenance management

system, decommissioning when required, doing required inspections, doing
required audits, maintaining records, data management for required
corrections ensuring availability/reliability of the equipment.

In a broad sense it is represented by Venn diagram as under:

51

How to Set Up Safety Management System in 91 Days For the Plants, the
asset integrity can be categorized broadly with suitable
inspections/assessment/

reviews/corrective actions as under: X

Static equipment integrity

Rotating equipment/machinery integrity X

Electrical equipment integrity

Instrument and control equipment integrity X

Structural integrity

Pipeline integrity

Evacuation and rescue system integrity The Plant/Asset integrity should

focus on maintaining the asset in a fit-for-service condition through regular
condition monitoring and also extending its remaining life in the most
reliable, safe, and cost-effective manner.

Plant/Asset Integrity management improves plant reliability and safety while

reducing unplanned maintenance and repair costs. Monitoring Safety Critical
Elements (SCEs) plays a vital role in asset integrity.

Safety Critical Elements (SCE) - means those parts of the installation or

plant including software programmes or any part of the facility purpose of
which is to prevent or limit the effects of major accident. While doing major
hazard analysis, one is required to find out SCEs operation of which will
either eliminate incidents or contribute to minimise the incident related
effects.

Therefore, maintenance and continuous availability of SCEs is vital to

maintain asset integrity.
Examples of some safety critical elements are: X

Layout

52

Safety Management Systems (7 days) X

Structural integrity

Process equipment/essential utilities X

Emergency shutdown equipment e.g., ESD valves, accumulators,

control/tripping circuits, pneumatic/

hydraulic tubing, etc.

High pressure/temperature relief valves provided on piping and vessels

Various sensors integrated to effect safe shut down when required

Human machine interface effectiveness X

Blow down systems/drains/containment system X

Gas/other detection systems

Fire detection/alarm/protection/fire-fighting system X

HVAC

Emergency power & lighting

Public address, alarm and evacuation system X

Escape and evacuation

Crane availability etc.

Few examples of condition monitoring S.No. Methodology

Application areas

Periodical vibration

All rotating equipment

analysis

On line vibration

Critical rotating equipment

monitoring

like turbines, high speed/

critical pumps

Shock pulse monitoring Anti-friction bearing 4

Oil and wear particle Critical low speed analysis

equipment in the plant

53

How to Set Up Safety Management System in 91 Days 5

Thermography

Heat insulation, roofs,

High tension and low-

tension systems/equipment

critical joints

Motor current signa- Motor rotor bar eccentricity ture analysis

7

Ultra-sonic thickness

Pipe and vessel thickness

testing

testing

Corrosion monitoring Pipelines, vessels, RCC

structures

For Pipelines, the asset integrity may be broadly categorized with

suitable inspections/assessment/

reviews/corrective actions as under: X

Adopting techniques to prevent metal loss due to internal (using certain

preservatives) /external corrosion (using cathodic protection or sacrificial
anode method etc.) to prevent any disastrous happening to public,
environment, financial, reputation loss, etc.

Corrosion circuits – means system broken down into corrosion circuits

shows damage mechanisms, materials of construction and process chemistry.

Failure analysis review of past incidences should be kept in view.

X

In case of a cross-country Pipeline, the ‘Integrity management’ takes a still

bigger role, as the integrity of entire length of the pipeline is necessary to
meet the intended purpose of safe transportation of the intended
hydrocarbons. This needs very 54

Safety Management Systems (7 days) elaborate planning of resource

allocation and layout planning. In fact, in case of Hydrocarbon Pipelines or
pipelines carrying corrosive liquids, there is regulatory requirement to have
such ‘Integrity management plan’ in place and to seek regulatory authority
approval for the same.

Salient points which need attention for both are: X

Asset integrity management policy addressing objectives, targets, plans,

processes, procedures, responsibility matrix, etc.

SOPs for each activity for each asset.

Competent supervisors, consultants, contractors, trained manpower.

Interaction among departments like Safety, maintenance, Quality control,

Technical audit, other concerned departments.
X

Ensure adoption of best-in-class practices.

Identify risks, conducting assessments, taking preventive actions and

implementing mitigate measures.

A process outline – Details the process envelope (temperature pressure etc.)

in which the system operates and any critical parameters that must be
followed.

Identify the threats of concerns to the asset and to assess risk and mitigation
measures.

Use Risk Analysis to assess potential hazards expected during the facility
operation and estimating the likelihood and consequences of 55

How to Set Up Safety Management System in 91 Days potential hazard. It is

necessary to have mitigation measures in place to meet such exigencies.

X
All the regulatory requirements should be complied.

Analyse damage frequency (statistics) rates of decay for timely actions.

Mitigation techniques, frequency, condition monitoring, inspections and

process monitoring requirements.

Asset condition history as on date.

Gap analysis in knowledge, skill, missing information, manufacturer’s data

report, review drawings, etc.

Review of design, materials of construction initially used.

Management of change review, alterations and repairs carried out.

X

Remediation measures–Repair techniques considered.

Also, one need to focus on:

Maintaining records

Performance plan

Communication plan

Regular Interaction

Management of change
X

Prevention and Mitigation measures

How to conduct assessments/frequency/audit of system

Various components of the integrity management systems which can be

pictorially represented are as under: 56
Safety Management Systems (7 days)

(Reference: https://wutomo.wordpress.com/2009/11/10/maintenance-
planning-scheduling/)

(Reference: http://magnaiv.com/Services/Specialties/Switchgear-
Modernization)

In a nutshell, the various factors that contribute to sustainable asset integrity

management system can be represented in Dr. Kaoru Ishikawa’s fish-bone
diagram or also known as cause-effect diagram as under: 57
How to Set Up Safety Management System in 91 Days To sum up, Asset
Integrity broadly classifies responsibilities as under :

a. Employer’s responsibility for facility: X

Facilities complying to various standards & manufacturers’

recommendations.

Ensuring regular testing and reliability of Safety Critical Elements.

Ensuring regular maintenance, inspection and upkeep of equipment.

Third party inspections, verification and certification of various systems.

b. Employees responsibility for facility : X

Operate systems/facilities as per standard operating procedures.

Following of instructions keeping in view SOPs/

JSA/TBT.

Avoiding short cuts.

Report unsafe acts and condition.

58

Safety Management Systems (7 days) An example:

A well-known incident which gives a lot of learning on Asset Integrity

Management (AIM) is Piper Alpha incident.

Over the course of 22 minutes on July 6th 1988, the Piper Alpha North Sea
oil platform leaked condensed gas that ignited and led to an explosion,
killing 167 of the rigs 229

workers. The UK government then followed up with a public inquiry by

Scottish Judge William Cullen which gave its findings/directions in 1990,
and contained 106 directions on how better to conduct HSE and AIM
strategies in future – all of which were accepted by the oil and gas industry.
37 recommendations covered procedures for operating equipment, 32 the
information of platform personnel, 25 the design of platforms and 12 the
information of emergency services. Many of these applicable
directions/learnings have been adopted by different industries to improve
upon HSE

and AIM in their set up like focus on proper maintenance practices,

availability of SCEs like PSV, proper design, risk analysis/mitigation, proper
operation procedures, enforcing proper safety measures, safety department to
be independent not linked to operation department to avoid clash of interest,
emergency communications/rescue management, etc. This disaster is seen by
many of the formative moment of modern approaches to both HSE and AIM
in oil and gas, not least because it led to a £1 billion safety measure
investment from every offshore operator.

Element 6: Pre-start up review: Generally, pre-start up safety review is

required in case of following situations: 59

How to Set Up Safety Management System in 91 Days a. Construction of

new plant/facility b. Modifications needed in the existing plant/facility The
purpose of pre start up review is: X

To conduct a thorough safety inspection/ review prior to commissioning of

above new or modified plant / facility

To ensure that the new/modified facility meet the original design or

operational intent X

To review / re-assess any potential hazard that may have been noticed during
various changes that might have happened during the detailed engineering
and construction
X

Management of change requirements have been taken care

All operating procedures are available X

All operators are properly trained to handle hazardous material/process

Proper maintenance and emergency procedures are in place

Recommendations of the risk analysis have been complied

All conditions of approval by the statutory authorities are complied

Are the proper PPEs available at site etc.

To meet this objective a team of personnel having good experience in areas

like mechanical, electrical, 60
Safety Management Systems (7 days) instrumentation, civil, Fire & Safety,
other discipline should be made who should do an inspection of the facility
keeping the following in focus:

To prepare suitable checklist with due deliberation among the team members

To thoroughly do physical inspection of the new/

modified/long shut down facility which is to be started

All display screens/start/stop/emergency push buttons are easily assessable

All required safety facilities are provided and operational

All relief facilities are directed to a safe place away from the workplace

All safety critical equipment is installed properly consistent with design

specifications and vendor’s recommendations (for example, alarm and
interlock etc.)

To see that the plant /equipment layout is ergonomically suitable and easy to
handle/operate and do not require stooping/bending/overreaching/

stretching etc.

Review all documents related to the facility like specifications, drawings,

check lists filled by the project personnel in order to verify that the design
criteria have been met. And if it is not met the reasons for the same should
be examined 61

How to Set Up Safety Management System in 91 Days X

Interview the key operating personnel to see that they have required training,
knowledge, skill to operate the facility and can handle emergency situations

Identify and comment if there are any incomplete items. If the facility can be
started without completing it, same should be recorded/ got approved from
the senior person in the plant with a time bound action plan/responsibility of
the concerned person to complete the same in due course of time

To recommend completion of incomplete item if it is necessary for safety of

the facility After finally completing the assigned task, the pre start up safety
review team should sign the document /checklist with their
recommendations and hand over the same to the senior personnel of the
plant who should review/approve the same and hand over to the operating
personnel with necessary instructions as required.

Element 7: Management of Change X

Management of Change (MOC) is the best practice used to ensure that

safety, health, and environmental risks and hazards are properly controlled
when an organisation makes changes to their facilities, operations, or
personnel.

It is a known fact that safety risks to the workers are much more during
various changes transition process than during the routine operations. A
small change sometimes may be dangerous if it is 62

Safety Management Systems (7 days) not properly analysed or understood

w.r.t various risks particularly the plants dealing with various chemical
processes. So, it is very important to recognise change and take all safety
precautions during its implementation/pre-start up activities/

transition activities till stabilisation of the change in the system. It is

necessary that one should review/

familiarise with new processes /modifications/ new equipment etc. for

various hazards and train the manpower otherwise it may lead to an accident
which may impact lives, assets and environment X

For all such changes in the system, new procedures covering these changes
/stages like operation, maintenance, inspection, plant/ facility performance
reviews should be documented properly for future reference/use
X

To illustrate this, few situations are mentioned below which may need
addressing MOC depending upon requirement of various plant
operations/businesses: X

Modifications/modernisation of the plant X

Addition of new software in the plant X

Changes in process control or instrumentation systems to upgrade the same

Changes in critical operating parameters like pressure, temperatures flow, set

points, alarm points, logic and control parameters. etc.

Changes in site level manpower

Changes in the maintenance procedures 63

How to Set Up Safety Management System in 91 Days X

Changes due to various new legal requirements X

Changes in raw material sourcing/ specifications X

Relocation of certain process equipment, piping, pumps, motors etc from

original location to different locations
X

New connection or alteration of connections in in utility systems like air,

electrical, gas, water, steam etc.

Changes in critical test equipment or Quality Assurance procedures

Alterations to safety systems like safety interlocks, safe shutdown

procedures, fire or explosion suppression systems changes etc.

An example...

One of the authors was posted as Chief Power & utilities manager at
Mathura Refinery looking after Power Plant generation, transmission,
distribution of power and utilities like power, process steam, industrial &
instrument air for entire refinery operation. During that period, it was
decided to switch over the control system of boilers, turbines, generators and
electrical feeders in the common main control room of power plant from
conventional pneumatic instrumentation control/manually hand operated
switches to digital control system.

Following change management system/procedures in brief were considered:

64

Safety Management Systems (7 days) X

There was a detailed discussion among all concerned engineers regarding the
suggested change, layout of panels/operating manpower, required awareness/
training of operating/maintenance manpower, possible risks involved, how
to safely start up and safely shut down the operating equipment with the new
system, etc.

Detailed discussions were held with the operating personnel also to involve
them from beginning.

Operators in control room requested that since the new digitized control
system is new to them, they should run it parallel to the old system. The top
management was in favour to discard old system and run entire system on
new digitized system from day one.

On intensive engagement with the operators, the author came to the

conclusion that it would help in smooth installation and commissioning of
the new digitized system if their knowledge and skill is built up by sending
all the operators to the supplying agency at Bangalore for imparting proper
training, awareness and hands-on experience at such training facility
available there. Also, for instilling confidence in operators for handling new
digitized system, parallelly the old conventional control panels were
allowed. The author managed to convince the senior management
accordingly.

X
Keeping the above thinking in view, all operators in small batches were sent
to Bangalore for 65

How to Set Up Safety Management System in 91 Days imparting proper

training, awareness and hands-on experience which took around 4-5 months
period.

Parallelly the construction activities were also progressing.

Also, proper pre-start up review as mentioned above for the related element
was undertaken to ensure smooth start up involving Instrumentation and
Operations Departments.

Ultimately the management of change in form of new digitized control

system in the main control room of the power plant was commissioned
successfully in time bound manner without facing any tripping problem.

Element 8: Emergency Planning and Response

The organisation must have an Emergency Response plan to meet any

emergency situation at any of their plant/facility in minimum time. The
organisation shall establish, document, implement and maintain procedures
to identify the potential situations leading to emergency and to appropriately
respond to such emergencies to prevent or mitigate associate adverse safety
consequences facilitating protection of the public, site personnel,
contractors, environment and the assets.

During the facility operation, various types of hazards like human injury,
health hazards, damage to property, damage to environment or combination
of these may develop in the plant which may lead to emergency situations.
So, all industries must carry out Hazard Identification and Risk Assessment
of such hazard 66

Safety Management Systems (7 days) i.e., HIRA involving experienced

executives and non-executives of the plant and create awareness among all
stakeholders for all the methods by which such hazards can be controlled. It
is one of the obligations of the employer to provide a safe workplace devoid
of such hazards to their employees and other stake holders.

Some examples of safety hazard are given below but may vary from industry
to industry:

Improper housekeeping like not making work/

operating area clean after the work is finished, improper storage of materials
in store area, which results in unsafe condition/hazard.

Fire hazards due to spark/ignition of flammable materials e.g., there have

been a lot of cases of fires in warehouse/basement of stored flammable
nature materials due to electric short circuit.

X
Slipping/tripping hazards such as slippery floor or wires run across floors
causing fall/bone injury.

Moving parts of machinery, tools and equipment like pump motor coupling
guard being not available and somebody accidently touching coupling in
motion meets an accident.

Fall from work at height such as work being done without safety
harness/precautions or working on unsafely erected non-standard scaffolds.

Ejection of hot material from moulding if falls on the body of an operator

can cause burn injury.

Failure of pressure systems such as pipe burst of steam/water/other material

handling pipes.

67
How to Set Up Safety Management System in 91 Days X

Accidents due to vehicles such as forklifts and trucks.

Failure of lifting and other manual handling operations causing injury.

Working alone, particularly at electric work sites, confined/isolated places,

etc.

Once there is a list of hazards of a particular work area or plant, risk can be
calculated using the following formula: P × I = Risk

P = Probability of the hazard taking place i.e based on plant experience in

scale 1-3 (1-Low, 2-Medium, 3-High) I = Impact of the hazard can be
divided into scale of 1-3 (1-Low, 2-Medium, 3-High) The Matrix is simple
to adopt for small organizations.

After determining the values for the Probability (i.e Likelihood) and impact
(i.e severity ) one can use the grid to determine the Risk Potential that each
hazard poses that need to be addressed priority wise as per the Risk Matrix
below : 68

Safety Management Systems (7 days) After every Risk is placed in the

matrix, one can give it an overall risk ranking. Risks that have severe
negative consequences and are highly likely to occur receive the highest
rank; risks with both low impact and low likelihood receive the lowest rank.
Risk rankings combine impact and probability ratings which helps in
identifying which risks pose the greatest overall threats and need to be
addressed on priority with explanations as under : Low: The consequences
of the risk are minor, and it is unlikely to occur (e.g no fatality/non-
reportable injury/very minor material loss etc.). These risks are given green
colour code Medium: Somewhat likely to occur, these risks come with
slightly more serious consequences (e.g no fatality/

minor injury/ material loss/equipment damage etc.). One should take steps to
prevent medium risks from occurring.

These risks are generally given yellow colour code High: These are serious
risks that both have significant consequences, and are likely to occur ( e.g
single fatality etc.).

One should prioritize such risks and respond to these risks in a time bound
planned manner to ward off their consequences to the organization/plant.
These are generally given orange colour code Critical : These risks have
highest consequences and may spread and threaten nearby facilities as well
(e.g big fire/ explosion/multiple fatalities etc.). One should have mutual aid
agreement with nearby plants / keep all concerned authorities etc. aware of
any help that may be needed by the organization/plant in case it happens
inspite of all foreseeable mitigation measures taken in this regard by the
organization/

plant. These risks are generally given red colour code.

69

How to Set Up Safety Management System in 91 Days Selecting a suitable

control measure for Risk often involves:

Evaluating and selecting short- and long-term controls;

Implementing short-term measures to protect workers until permanent

controls can be put in place; and implementing long term controls when
reasonably practicable.

For example, suppose a noise hazard is identified. Short-term controls might

require workers to use hearing protection. Long term, permanent controls
might remove or isolate the noise source.

Types of hierarchy of control generally adopted is depicted in the diagram

below:

Most
Hierarchy of Controls
effective

Physically remove

Elimination

the hazard

Replace

Substitution

the hazard

Engineering

Isolate people

from the hazard

controls

Administrative

Change the way

people work

controls

Protect the worker with

PPE

personal protective equipment

Least

effective

Source: NIOSH

(Reference:https://en.wikipedia.org/wiki/Hierarchy_of_hazard_ controls)
Elimination: Most effective way to make the work environment safe is to
physically remove the hazard, for example, a company involved in cutting of
scrapped fuel tanks may decide to stop buying such tanks to save their
workers from explosion hazards.

70

Safety Management Systems (7 days) Substitution: It may be possible

through studies to replace a highly toxic material with less toxic material in a
process.

Isolation: e.g., an enclosure can be made for the operating person in a high
noise area and controls for the equipment can be located there.

Engineering Control: This can be provided through redesigning of work

process to make it safer, automating dangerous works eliminating interphase
of operating personnel with the work process or creating suitable barriers,
dissipation of toxic environment before it comes in contact with the worker,
etc.

Administrative controls: Measures such as providing safe work practices

through Standard operating Procedures (SOPs)/practicing, training,
coaching, proper housekeeping, maintenance programmes, proper hygiene
arrangements like providing facility of shower/

change of clothes for the workers for works requiring such practice, etc.

Personal protective equipment (PPE): and clothing is used when other

control measures are not feasible and where additional protection is needed.
Workers must be trained to use and maintain equipment properly. The
employer and workers must understand the limitations of the personal
protective equipment. The employer is expected to make PPE matrix
relevant to plant working and ensure that workers use the PPEs appropriately
to work whenever these are needed. Care must be taken to ensure that PPE
are in sound condition. Otherwise, PPE may endanger a workers’ health by
providing an 71

How to Set Up Safety Management System in 91 Days illusion of

protection, as it is considered last protection in hierarchy of controls.

However, in spite of all safety measures, sometimes emergency or disastrous

situations may develop. To handle such situations, the organisation
appropriate to the business context should have: 1. Emergency Response and
Disaster Management Plans (ERDMP) properly documented, updated, and
communicated to all concerned in line with applicable rules and regulations.

2. Adequate resources both internal and external should be provided/lined up

to respond to an emergency situation in line with Emergency Plans.

3. System shall have procedures to familiarize Employees and others with

Emergency Response Plan, their roles and responsibilities to respond to an
emergency.

4. Fire defence system should be established, maintained ensuring continual

improvement through effectively laid down procedures.

5. Emergency Plans should have integration with all concerned civic

authorities, neighbouring industries and concerned plants/offices.

6. Neighbouring communities, concerned civil authorities and public around

the plant should be informed of the potential hazards and the way to respond
during such emergency situations.

7. Emergency Preparedness Exercise should be carried out periodically for

evaluating the strengths and weaknesses of emergency plan for further
action.

72

Safety Management Systems (7 days) Records of all such emergency

preparedness exercise /

learning for corrections should be maintained at site.

8. An emergency control room should be made where all required

information/documents/facilities are available like all important telephone
numbers, overall plot plan, Safety policy, emergency response plan with
names of various co-ordinators for designated allocated responsibilities,
classification of emergencies, emergency action flow chart, incident
reporting system, VHF set as required, CCTV coverage of the plant, etc.
This helps in better control and mitigation of emergency situation in short
time.

An example...

This relates to an emergency mock drill done at one of the CNG stations of
the City Gas Distribution network where one of the authors was engaged
with the owner group as observer. Disaster Management Institute, Bhopal
had come there as the recertification body for the emergency response
management plan. Level one emergency of gas leakage near the CNG
compressor was escalated to level two emergency with fire/

causality. The mock drill was successfully completed by ensuring vehicles in

stop condition immediately and then manually pushing vehicles out of the
station, using DCP cylinders, fire water spray in fine form, using
communication channels to inform police/fire brigade/
main Emergency Control Centre, isolating the CNG

supply at source/dispenser ends, actuation of CO2

flooding system, etc. However, like most of the mock drills, following
learning points were there: 73

How to Set Up Safety Management System in 91 Days X

Different siren codes for differentiating emergencies/operators need to be

given hands on practice.

Safety helmets/jackets in different colours should be available for easy

identification as per responsibility handling role assigned in the emergency
response plan manual.

Training/ hands on practice for use of Self Contained Breathing Apparatus

(SCBA) kit.

LEL meter should be available in working condition.

Mega phone at site for long range PA audible communication.

X

Updated list of all emergency contact numbers should be there.

For handling casualty, proper stretcher to be available.

First aid kit/training needs to be imparted to the concerned.

Mechanism for briefing media about the incident in minimum time.

Mechanism to give simultaneous messages of emergency to important

contact numbers to save time for communication, etc.

Element 9: Training

For success of operation, maintenance and other activities in the

organisation; knowledge, skill and abilities of the personnel are required for
the assigned jobs to get the 74

Safety Management Systems (7 days) desired results/outcome.

The organisation shall establish Training need identification procedure and
implement and maintain the same to enhance knowledge & competency of
the employees to facilitate safe operations practices and health of employees
and required compliance of laws and statutory regulations.

Keeping the requirements of the organisation in view, training system should

be established for all newly engaged or rotated/reassigned employees,
including Safety personnel to suitably equip them to handle normal &
emergency procedures, appropriate safety and occupational health work
practices before assuming duties.

Refresher training for existing employees should be carried out based on

assessment of employees’ knowledge and skill related to their job
requirements.

Training system should also include imparting First Aid Training to

employees by covering each and every section/department.

Training evaluation records should be kept and utility of the training should
be assessed for its effectiveness and analysis. It is required that the training
contents/

methodology should be reviewed/evaluated/redesigned under guidance of

senior persons in the organisation regularly to enhance outcome of the
training.

Element 10: Occupational Health

For better production and productivity, it is essential that an organisation

takes care of the health of the 75

How to Set Up Safety Management System in 91 Days employees keeping

their work environment in view. A system should be in place to identify,
evaluate, control occupational health hazards and to protect the health of the
employees, customers, contractors and the public from any adverse effects
that may result from the organisation’s activities and products.

Procedure should be in place for pre-employment/

pre-placement medical check of the employees and thereafter periodical

occupation health check-up during their working in the plant/organisation.

Records for such check-ups should be made/

reviewed regularly for timely necessary corrections.

The successful implementation of management plans and policies greatly

depend on its adaptability by the personnel (employees) and maintaining
their health is vital for productivity and effectiveness.

As such, their good health should be strongly emphasised in the

organisation’s strategic plan.

Promotion of health of employees in the widest sense, should, therefore, be a

high priority, both a goal and a challenge for the organisation.

To meet the above objective, it is necessary to have a structured occupational

health monitoring so as to have a scientific basis for decisions aimed at
protection of human health from any possible adverse consequences of
exposure to the hazards in the occupational environment.

Necessary engineering/administrative controls should be exercised to

prevent personnel from undue exposure to various hazards at the workplace.

76

Safety Management Systems (7 days)

Element 11: Environment Management X

The importance of Environment Management is well understood by all

organisations including public in general. A business that does not take care
of the environment cannot survive as the environmental activists and
surrounding public give stiff resistance to such businesses X

The business operations of the organisation should be managed in such a

manner that there is least or no damage to the environment.

The organisation must understand its operational activities Aspects(causes) -

- Impact (damage potential) affecting the environment in areas like air
pollution, noise pollution, water pollution, land contamination,
hazardous/non-hazardous waste generation etc

X
The organisation must keep monitoring and continuously improving
environmental performance of its facility in small steps w.r.t its plan meeting
target beyond compliance requirements.

This focus helps in making business operations sustainable

In this regard ISO – 14001 certifications on Environment Management

System helps the organisation to project “green image “ of its operations and
also serves the business interests.

Such certification has become a de facto pre-requisite for trade

consideration/export market throughout the world.

77

How to Set Up Safety Management System in 91 Days X

The organisation should look for opportunities for use of solar power,
rainwater harvesting for underground water recharging, vermin
composting/use of compost so produced in the office/plant gardens,
reduction of electricity/water consumption in plant processes, etc.

The organisation should have in place long term Pollution prevention plans
with focus on continual improvement. Procedure should be made to create
awareness on environment protection among employees and their family
members at large, including celebration of World Environment Day on 5th
June every year. Also, various activities involving employees/contact
workmen/families/

surrounding public should be undertaken to motivate and encourage all of

them to contribute their efforts towards environment protection.
X

As a starting step organisation may review its operations with involvement

of its employees and make initial environment performance plan with
Aspects/Impacts/Mitigation measures given below in a brief manner as an
example which may be suitably modified suiting the operations of the
plant/business. Afterwards awareness program for employees/certification
for EMS should be attempted in interest of better EMS, productivity, brand
building and business exports.

An example on Aspects/Impacts/Mitigation measures tabulation…….

78

Safety Management Systems (7 days) S.

Compo-

Aspect Impact (Dam- Mitigation Mea-

No.

nent

(Cause)/

age Potential) sures/Precautions

Activity

a. Air Pol- - Boiler /

- Exhaust

- Adopt lesser

lution
furnace

gases with

polluting fuels

operation more CO2 or like Natural Gas with Coal/ CO content/

bagasse

other green-

-Correct fuel

burning

house gases

-air proportion

crossing al-

controller so that

- DG set

lowable limits proper burning of

operation

fuel is achieved

- Increased

-Pack-

level of dust/ - Release exhaust

age Boiler other pollut- gases thro’ high operation

ants

rise chimneys/

treatment as per

-Excava-

State/Central

tion /con-

Pollution Control

struction

Bord norms

activities

-Water sprinkling

for dust control/

use RMC

b. Noise

-CNG

Noise levels

-Take actions to

Pollution compressor beyond per-

adopt less noisy

operation missible limits equipment affecting

-DG set

hearing ca-

- Use DG sets

operation

pabilities e.g meeting CPCB

norms during norms

- Pneu-

daytime/

matic

Night time:

-Use ear plugs for

device

workers

operated

facility

-Avoid noisy

works during

night

79

How to Set Up Safety Management System in 91 Days

- Metal

In industries- -Provide suitable

forging/

75 dB / 70dB; acoustic enclo-

cutting/

In commer-

sures around the

grinding

cial area 65

equipment

operations dB/55dB and

in residen-

- Provide suitable

tial areas -

acoustic bar-

55dB/45 dB

rier between the

residential facil-

ity and the noisy

equipment
c.

Water

-Increased -Stress on

-Adopt water

Pollution demand of existing water saving practices water

supply

- Rain water

- Gen-

-Pollution of harvesting

eration of water bodies

wastewater

- Plantation of

- Improp-

less water con-

- Inad-

erly treated

suming trees

equate

effluent not

sewage/
meeting the

-Upgrade capac-

effluent

norms

ity of ETP/STP

treatment

facility

facility

- Use planned

and treated sew-

age for secondary

requirements like

gardening/flush-

ing requirements

d.

Land

-Solid

- Disposal

-Waste minimi-

contami- waste
of waste not

zation with focus

nation

generation done properly on recovery and of varias per norms

reuse

ous kinds/

Electronic

-Monitoring

waste /

operations /ac-

tions to minimise

Medical

spillages

waste etc.

80

Safety Management Systems (7 days)

-Transpor- -Accidental

-Monitoring/

tation of

spillage of
timely actions to

hazardous hazardous

address corro-

material

chemicals

sions

leads to soil

- Oil spill-

- Segregation at

contamina-

ages dur-

source for all sol-

tion

ing various

id waste streams

operations -Increased

and utilise autho-

oil spillages

rised agencies for

- Improper /seepage of
safe disposal as

monitor-

oil to under-

required

ing of

ground water - Recycling of

corrosion due to dam- dry garbage as of bottom age of shell/

per guidelines

plates of

bottom plate -Treatment of

oil /other of the oil /

wet garbage by

storage

other tanks / Organic waste

tanks/

pipeline dam- converter and use

product

age due to

the same as com-

pipelines
corrosion

post/manure

- Use of dried

STP sludge as

manure

-Utilise common

ETP facilities as

required

- Transportation,

storage and han-

dling, disposal of

electronic waste

as per guidelines

- Strom water

drainage of

required capacity

should be made

81

How to Set Up Safety Management System in 91 Days

O

Element 12: Compliance Audits Audits are normally designed to achieve

one or more of the following goals:

To carry out a systematic, critical appraisal of all potential occupational

safety hazards involving personnel, plant, services and operation method X

To ensure that safety management system fully satisfies the legal

requirements and those of the company’s written safety policies, objectives
and programmes.

By doing safety audits of the facility at regular intervals one gets feedback
how well the planned/

implemented safety management system is giving the desired results of safe

work environment minimising/avoiding unsafe acts/unsafe conditions/

near miss incidents/accidents etc. The deficiencies observed in the system

should be reviewed and suitable actions should be taken to correct the same.
It is required that one day training/workshop should be arranged to create
awareness/skill on safety audit system for all concerned X

Typically following three types of safety audits are carried out:

82

Safety Management Systems (7 days) Type of

Remarks
Audit
a. Internal

• Make team of 2/3 experienced knowl-Safety

edgeable persons of different disciplines Audit

as required who have good knowledge of the plant operation/maintenance

aspects

• Decide the areas to be audited in planned months during the year with
suitable checklist as per IS-14489/OISD/

PNGRB Regulations

• This team should take round of the plant/

look for unsafe conditions/unsafe acts in various jobs going on at

site/examine that the permit has issued properly/interact with the
employees/outsourced workers to see that they have knowledge about their
jobs and know how to handle emergencies in their work area/ record of near
misses/incidents/accidents etc.

• Concerned department should make a proper action plan to implement

various recommendations of the internal audit committee

• Such an audit may be carried out on yearly basis

b. External
• External Safety Audits are carried out by Safety

a team of experts in line with standards as Audit

appropriate in context of business/standard as per IS-14489/OISD/PNGRB

Regulations

• For such audits the scope of the audit is discussed by the management with
the

auditors generally focusing on areas where they look for assessment by the
external experts regarding the effectiveness of their safety management
system and controls deployed/monitoring adequacy of 83

How to Set Up Safety Management System in 91 Days the change

management system deployed/

their recommendations to strengthen the safety management system etc.

• Such an audit may be carried out once in 2/3 years depending upon
nature/hazard of the business operations involved

• Time bound action plan on recommendations should be made by the

manage-

ment and reviewed regularly

c.
Safety
• Make team of 2/3 senior officials as re-Manage-

quired who have been associated in

ment Sys-

review/monitoring of safety on plant

tem Audit
operation/maintenance aspects, imple-

mentation of safety policy of the company etc.

• This team should examine in detail various elements of the safety

management system in practice and make recommendations for
improvement wherever re-

quired

• Top management should review implementation of various

recommendations

time to time

• Such an audit can be planned once in 3/4

years

Thus, it can be seen that regular Safety Audits, though on sample basis,
reflect proactive whistle blower approach for improving safety of workers as
the organization gets many early inputs/warning signals to improve safety
management system being practiced which help in avoiding many invisible
incidents/accidents waiting to happen.

84
Writing SOP for Safety Management System and ....
Chapter 5:
Writing SOP for Safety

Management System and

building Awareness
(21 days+ 8 days)

“Success is not always about greatness, it is more about consistency.

Consistent hard work will lead to success.

Greatness will come.” –Dwayne Johnson.

Writing SOPs (Standard Operating Procedures): What it should

contain:

Any organisation big or small must have appropriate Standard Operating

Procedures (SOPs) document made available to its employees/outsourced
manpower so that they can carry out all operation, maintenance and
construction and other day to day activities safely, productively meeting all
regulations/law of the land.

Following steps may be adopted while making the SOPs: X

Process Flow Diagram and P&ID diagram of the system in operation should
be studied by a group 85

How to Set Up Safety Management System in 91 Days of nominated

competent persons along with 1-2

knowledgeable workers.

Start with the end in mind that lays down emphasis on who, what, when, and
where for important procedures in your plant or organisation.

X
A list of total operation, maintenance, construction, procurement, storage
activities, etc. performed regularly or envisaged to be performed in context
of business activities should be made by breaking up total job into smaller
work activities.

Take the activities one by one to write SOP for that activity with proper title
and unique number identification. Proper index table for easy reference
should be made. Scope and purpose of the SOP

may be mentioned.

Mention terminology, including acronyms and phrases to bring clarity.

Note down all the steps how the activities are being done presently.

Each step should be examined for prior knowledge, general behaviours of

existing and new employees in view with a focus on what can go wrong/

what unsafe act or unsafe condition may happen.

Introduce any new step that is felt necessary for safe and productive
outcome.
X

SOPs for new employees can be in detail with training orientation.

All the steps should be written in a simple and 86

Writing SOP for Safety Management System and ....

understandable way in the language which the employees understand. Also,

the associated hazard on critical steps if bypassed may be mentioned.

Diagrams as actual at site may be incorporated where required for clarity

purpose.

Nominate a senior level committee for reviewing the draft SOPs for the
desired outcome.

Involve executives and non-executives to test some critical/other SOPs by

actually carrying out the job through the persons who are expected to use
these SOPs.

Incorporate all relevant suggestions received during its testing/time to time

in operation to improve the SOP further.
X

All the SOPs to be approved by Heads of Department in respective areas.

All new SOPs should initially be reviewed every year and thereafter this gap
may be suitably increased after review/stabilization of SOPs in practice.

Ultimately this becomes standardised SOP

document of your plant/organisation.

For introducing any new SOP similar steps may be repeated.

It may be good to adopt Best Practices from other organisations in

SOPs/safety management system.

A suggested col aborative approach for sharing best practices/

SOPs...

87
How to Set Up Safety Management System in 91 Days Taking example of a
new CGD company in India, it is very clear that there are already many
success stories in this sector. May it be of M/s Mahanagar Gas Ltd (MGL) in
Mumbai or of M/s Indraprastha Gas Ltd (IGL) in Delhi and NCR and many
more. A new entity need not invent the wheel again, rather follow the
successful models of already existing companies. A senior level multi-
disciplinary team be deputed to such organisation for thorough study and
learnings. Their best practices be immediately picked up and incorporated in
the safety management system/SOPs.

A mutual sharing of best practices platform be developed for each other’s

benefit and learnings be recorded, adequately circulated and rigorously
followed. In case of a multi-location organisation, such practice of sharing of
best practices be also developed within the organisation.

MSMEs are likely to draw immense advantage of such a system, by mutual

sharing of best practices, not only between MSMEs but also between MSME
and large companies operating in the same domain. There are many
examples and many forums through which sharing happens in-between
Industries. For example, through forums of PNGRB, Petroleum and Natural
Gas Regulatory Board , FIPI, Federation of Indian Petroleum Industries,
OISD, Oil Industry Safety Directorate, Pipeline Research Council
International (PRCI), ASME, American Society of Mechanical Engineers,
NSC, National Safety Council and SCOPE, Standing Conference of Public
Enterprises, etc.

88

Writing SOP for Safety Management System and ....

It is imperative that forum of MSMEs in similar domain or CGDs be

developed and every quarter, mutual sharing be organized by one-member
company on a rotation basis. Such meetings could also help in developing
mutual trust and mutual sharing of resources in cases of emergency. In fact,
formal Mutual-Aid schemes could evolve out of such mutual engagements,
for win-win situation. In Oil Industry such formal Mutual-Aid agreements
have been mandated by PNGRB, Petroleum and Natural Gas Regulatory
Board, besides other authorities and similar legal provisions exist in some of
the statutes. Insurance companies also consider providing special rebate in
the Insurance premium to the organisations having formal Mutual Aid
Schemes.

An example of SOP:

An illustrative example of SOP is given below. It is for starting of Fuel Oil

Pump in a Power plant having three oil fired boilers of 100 T/Hr steam
generation capacity 42 ata pressure with steam temperature of 425°C getting
fuel oil supply from Fuel oil pump house. SOP generally involves - SOP
document number/specific number for SOP, its purpose, scope, pre – checks,
requirement of specialised tools/tackles, procedure, possible safety health &
environment risks, environment impact, formats to be used, cross references
and finally approval by HOD. Such SOPs help in carrying out activities
smoothly as all concerned executives become aware of such standardised
procedures. This enhances self-discipline in carrying out the assigned jobs
safely, which 89

How to Set Up Safety Management System in 91 Days in turn helps in

creating positive safety culture for sustenance of the organisation. A sample
format in this regard is given below: ABC Co. Ltd.

Department System Logo of company

Manual

SOP for start-up Document No. ……

of Fuel Oil Pump

for Boiler no. 1,2 SOP no……

&3

Purpose

This SOP is for starting Fuel Oil Pump located in FO

Pump House
Scope

This procedure is applicable Fuel Oil Pump operation of Power Plant under
ABC Company located at

......................................

S.No.

ACTIVITY

RESPONSIBILITY

Pre - checks

Mandatory PPE must Shift supervisor

be worn all the time like FO pump Operator Safety helmet, Safety Boiler
operator shoes, Safety gloves,

Any one in job there

Hearing protection, Eye

protection, Respiratory

protection etc

All work permits are Shift supervisor returned and closed

Ensure electrical

Shift supervisor

clearance has been

received

Ensure that mechanical Shift supervisor clearance has been

received

90

Writing SOP for Safety Management System and ....

Ensure that all blinds Shift supervisor in the fuel oil line are

removed

Ensure that Fuel Oil tank FO pump operator is having oil more than

50% level with proper

temperature through

functional heating

system provided

Ensure auto start facility FO pump operator of pump in case of low

pressure is checked and

is in line

7
Ensure that all

FO pump operator

instrumentation like

Temp./pressure gauges/

control valves/system are

functional and in line in

his area

Ensure that all

Boiler operator

instrumentation like

Temp./pressure gauges/

control valves/system are

functional and in line in

his area

Requirement of specialized tools and tackles, if any 1

Manual metallic roll tape FO pump operator for measuring level of

FO tank

Sampling jar
FO pump operator

A temperature gauge FO pump operator

having metallic casing

Procedure
1

Ensure suction valve is FO pump operator open

91

How to Set Up Safety Management System in 91 Days 2

Priming of the pump to FO pump operator be carried out gradually

till all air is dispelled and

oil is seen coming out

near pressure gauge with

its drain point valve open.

Same to be closed/locked

thereafter

Inform the Boiler

FO pump operator

operator before starting

the pump

Start the pump

FO pump operator

Check discharge pressure FO pump operator developed with current in

amperes

Check for any vibration, FO pump operator abnormal sounds,

temperature of bearing

etc

If normal, slowly open FO pump operator the discharge valve with

NRV in line

Interact with the boiler FO pump operator operator about receipt of

fuel oil at boiler end with

pressure of oil

If normal, run the second FO pump operator pump in similar manner

as required

10

To stop the pump, press FO pump operator the stop push button of
motor

11

Isolate the suction and FO pump operator discharge line

92

Writing SOP for Safety Management System and ....

12

Depressurize the pumps FO pump operator as required

Possible Occupational Health & Safety Risks and Environmental

Aspects

Possible Hazard

Possible Risks

Possible Control
Measures by FO operator
1. Leakage in -Fire

/F&S

Fuel oil tank /

- Contain leaked oil in

Fuel line

dyke by closing dyke

valve for oil tank

- Inform Fire & Safety

Dept.

- Inform Shift supervisor

- Use DCP cylinder as

required

- Ensure vigilant plant

rounds for abnormal

situation for its timely

detection / timely

control

- F&S to take suitable

action as per the

prevailing situation…..

F&S Dept.

- Mutual aid, if require,

may be activated

…………… F&S Dept.

Formats to be used
1

Use Field log books for FO pump operator taking regular readings

Use Permit system

Shift Supervisor

as defined in Safety

Management System

93

How to Set Up Safety Management System in 91 Days Cross References

Operation Manual of All concerned

Power Plant

Old records will be stored All concerned at a central designated

place for three years and

thereafter disposal of

records can be done with

approval of HOD
Approval
Approved by HOD ………… Put up by Sectional Head …………….

Dated…………….

Stamp…………………….

94

Setting up the Safety Governance Mechanism (7 days) Chapter 6:

Setting up the Safety

Governance Mechanism
(7 days)

“Safety applies with equal force to the individual, to the family, to the
employer, to the state, the nation and to international affairs.”

After having introduced Safety management system into the organisation

and writing SOPs etc. at site level, it is necessary that a Safety Governance
Mechanism is also designed through which the effectiveness of
implementation of SMS is ensured. The involvement of senior leadership is
very important for maintaining effectiveness of the system.

Accordingly, three levels/ two levels Safety Monitoring mechanism can be

established.

Depending on the size and geographical spread of the organisation, MSMEs

or CGD company may design a mechanism, through which each site head,
the in charge of a location, a business, a Geographical Area (GA), or a
manufacturing facility head should review the implementation 95

How to Set Up Safety Management System in 91 Days of SMS, at least once

in a month, in a structured fashion. A format be designed for the sake of
uniformity and guidance to the sites, in case of multi-location organisation (a
typical format is attached for ready reference) which can be utilized by the
Head of unit, as detailed above, to exclusively review the safety
preparedness in the respective facility. In this review meeting, various
functional heads be invited and asked to discuss various actions taken by
them to manage Safety in their own domain area during the month. This
would also include statutory compliances related to Safety, Safety
observations made during site safety tours, compliance of Safety Audit
recommendations by internal or external Safety Auditors, details on Safety
trainings imparted, any unsafe events happened during that period and
corrective actions taken, details of Mock drills organized and response
thereof, Fire prevention activities, Risk management activities like QRA,
HAZOP, HAZAN, etc. done during the month and outcomes thereof, finally
the exceptions on Safety Compliances. After detailed discussions and
deliberations, a report could be generated and submitted to the CEO of the
organisation, and to other concerned Directors.

The success of any Management System largely depends on Leadership

engagement. If a leader is committed and demonstrates visible, transparent
and felt leadership, every one follows him/her. Leader has to ‘walk the talk.’
His/

her keen interest in safety management system and Safety Values, draws
everyone’s attention and officials down below, start paying respect to the
Safety Management System.

96

Leadership & Commitment Cultural change has to be driven from the top
not by Setting up the Safety Governance Mechanism (7 days) specialist at
any intermediate/middle management level.

COMPENTENCE

Top Management should have die heart desire CORE

Overcome from “touch me not” or “stay out”

LEADERSHIP

VALUE

COMPLIANCE

approach

ENGAGEMENT

Structured Safety Review Mechanism

PILLARS OF SAFETY

LEADERSHIP
Safety Review against a Predefined Agenda at Corporate Level and at Site
Level one in month

(Reference: https://esb.ie/acting-responsibly/staying-safe/esb-safety-Visible
and felt Safety Leadership

leadership)

As such, to demonstrate above, the CEO of the MSME

or CGD should hold a meeting to review Safety Management System across

the organisation, at least once in a quarter.

During this focused meeting, each Facility head or GA head, should present
before him all details about progress achieved in Safety Management
compliances, Exceptions, if any, New achievements, Safety preparedness,
compliance on Safety Audit recommendations, etc. besides review on lagging
indicators like no. of incidents, accident frequency, severity ratio etc: refer
annexure … for guidance. The Safety Manager should co-ordinate and
facilitate in organizing this meeting on schedule.

Compliance on Safety recommendations, either statutory or non-statutory

given by external auditors, should be non-negotiable. KPI and KRA should
be written down for each supervisory level official, right up to the facility
head or GA head, with respect to Safety management. Each incident 97

How to Set Up Safety Management System in 91 Days should be thoroughly

investigated by multidisciplinary team, who should be asked to present their
findings and suggest mitigation measures before Board of Directors. Once
accepted by the board, findings should be shared with all employees for their
learning and correction in their own system. So that similar incident does
not happen at any other facility or area of the organisation, in the future.

Safety KPIs should also be linked to the incentives. A serious or fatal

incident should be seen as not acceptable event and serious dis-incentives be
proposed in the system, for officials right up to the level of Facility head or
GA head, as applicable. However, bad news about small incidents here and
there should never be kept under the carpet and be never seen as something
which may invite wrath of the seniors. Rather, a system be developed where
in reporting of unsafe conditions, unsafe acts and near misses, etc. be
encouraged. However, such incident/condition be thoroughly investigated,
the cause be identified and corrective action taken. So that, next time, it
should not appear again in the form of more serious event. Such root causes,
as investigated, be widely circulated along with the lessons learnt. Efforts be
also made to catch hold of case studies of similar industries, who have
already encountered some incidents/accidents and proactively learn from
those cases. The findings and recommendations of such events be quickly
disseminated across the organisation, and corrective actions be taken
proactively.

On the other hand, good incentive be given to those sites where NIL
incidents are reported during the year or landmark number of Safe
manhours are achieved during a 98

Setting up the Safety Governance Mechanism (7 days) specified period. Such

scheme help in developing common team goals towards achieving Nil
incidents and thereby a good safety culture, wherein each employee, worker
or manager takes care of not only himself and his team but also other
colleagues, in achieving Zero incidents/accidents.

Benefits of having a Governance Mechanism: a. The top leadership is

directly involved in the final outcome of this initiative and part of the
process.

b. There is a pre-decided calendar of meetings/engagements that ensures

sufficient communication on progress and any remedial action required.

c. Ensures that leadership ‘walks the talk’ to motivate and drive change of
behaviour and overall culture.

d. A pre-approved format is used to review Safety status and impact of the

new Safety mechanisms.

e. Deadlines are adhered to, and the project moves at the desired pace.

f. There is proper documentation of progress, discussions, action taken and

changes implemented.
Challenges of setting up a Governance Mechanism: Running an effective
Governance mechanism is not as simple as it looks. Though the leadership is
involved in it, if it is not implemented conscientiously, it would not be able to
yield any results. In our experience, almost half of the organisations which
are driving a Safety culture change are failing due to a poorly implemented
Governance mechanism. So, what can go wrong in the Governance
Mechanism?

99

How to Set Up Safety Management System in 91 Days a. The system is too

simplistic and does not incorporate the right set of people: To take a case,
there was an organisation where the Governance structure was being set up
to drive the Safety Culture. Most of the leaders shied away from this
additional responsibility as it would require their time and effort. They were
able to do this as the CEO was not fully committed and had minimized his
engagement in the process. Eventually, most of the members of the
Governance committee were from the Safety department and support
functions like HR, Training and Supply chain. Leaders from the critical
department of Operations were missing. This impacted the power of the
Governing body. Though the body could clearly see lapses in the
implementation of the process and asked for remediation, their instructions
were not adhered to by the Operations team (which was directly responsible
to drive Safety in the organisation).

b. The Governance system is too complex: A large, multi-location and

complex organisation set up a governance structure which was quite
complex with a long list of activities in each meeting and frequent meeting to
be done at various levels of the organisation. Within three months, there was
a built up of ‘meeting fatigue’ among the members and they started either
cancelling whole meetings or finding that very few members were joining for
them. Also, there was a counter effect in that the meetings became very
unproductive and there was no useful action or outcome. Eventually, the
system had to be scrapped and changed to make it more usable.

100
Setting up the Safety Governance Mechanism (7 days) c. The Governance
system is too centralized: In an ironical example, the leader (CEO) of this
organisation (which was multi-locational and with numerous functions) was
driven to implement a Safety Culture and was personally involved in
structuring the Governance system. As he (and his set of top leaders) did not
have confidence in the lower hierarchy, they set up a very centralized
system, where all communication and action had to be shared with the head
office. This required for the locations/

functions to fill up forms and send them to head office.

There was an option of online filling the forms, but that was not used much
because the personnel would be out in the field while filling up the data.
Also, during meetings, the members were more concerned to write up the
‘minutes’ of the meeting rather than having a discussion and deciding on
action. Eventually, the employees in the field started faking the data. Minutes
of meetings were the same stuff, which was changed a bit and sent off to HO
every month.

d. The system is inflexible: Flexibility is very important here. The

decentralized governing bodies should be able to shift priorities, look at
practical application of procedures, skip steps and change the format of
communication. They have to take ownership of driving the safety culture
and accept that the Governance mechanism is just a tool to ensure that
outcome.

e. There is minimum ‘informal’ communication around the Governance

process: This is a lapse which is usually not noticed but creates maximum
damage. In an 101

How to Set Up Safety Management System in 91 Days optimal governance

process, there should be a minimal communication on the findings and
actions (after all, the committees are not required to write a book on the
same!). A ‘minute of meeting’ could be just a one pager with bullet points.
But once it has been circulated, the stakeholders and employees on the
field/workplace should have a healthy discussion/conflict/alignment around
that as they move forward to implement the actions. If that is happening, we
can be assured that the mechanism is working. Otherwise, it can be accepted
that the governance mechanism is a ‘top down’ activity forced on people.
They are engaging at a minimum level to show that they have done what was
asked for.

Further, it is not being seen in a positive way and at the first sign of
weakness, people will skip the action required of them.

The Governance process can have various formats and needs to be

customized for each organisation. But the standard format should have the
following elements: 1. Structure: This includes the Organisational design,
reporting structure and the structure of the committees and charters. This is
the ‘skeleton’ of the Governance structure which ensures a structure.

2. Responsibilities: This includes the Board oversight and responsibilities,

management accountability and authority, and the authority and
responsibilities of the committees. These are essentially the powers given to
the governing bodies, which can be used to review progress and drive
implementation.

102

Setting up the Safety Governance Mechanism (7 days) 3. Talent and Culture:

Performance management and incentives, business and operating principles,
and leadership development and talent programs which would be used.

4. Infrastructure: Policies and procedures, reporting and communication,

and technology are the key subcomponents under this section.

The process sequence for setting up a Governance Structure is as given

below:

Step I:

Define the operating requirements for your governance model.

O

Look for frameworks that will work best for your organisation or design
your own.

Factor in any applicable regulatory, governance, or legal requirements.

Consider the scope of your operations and how governance factors in all
aspects of it.

Understand your current state of governance, including its strengths and

weaknesses.
Step II

Design the governance operating model and its components.

Define the key accountabilities, decision rights, and path for escalating
matters up the levels of authority.

103

How to Set Up Safety Management System in 91 Days Step III

The final part is implementing the governance operating model.

The completed model should define how boards will measure their success
using standards and metrics.

The model should tie governance requirements, organisational functions and

business requirements together and allocate resources accordingly.
O

Implementation should include a schedule of how often the board reviews

the governance operating model and may suggest that a third party
participate in reviewing the plan. The review process should include the
components, the plan, and the implementation.

104

BBS Integration into the Organisation (7 days) Chapter 7:

BBS Integration into

the Organisation
(7 days)

“If you want to change attitudes, start with a change in behaviour.” –

Katherine Hepburn

After having known about Safety Policy, Safety Management System and
Safety Governance mechanism it will be interesting to read about the
recommended behavioral intervention, which supplements the efforts in
creating safe working environment and thereby reducing no. of incidents and
accidents. This chapter deals with the subject “Behavior Based Safety”, a
behavioral intervention to address “Unsafe behavior” or “At- risk
behavior’.

History of BBS (Behaviour based Safety): BBS is said to have begun after
re-search conducted by Herbert William Heinrich, an industrial safety
pioneer between (1886-1962). The research led to his definitive book,
‘Industrial Accident Prevention, A scientific Approach.’

Heinrich’s research led to the theory that 95% of accidents in the workplace
are caused by unsafe acts or behaviour.

105

How to Set Up Safety Management System in 91 Days 1

Major Injury

Minor Injury

29
300
Near Misses

Heinrich’s pyramid

(Reference: https://www.ishn.com/articles/109182-the-safety-triangle-a-
useful-yet-complicated-theory)

Following the publication of Heinrich’s book, companies began to take a

more systematic approach to analysing accident data. In the seventies,
various organisations started working on BBS.

Various projects in different organisations led to the beginning of the

Behaviour Based Safety (BBS). Some of these initial projects helped to
develop the key concepts of Behaviour based safety and how it should be
implemented in the Organisation.

Many companies like DuPont, Safety Performance Solutions, Behavioural

Science Technology, etc. started offering structured solutions to drive BBS in
organisations.

Why BBS?

Further studies and real-world experience have shown that more than 85%
of accidents happen due to unsafe behaviour. In course of our experience, we
have come across large organisations who set up multiple levels of process
safety but still ended up with accidents due to poor safety 106
BBS Integration into the Organisation (7 days) attitude of the workers. When
an accident happens, we see the incident, but we do not see what went on
behind the incident to cause it. This is very well shown in the below ‘Safety
Iceberg.’ Eventually, any accident can be sourced back to some unsafe act or
unsafe condition.

Heinrich’s basic pyramid, which is shown in the earlier page, was further
detailed out to give some arithmetical ratio between an ‘unsafe attitude’ and
progressively more serious incidents.
The logic is that when a person demonstrates an ‘unsafe attitude’ repeatedly,
nothing may happen all the time or most of the time. But, if it happens again
and again, a sense 107

How to Set Up Safety Management System in 91 Days of complacency

creeps in, and eventually it results into an accident. The below pyramid gives
an idea of how a simple case of ‘unsafe attitude’ can eventually result into a
fatality.

In our experience, there have been numerous large manufacturing

companies, which spend crores of rupees to install multiple layers of security
on their machines, and yet the workers find ways to circumvent the safety
levels and get involved in a safety incident.
The Safety Pyramid for behaviour
(Reference: http://umich.edu/~safeche/processtriangle.html) The BBS
concept believes that eventually, it is the person’s attitude towards Safety
which decides his/her safety.

An interesting example is of the fact that most road accidents happen with
people who are skilled drivers. People who are learning to drive are too
careful and mindful to ensure that they do not drive recklessly and thus
cause an accident.

108

BBS Integration into the Organisation (7 days) The above picture shows how
eventually 85% of the safety is with the person himself/herself.

Different origins of accidents:

From the perspective of an MSME, this is a very interesting fact, as it

implies that a safe organisation need not spend crores of rupees in
developing safety systems. A practical safety structure combined with strong
BBS can ensure that accidents do not happen.

What is the process of Behavioural Based Safety?

Multiple awareness surveys have shown that accidents are caused due to
unsafe behaviour of humans. On an average, considering various inputs and
sources, we can say the following: a. Eighty to ninety percent of accidents
are triggered by unsafe acts or behaviours.

b. Further, it has largely been seen that most of the unsafe behaviours are
easily identified or noticeable at any workplace at any given point of time.

c. Unfortunately, as the workers and supervisors are not having safety

awareness, they either ignore or miss out on the unsafe behaviour happening
in front of their eyes.
The above observations lead us to the understanding that if every
supervisor/worker/employee is trained in observing/

noticing unsafe behaviour (for themselves and others), it would considerably

improve the Safety of the workplace.

109

How to Set Up Safety Management System in 91 Days Based on this simple

concept, the broad guidelines of Behaviour Based Safety are as follows: a.
Increase awareness of Safe Behaviour: The first step is for Supervisors,
workers, employees to know what is safe behaviour and how to identify if it
is being followed or not in the workplace. A worker not wearing the gloves
or helmet, using the wrong tools, not following safety guidelines, incorrect
posture etc can be seen as unsafe behaviour. The areas which have been
largely followed for considering safe behaviour are as follows: a. Usage of
Personal Protection Equipment b. Usage of proper tools

c. Following Safety guidelines of the procedure d. Correct posture

e. Using correct PPE, equipment and following guidelines for working at

heights

f. Working in enclosed spaces

g. Housekeeping

h. Visual focus

i. Material Handling
j. Managing distractions

k. Ergonomics

l. Slips, trips and falls

m. Road Safety – Defensive Driving

As observed, people tend to see what they are looking for and ignore the rest
of what they are seeing. So, we see with our brains rather than our eyes. If
the brain is taught to notice 110

BBS Integration into the Organisation (7 days) deviations in these areas,

then it will be easy to detect them right away.

b. Understand that correcting these small behaviours will ensure that

accidents are avoided.

Look at the following scenarios:

a. While walking down the stairs, an employee ignores the hand rails and
does not take support, as both hands are busy holding files and other things.

b. While sitting on a chair and engrossed in work, a person leans on the

chair back, balancing it on two legs.

c. A worker working on a cutting machine pulls down his eye protection

goggles because it is sweaty.

d. While driving, a person gets a call on the mobile phone and turns his head
quickly to look at the phone.

e. Two workers are at a stamping press, talking excitedly about something

while operating the machine.

What are the possibility of these acts converting into accidents?

All such behaviour are minor deviations and usually nothing happens. As
nothing has happened in the past, most of us tend to believe that nothing will
happen in the future. So, we continue this behaviour. Eventually, we start
believing that this behaviour is actually safe, and will not cause accidents.
This is usually the root cause of unsafe behaviour.

Tragically, many of these ‘minor’ breaches of safety sometimes end in

fatality or severe body impairment. The employees have to understand that
each of these acts is a 111

How to Set Up Safety Management System in 91 Days potential ‘risk’ which

can cause accidents. So they have to be avoided each and every time.

c. Engaging positively with others to change their behaviour: A supervisor

sees a worker at the cutting machine but not using protective eyewear. The
worker may feel that he is fine, but the supervisor knows that the worker
could lose his eyes if a spark or speck goes into them. The worker is
experienced and knows his job.

He has also been told that it is important to wear the protective eye glasses.
Despite knowing that, the worker prefers to work without the eyewear as he
finds them uncomfortable.

As the Supervisor approaches the worker, he knows that just telling the
worker to wear the eyewear will not help in the long run. The worker will
again revert to the old behaviour when no one is looking.

What will the Supervisor do to help convince the worker that he should
change his behaviour?

The above challenge is at the heart of Behaviour Based Safety. The key
principles of BBS accept that behaviour change is not easy, and an effort has
to be made to convince people to be safe.

For a person to change, he or she should be willing to listen. People listen

when they are in a positive state of mind and trust the person who is giving
them instructions or advice. People listen when they accept and/or agree
that what is being told to them is important.
112

BBS Integration into the Organisation (7 days) Taking this challenge in

mind, the key steps of BBS

include the following:

a. Observe the activities of the other person. See what is being done
correctly as much as you observe what is not being done correctly. Keep
both the types of behaviour in mind when watching the person. To take an
example, you observe a worker who is wearing all the PPE but is not using
his tools correctly.

b. Start with the positive: Approach the person and talk about the correct
behaviour being demonstrated. Talk in positive terms and appreciate the
correct understanding of Safety by that person. To use the above example,
you appreciate that he is wearing all the PPE correctly. You talk about how
this safe behaviour is ensuring safety from various accidents.

c. Shift to identifying the unsafe behaviour: First ask what unsafe behaviour
he is demonstrating. This prompts the person to think and try find out what is
being done incorrectly. The best situation is where the person himself
identifies what is being done correctly. This significantly increases his
confidence. Eventually, the discussion should lead to concluding which are
the one or more unsafe behaviours. To take forward the example mentioned
above, now the supervisor brings to his notice that he is not using the proper
tool.

d. Revisit the worst impact of the unsafe behaviour: On the face of it, any
such minor unsafe acts may not cause any accidents. Yet, the same
behaviour could cause fatality or severe bodily injury. The person has to
dwell 113

How to Set Up Safety Management System in 91 Days on the worst that

could happen in that situation. This helps reinforce the need to be safe. The
eventual impact would also include the financial and emotional effect on his
family and other near and dear ones. Taking forward the example, they
discuss how using the wrong tool could cause bodily harm to the extent of
losing a hand.

e. Discuss any challenges or doubts in following safe behaviour: Is there any

extraneous issue which is holding the person back from following safe
behaviour? To take an example, a supervisor on his rounds finds that a
worker is using a blunt tool to do his work. This could lead to fatigue and
eventually an accident. On enquiry, it is found that the worker had asked for
a proper tool, but the tool shop did not have it in the inventory. In such a
case, the supervisor will have to take this up with the tool shop and ensure
that the worker is given the correct tool for the job.

f. Get a commitment to follow safe behaviour now onwards: By this time, it

could be presumed that the worker has identified his unsafe behaviour,
understood the worst implications and also addressed extraneous issues (if
any) which are prompting unsafe behaviour.

By this time, the worker’s mind is primed to follow the new behaviour
consistently into the future. At this moment, the supervisor can take a
commitment from the worker to follow safe behaviour in the future. The
worker is given the freedom to stop work or walk up to the supervisor if he
feels that he is not able to sustain the safe behaviour.

114

BBS Integration into the Organisation (7 days) All of the above is a mature,
adult to adult engagement, which addresses the simple logic of cause and
effect. During this conversation, the Supervisor mostly engages as an equal
with the worker. The worker is not being exhorted to be safe by his boss.
Rather, it is also a discussion with a concerned colleague who cares for him
and wants him to be aware of the implications of his wrong behaviour.

g. Collate, Analyse and Leverage Data of Unsafe Behaviour: Post the

discussion, the unsafe act is recorded and collated to provide data and
ensure that these acts are not repeated. As the data accumulates over a
period of time, it is a veritable treasure house of information in terms of
types of unsafe acts being done at the workplace, the unsafe acts which are
being repeated despite being observed and discussed, the physical areas
with more unsafe behaviour and so on.

In a nutshell, a successful BBS program requires the following pieces

working in unison:

Dedicated involvement from every employee (even the CEO); including

contractors and sub-contractors makes the program even stronger.

A method for collecting and evaluating the data.

Mechanisms for instituting change to policies, procedures, and systems so as

to support safe behaviour.

How does BBS improve Safety at the workplace?

Incorporating BBS into your existing EHS and employee training plans has
organisation-wide benefits. Some of the direct benefits of BBS are as below:

115

How to Set Up Safety Management System in 91 Days O

Improve employee health and welfare

O

Increase job satisfaction

Improve employee retention rates

Lower or eliminate cost of worker’s compensation claims O

Reduce costs related to employee medical leave and absenteeism

The underlying long-term benefits are as below: Proactive attitude to

Hazards and Risks A BBS approach pushes the organisation to look
proactively at hazards and risks, so that the hazards can be removed and
risks mitigated before any accident happens.

This happens because as the leadership, supervisors and workers gain

awareness of hazards and risks, they start noticing things that were ignored
earlier. Potential unsafe acts or conditions are brought to the notice of the
management and action is taken on them. This is significantly better than
having to respond to accidents after they have happened.

This also reduces the underlying costs related to accidents, which are very
high in the long term. To take an example, if a worker loses a small finger in
an accident, the visible costs would be in terms of loss of workday,
medical/hospitalization and compensation to the worker. But the costs which
impact us in the long term are many more. There would be damage to
equipment and tools, legal costs, reduced efficiency of the worker,
replacement/training costs, and last but not the least, loss of goodwill and
reputation. At the minimum, the hidden costs would be five to six times of the
visible cost of the accident. Please find below the Accident Cost Iceberg, 116
BBS Integration into the Organisation (7 days) which shows the significance
of hidden costs in case of an accident.
ACCIDENT COST ICEBERG
INJURY & ILLNESS

COSTS

Medical

Compensation Costs

(Insured Costs)

Building damage

Tool and equipment damage

Product and material damage

Production delays and interruptions

Legal expenses

Expenditure of emergency

supplies and equipment

Interim equipment rentals

Investigations time

Wages paid for time lost

Cost of hiring and/or

training replacements

Overtime
Extra supervisory time

Clerical time

Decreased output of injured worker

upon return

Lose of business and goodwill

(Reference:https://www.researchgate.net/figure/Iceberg-Model -of-Accident-
Costs_fig1_273529533)

From the perspective of an MSME or CGD, this pyramid emphasises that we

do not really see the invisible impact of accidents. We believe that we could
just pay some money and get on with our work. But, despite our best efforts,
any workplace accident has a financial and psychological impact which
slowly drains away money from the organisation.

Significant Improvement in Safety at workplace.

A BBS program’s purpose is to prevent workplace incidents, by focussing on

the biggest reason for accidents: 117

How to Set Up Safety Management System in 91 Days Human Behaviour

which contributes to more than 80%

of accidents at the workplace. Thus, Organisations that incorporate BBS

into their safety culture tend to see a drastic reduction in accidents and
incidents, especially those resulting in injury or fatality.

Further, BBS encourages any modifications in processes to improve safety

while maintaining efficiency. This flexibility keeps workers motivated to
follow BBS and improve safety.

Higher Benefit to cost ratio:

BBS programs are a low-cost investment in safety.

Usually, organisations can implement them with no additional personnel,
limited additional resources, and few interruptions to business activity.
Further, the visible impact is quick and if effectively implemented, the results
can be seen within a couple of months. The Cost to Benefit ratio of a BBS
program is significantly lower than any other Safety initiative.

Employee empowerment to drive Safety: Unlike any other regular Safety

initiative, BBS empowers the employees and workers to understand and
drive Safe behaviour at the workplace. If implemented effectively, BBS

can dramatically transform the way that Safety is viewed by the workers and
employees. It also gives an opportunity for the leadership to engage more
deeply with the workers on safety and foster a culture of Safe behaviour.
When a worker observes an unsafe act and ‘red flags’ the behaviour,
triggering remedial action by the management, he/she feels empowered 118

BBS Integration into the Organisation (7 days) to drive Safe behaviour and
ensure protection of himself and other workers. This has a powerful
psychological advantage as compared to traditional Safety initiatives which
are more driven by ‘fear of punishment.’

Shifting responsibility of Safety from Leadership to workers:

BBS allows workers to take responsibility of their own safety, supported by

the leadership. Worker safety is a key area of contention for most workers’
unions, and BBS helps them to take more control of their safety. This also
has a direct impact on the motivation and employee engagement of all
employees. The management and safety team support the employees by
making changes in procedures, processes, machinery, etc. if required. Also,
they collate data and analyse it to show where are the gaps for correction.

Driving a Safety Culture: Implementing a BBS program can accelerate the

building of a Safety Culture, which is way more powerful in driving safety.
The Safety culture is driven by the BBS process, which encourages workers
to take care of each other’s safety and also to engage in conversations
around safety. These group engagements at peer level are very effective in
bringing a culture of Safety.
Steps for integrating BBS in the Organisation: 7 days Key Elements to a
BBS Program

In a BBS program, employees not only feel responsible for their own safety,
but for their peers’ safety as well, and the organisational culture supports
them acting on that 119

How to Set Up Safety Management System in 91 Days responsibility.

Individuals have the necessary tools and methods, as well as appropriate
person states (e.g., self-esteem, group belonging, personal control) to
actively care for the safety of co-workers. Additionally, the organisation’s
formal management systems and the leaders’ informal management
practices facilitate active caring by encouraging, recognizing, and
reinforcing appropriate behaviour.

The different steps that effectively work for integrating BBS into the
organisation are as follows: Pre-Launch: 2 day:

a. Leadership Support: Leadership support is critical to make a success of

the BBS program. The top management/ leadership will have to firstly lead
by example and show to the rest of the employees that BBS is taken seriously
in the organisation. Also, they would have to communicate very frequently,
sharing knowledge, motivating the employees, highlighting good work and
pushing everyone to follow the BBS rules at the workplace. It’s a good idea
to take the leadership through the complete process of BBS, get their buy in
and also what is expected of them. As the BBS

program progresses and unsafe conditions are revealed, the leadership may
be asked to modify processes, procedures, change/repair machinery and
spend some money in improving the work processes for safety.

b. Identify potential BBS champions: There has to be a team that drives

BBS in the organisation. The first thing that usually comes to mind is that
let’s have the 120

BBS Integration into the Organisation (7 days) Safety department drive BBS.
But that may not work.
The Safety department is more of an enabler who can support the primary
BBS team in this work. The BBS

team should be a set of people from different functions like operations,

warehouse, maintenance, marketing, production, etc. who are going to be
implementing BBS at their workplace in the future. These are people who
have shown an ability to engage with others, have a good idea of Safety and
its importance, and have demonstrated some kind of leadership skills.
Preferably, they should have a good understanding of the processes in their
function. This team will lead the BBS program in their respective functions
and also work as a team for cross learning, helping each other and
gathering/

analysing data.

c. Identifying critical behaviours - In this step, a steering team reviews a

representative selection of the site’s incident reports looking for the
behaviours critical to safe performance. It’s common for the team to
discover 20-35 behaviours that are implicated in 90-95% of recent incidents.
Shop floor employees/workers, who are most familiar with the daily risks of
the job, will sometimes identify additional behaviours that may not be
implicated in incident reports but that they know to be critical to worker
safety. Committee members then define each of the identified behaviours in
operational terms and categorize them for inclusion in a data sheet.

Operational definitions might focus on areas like pinch-points, line-of-fire,

eyes-on-path, and 3-point-contact 121

How to Set Up Safety Management System in 91 Days on ladders or stairs

or scaffolding.

BBS Launch: 4 days:

Now we are prepared to launch BBS in the organisation and below are the
key steps for the same:

O
Communication: All the employees of the organisation need to know that a
change is coming. The larger question is ‘why is the change being
enforced.’ There is a tendency for people to dislike being changed or work
on new things, unless they are convinced about its benefits and are looking
forward to it. The following need to be kept in mind for the initial
communication: O

The initial communication should come from the top leadership and should
clearly enunciate how (and why) BBS will make a positive impact on Safety
and overall wellbeing of the employees.

The communication should also stress on the fact that BBS is not a
complicated process, but rather an informal process of observation and
engagement.

Thirdly, the communication should reassure the employees that the

management/leadership fully support this initiative and all systems will be
aligned to its success.

Finally, the communication should drive a strong ‘sense of urgency,’

underlying the fact that BBS should be taken seriously and implemented at
the earliest, as Safety is of paramount importance and cannot be delayed.

O
There should be an indication that those who take up 122

BBS Integration into the Organisation (7 days) the BBS initiative with rigor
will be rewarded and those who neglect it may be disciplined if required.

This kind of communication will ensure that the employees take the new
initiative very positively and act on it right away.

Committees: There are various committees/teams that can be formed to

oversee the effective implementation of BBS. An Apex committee consisting
of top leadership/

Functional leaders plays the role of providing funds, strategic guidance and
approving change of processes/

procedures. Below the Apex Committee, there can be functional committees

which oversee the execution of BBS program at the workplace, gathering of
data, analysis and suggested remedial action.

BBS Training: This is the core of the BBS initiative, as here the employees
are trained to implement BBS

effectively in the organisation. The key aspects of the BBS training are as
follows:
O

Understand which are the critical unsafe behaviours which are the reason
for more than 70-80% of the accidents.

Know the basic process of Observation, Engagement, Positive feedback,

discuss the unsafe act and implications and finally the suggested change of
behaviour. Be sensitive to human psychology and engage in such a way that
the person is driven to change behaviour.

The training should first be done for the Leadership team and the selected
‘BBS Champions.’ These are the people who will communicate, drive and
create the 123

How to Set Up Safety Management System in 91 Days positive drive for

BBS. Then the training can be spread out to other supervisors. The BBS
champions and supervisors can be prepared as ‘Trainers’ who then can
train small groups of employees in the BBS process.

The training participants are also trained in gathering data on unsafe acts
and conditions at the workplace.

This data is critical to build an understanding of which are the vulnerable

areas or hazards/risks and how to mitigate them.

Post Launch: Ongoing process:

a. Gathering data - Trained observers use the data sheet to measure the
level of exposure to risk in the workplace.

The operational definitions not only provide an objective measure of safe

performance, they help foster a new common vocabulary for safety. While
many sites train supervisors in behaviour-based observation procedures, the
observer corps at most sites is made up primarily of workers who perform
regular observations of their peers, after which they provide performance
feedback.

Gathering of data is a difficult and yet very critical aspect of BBS.

Supervisors may have a discussion with a worker on unsafe behaviour, but
would think twice before putting the details on paper. Some BBS programs
allow the name of the person (who is demonstrating unsafe behaviour) to be
blanked out so that people feel free to fill in the data without fear of
repercussions. Here, it is critical that the leadership reassures the employees
that feedback will not be used against any employee, and only to analyse and
correct behaviour.

124

BBS Integration into the Organisation (7 days) b. Providing ongoing

feedback - After gathering data, observers have informal discussions with
their co-workers about the safe and at-risk behaviours they observed. The
observer points out the places where the employee was performing safely,
providing success feedback and tries to discover the reasons behind any
observed at-risk behaviours. The observer records co-worker’s suggestions
and ideas about barriers to safe work, without recording the employee’s
name. Data recorded in the observation is then analysed by computer
software. Posted reports and charts of work group performance provide
additional ongoing feedback.

c. Removing barriers - Perhaps most critical to improving the working

interface, barrier removal uses observation data to target those areas where
workers are exposed to risk. The steering team uses the observers’ written
comments to identify the number and kinds of remedies needed. Keeping in
mind that the pool of exposure comprises three categories of behaviour
enabled, non-enabled, and difficult, the BBS steering team can tailor
interventions appropriately. In the case of enabled behaviours, or those that
are easily within the control of the worker, the team may rely on ongoing
feedback or training sessions to increase the occurrence of safe behaviour.
In the case of non-enabled behaviours, or those that are impossible for the
worker to perform, and difficult, or those that require extra effort, the team
will work with management to remove barriers in systems or equipment that
are exposing workers to risk.

125

How to Set Up Safety Management System in 91 Days d. Communicating

progress regularly: The BBS core team should drive regular communication
to all the employees, showing how BBS is impacting Safety at the workplace
and improving the lives of all the workers. It should continue to highlight the
good work and also the areas of development, so that there is a constant
dialogue around the subject and it is kept alive and kicking.

e. Committee meetings: Monthly or quarterly meetings of the committees

have to be conducted where the members discuss the progress on BBS,
analysis of data and actions to be taken.

If done well, BBS can significantly lower risk and help eliminate workplace
incidents. But, like any other kind of HSE program, unlocking the full
benefits depends upon a successful implementation.

How is BBS different from a traditional Safety initiative:

It’s important to understand how BBS is different from the traditional safety
initiatives. This would help the leadership to use the correct approach while
implementing it. The key points are as below:

BBS is not a Leadership Initiative: Most safety programs are ‘owned’ by

the leadership. The leadership instructs the safety team/functional heads to
drive the program and holds accountability for its success. BBS on the other
hand is supported by the leadership but driven by employees. They are
equally accountable to making it a success.
126

BBS Integration into the Organisation (7 days)

BBS is not a Punishment driven program: Key Safety programs usually

have aversive control. The employees who do not follow them would be
punished in terms of loss of pay or growth. BBS is more engagement driven,
as it encourages employees to engage and help each other improve safe
behaviour. Its ethos is primarily predicated on positive reinforcement or
encouragement for engaging in safe behaviour. BBS is more of a reward
driven program.

BBS runs on data and its analysis: The data collated on unsafe behaviour is
analysed and the results are taken back to the shop floor. The results are then
discussed with employees and they are made aware of how their unsafe acts
are putting their lives in danger. This is different from Safety programs,
which are just about implementation of safety rules and procedures.

Focusing on incident rates without a focus on behaviour: BBS runs on

data, but the focus has to remain on behaviour. Behavioural safety systems
do not solely focus their attention on reduced accident rates.

Their focus is on encouraging safe behaviour across the board. Providing

positive consequences for safe behaviour explicitly links the desired
behaviour with the reward. Reduced accident rates are merely an outcome of
this process. If a company is solely concerned with manipulating accident
rates, by for example encouraging under-reporting, it could be argued that
its safety management system is not yet mature enough to consider the
implementation of behavioural safety.

127

How to Set Up Safety Management System in 91 Days Chapter 8:

Digitalisation of
Safety Processes
(7 days)

“The danger which is least expected soonest comes to us.”

After having done major part of activities and setting up processes, it is

necessary that processes are made ‘Smart’ and

‘efficient’ for which digitalization has been recommended.

DIGITALISATION OF PROCESSES:

In the modern world of digitalisation, it is important that all the

organisational processes are digitalized, for faster execution, better
efficiency, control, monitoring and transparency. It is essential that
whenever organisation goes for digitalisation drive, all the processes in
various functions be identified, and undertaken for digitalisation. In case, we
limit the process of digitalisation to only a few functions say, only limit to
Production or Maintenance, etc. the desired result cannot be achieved. One
must consider digitalizing all the organisational processes for quick
integration and efficient results.

128

Digitalisation of Safety Processes (7 days) So many digital platforms and the

service providers are available in the market to quickly digitalize all
organisational processes, including operation, maintenance, Safety
processes, HR, commercial, finance, etc.

Safety Management System implementation, monitoring and control should

be digitalized for better efficiency and internal customer satisfaction,
without compromising on safety provisions. One such example is EHS
module available on SAP platform. The module can be customized to
individual organisational needs and enhancements be done. Such digital
platforms help in tracking implementation of Safety Audit recommendations,
recording and following correct tools for incident investigation, carrying out
Risk analysis, Management of Change Procedures, MOCs, issuing work
permits digitally and analysing data for course correction, etc.

There are so many Apps available in the market, which can help in providing
easy access to such digital solutions for all employees, through smart phones
and other gadgets.

It has been seen that while main Operation and Maintenance activities and
transactions are digitalized and data analysed through Data analytic tools,
Artificial Intelligence (AI) etc., but processes related to Safety Management
System, at times, get left behind. Organisations should integrate all such
processes along with Operation and Maintenance processes, for getting
better results. The regulatory requirements of organisations like Petroleum
and Natural Gas Regulatory Board 129

How to Set Up Safety Management System in 91 Days (PNGRB), Petroleum

and Explosive Safety Organisation (PESO), Director General of Mines
Safety (DGMS) and Oil Industry Safety Directorate, Director of Industrial
Safety and Health (DISH), etc. related to Safety management, need to be
built on digital platform, for easy reporting and timely compliance of the
regulatory provisions.

A system be developed for reporting of incidents and accidents in structured

fashion. On a digital platform, each reported incident can be uniquely
numbered, for easy tracking of the incident and later linking it with the
investigation outcomes and lesson learning, etc. Reported incidents should
be investigated thoroughly through a multi-disciplinary committee, to find
out the root cause and to incorporate corrective measures for avoiding
similar incidents in the future. Such incident investigation reports can also
be placed on the digital platform and widely circulated for taking best
advantage of learnings from the incident.

The advantages of digitalisation adoption, the use of advanced technologies,

and what form it takes will inevitably differ from one industry to another.
Discrete manufacturing benefits include collaboration between cyber
physical systems; using the Internet of Things (IoT) and the internet of
services to adopt digitalisation across the whole value chain leading to
increased production flexibility and better productivity performance.
From the ‘virtual’ world, where integrated engineering can be supported
through a cloud-based platform and operating system, areas such as data
analytics and asset performance management can be married to the ‘real’
world 130

Digitalisation of Safety Processes (7 days) of integrated operation, courtesy

of secure connectivity, preventative maintenance regimes and the use of
digitally enhanced products. Such integration offers the potential for
improving safety by reducing the scope for systematic errors throughout the
lifecycle.

Big or smarter data has the real potential to contribute to process safety in a
number of areas such as supporting plant reliability and asset integrity,
steady state Process control, process optimisation, accident investigation,
delivering the collation of leading indicators for process safety, as well as
accessing available data from maintenance systems and incidents to better
promote future process safety.

Finally, while digitalisation promises many benefits such as improved

productivity, reduced time to market, improved product quality, and
enhanced process safety, the additional level of integration across the plant
lifecycle, and between its various stakeholders, brings with it added
challenges for cyber security by arguably increasing the attack surface even
further.

The extra connectivity needed to implement digitalisation requires additional

consideration of cyber security measures to be put in place to protect the
control system and the associated datasets.

The adoption of a digitalisation strategy is now the way forward for many
within the industrial base, offering clear benefits in a number of areas;
process safety.

A new breed of strategic business initiative has come on the industrial scene
that’s having a profound impact on 131

How to Set Up Safety Management System in 91 Days Operational

Excellence and continuous improvement: Digital Transformation. This topic
is actively being discussed in executive suites and plant managers’ offices
across all industries. Projects to digitalise the plant, the enterprise, and the
value chain are underway, with more coming.

These digital initiatives impact how businesses operate from the shop floor
to the top floor, and across global business networks.

Digital Transformation is More than a Buzzword Is Digital Transformation

for real? In short, yes, driven by the availability of inexpensive computing
power, sensor technology, and pervasive internet connectivity. Four main
digital technology trends are enabling new business models, processes, and
products not before possible.

The Internet of Things (IoT) is enabling networks of smart connected devices

and equipment that use sensors to gather many types of data that can be
mined for insights, and trigger intelligent actions, even without human
intervention.

Big Data Analytics tools can analyse large volumes of diverse operational
and business data, enabling Predictive Analytics and improved decision-
making.

Mobile applications are driving employee engagement by making

information and capabilities available anytime; anywhere they’re needed.
O

Cloud computing is enabling much more cost-effective, flexible deployment

of robust business applications than was possible before with expensive on-
premises systems.

132

Digitalisation of Safety Processes (7 days) Digital technologies are indeed

changing the way business is done by enabling new capabilities. EHS
managers and professionals will benefit from awareness of these trends and
adapting accordingly.
New Risks Are Being Introduced
Digital Transformation can change how businesses operate, which has
major implications for EHS management regarding new risks that need to be
managed. Consider two examples: 1. New business models mean new
workplace risks. As formerly product-based businesses become more like
service providers, new roles and workplaces may be created. For example,
an aircraft-engine manufacturer selling hours-in-service rather than an
engine may have new off-site job roles for inspection, maintenance, repairs,
etc. with a new set of hazards.

2. Networked production systems pose greater cyber security threats.

Manufacturing and industrial operations are being revolutionized by the IoT,
with networks of smart connected devices, assets, and operations. Such
systems are more vulnerable to security breaches by cyber-intruders, with
associated safety and environmental impacts. After all, security lapses create
risk, and risk decreases safety. Consider that in many languages including
French, Italian, and German security and safety are described by the same
word.

Digital technologies are accelerating the pace of change in organisations

and operations. With change comes risk, 133

How to Set Up Safety Management System in 91 Days and the need for
rigorous systems to manage it effectively.

The EHS function plays a vital role in operational risk assessment and
control, and management of change. These processes need to be better
defined and executed than ever to be a part of the overall EHS management
system.

Digital Transformation Creates Opportunities for EHS

The digital revolution also presents opportunities to incorporate new ways of

managing EHS. Innovative technologies can help better operationalize EHS
management systems to drive continuous improvement. The use cases below
just scratch the surface of what’s possible.
O

Improved machine and equipment safety with the IoT-sensor-equipped

manufacturing lines capture extensive information on production, safety
systems, and asset performance, such as operational status, event sequences,
stoppage codes, motion monitoring, and so forth.

With IoT-enabled Smart Connected Assets, EHS and operations personnel

now have better visibility to such data, as well as advanced analytics
capabilities, and can use it in root cause analysis of incidents and accidents
for preventive action.

Predictive Analytics and leading indicators – it’s now possible to combine

the analysis of EHS data with vast amounts of operational data from other
business systems such as EHS, HR, asset management, and manufacturing to
identify and mitigate priority risks predictively. In the case of one
manufacturer, such analysis showed that factors such as overtime hours and
completion of preventive maintenance activities were 134

Digitalisation of Safety Processes (7 days) correlated with incident rates. By

monitoring and acting on these leading indicators, incident rates were
reduced significantly.

Mobile applications to increase employee engagement.

Mobile applications are widely available as part of most EHS management

software platforms. Incident management, including safety observations, is
among the most common apps, along with audits and inspections.
Equipping employees with mobile apps helps them to actively engage in EHS
programs and processes such as a behaviour-based safety and helps build
the desired culture around EHS and safety. This also allows larger amounts
of data to be collected, in turn enabling better analysis.

The Promise of the Digital Transformation of EHS

Management.

Digital technologies such as the IoT, Big Data, Mobility, and Cloud offer the
potential to improve EHS performance in new and meaningful ways. The
digitalisation of EHS

management is already occurring, and helping organisations make EHS

processes more automated and intelligent, and perhaps more importantly,
more integrated with core business operations across extended supply
chains.

EHS managers and professionals are well-advised to get involved in their

organisation’s Digital Transformation initiatives, both to help better manage
the risks, as well as take advantage of the big shift as a means to better
operationalize EHS management systems.

135

How to Set Up Safety Management System in 91 Days Key benefits of

implementing Digital Safety Management Systems:

Easy to use

Speed of use
O

Visibility of data across multiple sites O

Trend analysis reporting

Tracking of action management

Credibility with younger employees

Drill-down analysis of data

Accurate data

Live updates to policies and procedures O

All systems in one place – accessible and easy to find Digitalisation means
that information of all kinds is handled and networked electronically,
thereby permitting powerful management of the information. This enables,
for example, work schedules and instructions to be prepared for specific
situations in consideration of the progress of work, the product
configuration, and the workers’ experience.

Information can be presented not only on conventional monitors but also on

smart glasses, or can be projected into the working area. These new forms of
presenting information link it directly to the work object (see image p.

3). The overhead of searching for relevant information and the

corresponding workload for the workers can thereby be reduced
considerably. It is important here for the actual form taken by digitalisation
– such as the selection of relevant information and the form in which it is
presented – to meet 136

Digitalisation of Safety Processes (7 days) the specific needs of the company

and thus to be accepted by all parties involved.

Computer-based handling of large volumes of information permits better

planning of personnel deployment. Workers’

individual stress/strain situation can be considered, in addition to their

availability and qualifications, when they are assigned to specific tasks. The
stress/strain situation can be determined and considered in the planning
process with computer support by means of worker, workplace and task
profiles in accordance with established procedures, such as the key indicator
methods1. A system of this kind can also be used to assign certain tasks to
each person at least once within a defined period, in order for a sufficient
level of practice with the task and thus also familiarity with the OSH
information related to it to be retained. This includes strategies for
systematic rotation that ensure that regular changes occur in the
stress/strain situation and that stresses are consequently better distributed
among the workforce.

137
How to Set Up Safety Management System in 91 Days Chapter 9:

Safety Leadership and

Culture Building
(15 days)

“Culture eats Strategy for breakfast” – Peter Drucker No management

system can work well, without inspiring, decisive and energetic leadership.
Secondly, to sustain the process of “Safety Management System” in the
organization, it is necessary to have good safety culture. These two
important areas will be dealt with in this chapter, in detail What is Culture
and how it defines the Organisation?

There is a famous story of two young fishes who are moving around in the
river, nibbling at plants and generally having fun. An old fish passes by,
swimming slowly and languidly. The old fish looks at them and smiles,
commenting, “Hi, young ones, how is the water today?”

The young fishes smile back and move on without saying anything. A few
moments later, once the old fish has swum out of earshot, one of them turns
to the other and says, “What is water?”

138

Safety Leadership and Culture Building (15 days) Something very similar
could be said about Culture. We are social animals and learn to live with
people right from the day we are born. We rapidly imbibe habits, norms,
behaviour and ways of engaging which fall below our awareness and are
anchored in our habits. This ‘invisible’ matrix of values, beliefs, mindsets,
behaviour and social engagement processes adds up to be our culture.

Organisational Culture has been a topic of discussion for a long time now,
but not easily understood. Management experts have always understood the
importance of culture in the success of an organisation. Many Leaders have,
usually with a common-sense approach, leveraged organisational culture to
drive success. But few people have come up with a fail proof formula to
shape a great Organisational culture which keeps people engaged and
fulfilled while driving sustainable success.
A culture is like the Operating System (OS) in a computer or a smart phone.
It is the ‘platform’ on which the different apps, emails, programs and tools
are being run by the user. It is not visible, so to say, but has an overpowering
influence on every operation being run in the gadget.

Every interaction in a group, whether between two individuals, family, team,

friends, society, community, organisation or nation, is influenced by the
culture of the people. Though it is not spoken about, it is demonstrated in
various ways. Below are some of the ways by which the culture of a group
can be assessed: a. Observed regular behaviour: How people greet each
other, sit together, interact, body language, etc.

139

How to Set Up Safety Management System in 91 Days b. Rituals and

Celebrations: The way they eat, engage with each other, celebrate success or
share sorrow.

c. Artifacts: The physical layout of the surroundings.

d. Espoused Values, Beliefs: Which values are talked about and cherished in
the group like honesty, strength, individuality, team work, etc.

e. Underlying assumptions: What are the beliefs (accepted as true) by the

members of the group.

The Culture of a group is formed and shaped as new people join the group
and some of them leave the group. It is a set of rules for engaging with each
other, which ensure the survival of the group.

One of the most comprehensive definitions of Culture is taken from the book
“Organisational Culture and Leadership” by Edgar Schien. It is as given
below:

“The culture of a group can be defined as the accumulated shared learning

of that group as it solves its problems of external adaptation and internal
integration; which has worked well enough to be considered valid and,
therefore, to be taught to new members as the correct way to perceive, think,
feel, and behave in relation to those problems.
This accumulated learning is a pattern or system of beliefs, values, and
behavioural norms that come to be taken for granted as basic assumptions
and eventually drop out of awareness.”

If a group is asked to behave in a way which is conflicting with the culture,

that behaviour would be rejected by the 140

Safety Leadership and Culture Building (15 days) group. Thus, if an

organisation strategy is implemented which does not align with the culture
of the Organisation, it would not be successfully implemented by the
employees of the organisation.

To take an example, say there is an organisation which has a very strong

culture of maximising production at the manufacturing plants. There is a
strong demand for the product and the best way for the organisation to make
money is to ensure that the manufacturing is maximised.

Thus, all the functions are giving top priority to ensuring that month after
month, the production is at the highest possible number. Thus, the plant
manager is always finding ways to keep the machines running and
production is smooth. The maintenance team is focussed on ensuring that
there are no breakdowns. The management is always willing to invest in new
machinery or any other equipment to support production.

Over a period of time, the number of accidents start going up, and workers
start getting hurt. The top management decides to prioritize safety. A Safety
program is initiated in the plant, which requires the plant manager and his
supervisors to follow safety guidelines. These guidelines are very good for
Safety but they slow down the production. In such a case, the plant manager,
supervisors, and employees would struggle to embrace the Safety guidelines.
There would be resistance to the constraints and workers would start
ignoring or bypassing them. A few months later, the management would
realise that the Safety program has not been properly implemented.

Similarly, let’s say an organisation has an autocratic culture.

The supervisor gives directions to the subordinate and orders are followed.
There is less empowerment of employees down 141
How to Set Up Safety Management System in 91 Days the hierarchy.
Decisions are taken unilaterally and supervisors do not follow consensual
decision making. The management realises that this management style is
creating a suffocating environment and good, bright people tend to leave the
organisation. They try to bring in a more consensual style of management.
As the autocratic style is deeply entrenched in the Culture, the consensual
style would be rejected by the employees and will find it difficult to be
implemented.

Thus, Culture is the most deeply embedded, and very powerful aspect of the
organisation. It drives the way employees engage with each other. If any new
idea has to be truly implemented, it should either become a part of the
culture or should be aligned to it.

What is a Safety Culture and why we should have it?

What is a “Safety Culture”?

A safety culture is the result of a set of core values and behaviours that stress
safety as the priority. While values are at the core of every culture, an
organisation’s culture is ultimately defined by what is said and done,
behaviours define culture. While each organisation has, or should have, its
own description of what an ideal safety culture is, based on its values, there
are key components that should be common to all.

A safety culture is one where the concept of Safety is encapsulated by the

mindsets, attitudes, and behaviours of workers, supervisors, managers, and
owners toward safety in the workplace. A positive safety culture in the
workplace is absolutely a vital part of a successful and effective health and
safety program.

142
Safety Leadership and Culture Building (15 days) We may find the idea of
building or changing your safety culture daunting because the “way it is” at
your workplace has fallen into a pattern of complacency. The effects of
complacency can be catastrophic: accidents, injuries, illnesses, even loss of
life could result. To avoid this, it is critical to work towards a Safety Culture
in the organisation.

Many organisations have made an attempt to understand Safety Culture and

how to implement it in an Organisation.

Dupont developed the ‘Bradley Curve’ with various stages which lead to a
Safety Culture. Another popular concept is of the ‘Safety Culture Ladder’
developed by Shell. All these concepts have helped build a good
understanding of how a Safety culture can be incorporated. But these are
broad guidelines and each organisation has to develop a customized process
as per their own challenges and needs.
The Safety Culture Maturity Matrix by Shell
(Reference:https://www.google.com/search?q=Safet+culture+maturity+ma
trix+of+shell&source=lnms&tbm=isch&sa=X&ved=2ahUKEwjnkImV48

DuAhXxzzgGHQd8BmgQ_AUoAXoECBAQAw&biw=1280&bih=68

9#imgrc=oFMn8afQBLwlzM)

143
How to Set Up Safety Management System in 91 Days the journey to
excellence

Natural instincts
Organisationa

Hierarchy

ate

Maturity

yr

Individual

Team

Injur

Behavior

Reactive

Independent

Interdependent

Obedience

Dependent

Comprehension/

Team sprit

Safefy by natural

Management

integration

Recognition
instinct

commitment

Personal commitment Collective

Responsibility of

Discipline

Involvement of

responsibility

Safety Officer

Rules/proceedurs

organization

REACTIVE

PROACTIVE

Present

Objective
The Bradley Curve by Dupont
(Reference:https://www.linkedin.com/pulse/bradley-curve-tadio-bogdan)
Let’s try to understand how a Safety Culture is formed in an organisation.

Recently, during a culture shaping engagement with an Oil and Gas

company, a senior official mentioned that there is a serious conflict in
bringing in a Safety culture in the contractual staff. The main problem is that
they do not use any PPE properly and ignore its value. They had tried to
discipline the contractors (who were providing the contract workers) and
even levied penalties, but the contract workers (coming from the poor
section of society) would either forget to bring the PPE or just not use it at
the workplace.

“How do I make them realise that this PPE could save their lives? Is it that
difficult?” …. his classic question brings forth the fundamental challenge of
including a new value in an organisational culture.

144

Safety Leadership and Culture Building (15 days) Another company went for
investing heavily in training.

They set up workshops for all their shopfloor workers, where the workers
spent almost a full day (impacting production significantly) to learn about
Safety. After almost six months of rotating training, the workers were still
going back to their old behaviour. They were finding the new expectations
too cumbersome and difficult. This example highlights the interplay of social
learning, environment and sub cultures which undermine the impact of
traditional forms of learning.

No amount of training can ever help in changing behaviour only.

As is true for any value system, it takes time for a new value to get
incorporated in the Culture of an organisation.
Initially there is a resistance of the employees to something new, which is
seen as being forced on them. They find reasons to not do it and create
hurdles for its success. This is a stage when the employees are still trying to
understand what is safety, what are its implications and how to implement it
successfully. They are not really willing to change their style of work or
priorities for Safety. When an accident does happen, they react to it with
what best resources are available.

In this stage, the organisational relation to safety is described as below:

Employees are part of the problem, not of the solution.

Neither employees nor managers at any level feel responsible for safety or
have a commitment towards it.

Bad luck is widely believed to be the main factor behind accidents.

Indeed, accidents take place and remedial action is 145

How to Set Up Safety Management System in 91 Days taken afterwards,

through hurried measures that do not address the root of the problem.
O

Safety is given second priority to the core values of the organisation.

The primary approach is to ignore Safety as far as possible.

At this stage, the top leadership has to play a key role of imposing Safety in
the organisation. The new rules and guidelines exhort the employees to
follow Safety. There is a sense of discipline and a process of reward and
punishment.

There is continual communication and the leaders demonstrate safety and

‘walk the talk’ so that employees understand that it is important. A Safety
structure is set up and the Safety status is reviewed and action taken on a
regular basis.

As the leadership sets up the Safety action and review committee and
establishes continual communication on Safety, the employees start adhering
to Safety out of fear and to ensure one’s place in the organisation. Here the
Supervisor or the employee are not interested to follow Safety but as they are
afraid to lose their job or be disciplined, they follow the procedures and
rules.

In the next stage, the organisational relation to Safety can be described as

below:

Employees continue to be part of the problem, not of the solution.

O
Appointed persons are in charge of safety. They set up rules, guidelines and
procedures for the other employees to follow.

146

Safety Leadership and Culture Building (15 days) O

Safety is achieved when these rules are followed.

Accident rates decrease, and it is believed that injuries happen because

safety rules are disregarded.

A reward and punishment process is established and employees start

reluctantly following the Safety norms.

Safety is still not considered a core value, but more of a priority to be

managed at the workplace.

Significant effort of the organisation is still spent on reacting to accidents

and mitigating damage after it has happened.

O
The primary approach is fear.

As the employees further engage in Safety and follow the procedures, they
start developing a sense of responsibility for Safety. But here, they are only
concerned about showing themselves as good employees and concerned
about their personal safety. They are not really concerned about the Safety
of others or the organisational property/equipment.

There is a shift in the way they perceive Safety. They do not have to be
reminded about it and now develop a habit of following procedures and
guidelines. The reward and punishment has to be implemented lesser than in
the past.

Here the employees have finally seen the value of Safety for themselves and
feel it is good sense to stay safe.

At this stage, the organisational relation to Safety can be described as

below:

Employees are part of the solution, not of the problem.

Employees and managers at every level take responsibility 147

How to Set Up Safety Management System in 91 Days for safety through the
proper use of safety equipment, procedure compliance, training and
individual commitment.

O
Safety is achieved when everyone’s looking after themselves.

Accident rates decrease further, and it is believed that injuries happen

because of a lack of self-protection.

The primary approach is a sense of responsibility for one’s own safety.

As the organisation progresses forward, engaging the workers through

communication, leadership ‘walk the talk’

and prioritizing Safety, the employees start engaging in groups while being
Safe. Now the employees do not just think of their safety, but also of their
team members. Safety is discussed at the workplace and everyone
collaborates to drive Safety. Employees look out for their co-workers when it
comes to risks and are willing to spend time in educating or training others
in Safety.

At this stage, the organisational relation to Safety can be described as

below:

Teams of employees are the solution.

O
Employees and managers at every level take collective responsibility for
safety, as a team. Safety is regarded as part of the workload, and risk-taking
is not accepted from any team member.

Communication, training and involvement are key to improving safety, as is

the shared pride of belonging to a team and an organisation.

148

Safety Leadership and Culture Building (15 days) O

Injuries at work are not acceptable. There is a serious commitment to

achieve a zero accidents goal within the organisation.

The primary approach is of Pride in being safe.

Safety culture and performance are related.

Equally, it is possible to establish a link between safety culture and

performance. Both concepts are related, as can be seen by plotting responses
from different companies to the DuPont’s Safety Perception Survey on the
Bradley Curve (median and deviations are shown).

Role of leadership in implementing a Safety Culture A robust safety culture

is the combination of attitudes and behaviours that best manages the
inevitable dangers created when humans, who are inherently fallible, work
in extraordinarily complex environments.

Leadership plays a critical role in the implementation of a Safety Culture.

The key areas in which the leadership drives Safety are as below:
O

Clarifying the Safety Value and what are the behaviour expected from
employees: Employees will be able to bring about a change only if they
know what is the change expected of them. Many times, due to poor
leadership vision, the employees are not clear of what is expected of them
and end up getting confused. Thus, the implementation of Safety culture does
not happen.

Walking the Talk: The leaders should demonstrate adherence to all Safety
norms at all times. They are 149

How to Set Up Safety Management System in 91 Days being watched by the

employees and if the leader falters even once in following norms, the
employees will consider that Safety is not important. Lead by example by
following all safety policies and encouraging employees to do the same. If
management commits to safety, employees will follow suit. Employee buy-in
is crucial to a positive safety culture. Workers won’t buy-in to safety if they
don’t see policies and procedures being followed by their superiors. Safety is
more than talking the talk; it’s walking the walk.

Psychological safety that ensures speaking up is not associated with being

perceived as ignorant, incompetent, critical or disruptive (leaders must
create an environment where no one is hesitant to voice a concern and
employees know that they will be treated with respect when they do).
Creating psychological safety is a fundamental responsibility of leadership
in creating a safety culture.
Psychological safety is an environment where no one is hesitant to voice a
concern about a patient or anything that puts the organisation at risk.

Fostering a learning system where engaged leaders hear customers and

employees to understand if there are any Safety issues and promote
improvement to increase safety and reduce waste. Leaders are the keepers
and guardians of these attitudinal norms and the learning system.

Dealing with unacceptable risk: Effective leaders must also address the
behaviours that create unacceptable risk and send a very clear message that
these behaviours will not be tolerated. The real test of leadership and 150

Safety Leadership and Culture Building (15 days) organisational culture

comes when someone does act in this way. It is really not a question of ‘if,
but rather when’

this will occur. Leaders need to know that their response will be watched
widely and closely, and will send a very powerful message within the
organisation about its culture. If leaders are consistent in holding people
accountable for unacceptable behaviours that create risk, they will have laid
the foundation for a strong safety culture.

Communication: Leaders need to communicate all the time on Safety. They

should bring up new ideas, reward those who adhere and discipline those
who do not follow safety norms. There needs to be a dialogue between the
leader and other employees, encouraging open thinking and innovation in
driving safety. This is critical to embed a Safety Culture. A great way to
increase safety communication while building a positive culture is to hold
weekly or monthly safety talks. Increase worker buy-in by having them lead
the talks. Make safety policies readily available electronically or on paper,
and use your Intranet to communicate safe practices, expectations, and best
practices when it comes to safety in your workplace.

Key steps to initiate a Safety Culture: Ongoing Four Steps to

Implementing a Culture of Workplace Safety Initiating a strategy that
impacts workplace culture requires extensive planning. Employees at all
levels of the 151

How to Set Up Safety Management System in 91 Days organisation must be

committed to its success. The following steps can kick start the process: Step
1: Establish a sense of “Urgency to Change.”

There is a tendency for people to ‘not change.’ This inertia will also come
into play when we try to bring in a culture of Safety. The first step for the
leadership is to recognize that a current system that relies on systematic
preventative measures and controls and reactive training and behaviour
correction is not successful at sustained workplace safety. This conclusion
should be backed by data, research done in similar industries and logical
thinking as to how a Safety culture will add distinct value to the company
and, more importantly, the employee or employee groups.

Once this logical basis is established, the leadership has to drive a sense of
urgency for change. The hierarchy has to be galvanised to communicate and
drive this message across the organisation. The leadership can expect
resistance at all levels and functions, as people are jolted out of their regular
work lives and pushed to do something which is different and new. The
following steps are helpful for the leadership to drive the ‘Urgency for
change.’

1. What are you demonstrating?

Leaders communicate by their example. The leader has to first start

demonstrating the urgency that he wants others to show. If the leader is
‘talking’ about something but not really demonstrating it, he will not truly
succeed in changing others. He should be really excited about the change,
believe in it and talk about it in a positive way. Further, he should be 152

Safety Leadership and Culture Building (15 days) seen demonstrating it all
the time. When others see the leader engaging, demonstrating and talking
about something with energy and commitment, they feel the ‘need to be
included’

in this potentially successful story. Thus, they are inspired to change.

2. What is the change of Behaviour you are looking for?

The leader needs to clarify to the employees. “Let me explain what is

happening and what I need from you. If I am unclear, ask me questions.”
Clarifying questions often reveal the level of understanding employees
possess. The gap between recognition and response will reflect their
capacity to judge the situation correctly then act with urgency. Other times,
explanations may not help. “Just do it… I’ll explain later” may be the
appropriate response for an overwhelmed employee, so long as there is a
relationship of trust.

The leader has to repeatedly communicate the change that is required in the
employees. Just making general statements like ‘Become safer’ or ‘Safety
should be seen in every action’ will not help. The behaviour will have to be
drilled down to specific actions that are validated as the right behaviour by
the organisation. As the employees see the leader demonstrating the
behaviour and talking about it, they will slowly start embracing it.
3. Clarify the consequences.
Fostering a sense of urgency is more difficult when teams fail to fully grasp
the real consequences of the present 153

How to Set Up Safety Management System in 91 Days behaviour.

Consequences have to be real and brought to their attention repeatedly.

A few years ago, I observed a leader driving a Safety Culture in the

organisation. He explained the consequences of the unsafe behaviour
prevalent in the organisation and asked the employees to start demonstrating
change right away. Most of them were hedging or giving excuses. He was
silent for a while and then said, “Your unsafe behaviour is going to cause
losses of 5% on the quarterly profits, and we cannot delay the change. If you
do that, be ready for a drop in your quarterly incentives.”

4. Use urgency to persevere toward victory despite the pain

Urgency helps to manage the pain of change. It forces the mind to focus and
look at a change in the ‘here and now.’

But that works if it is persevered and brought back again and again. If the
sense of urgency is allowed to fizzle out, the passion will dry up like a pond
in hot summer. Like a child touching a hot stove, urgency declines or
improves in an organisation in proportion to the organisation’s capacity to
properly perceive the pain/performance connection. Urgency helps us push
through pain rather succumb to it. But it is kept alive by being reminded of
the consequences again and again.

5. Recognize employees who exhibit a sense of urgency Changing your

team’s sense of urgency may take time.

Success begins with small steps. Reward incremental successes by

recognizing your team members who set an 154

Safety Leadership and Culture Building (15 days) example for others in
demonstrating a sense of urgency. A simple “Congratulations” or “way to
go!” goes a long way.

This also creates a sense of urgency which eventually leads the group in the
right direction.

Step 2: Create a Plan of Action

Once the sense of urgency has been set and the key behaviour has been
understood, the next step is the body of the change. How exactly do you wish
to see the team, group or organisation bring in the Safety Culture? The key
points here are: a. Define the elements of a new culture of workplace safety.

b. Establish clear goals, measurement tactics, enforcement procedures, and

feedback systems.

c. Build a timeline for organisational change and set benchmarks for short-
term wins and long-term milestones.

d. Keep it SMART (Specific, Measurable, Action oriented, Realistic,

Timebound). This will help ensure that the action is doable and progress can
be measured.

Step 3: Plan for Implementation

Introduce workplace safety as the new culture and

“lifestyle” of the organisation. This is where you move from Safety being one
of the priorities to being the first priority.

Some steps which lead towards this are: a. Administer a brief safety attitude
questionnaire to obtain 155

How to Set Up Safety Management System in 91 Days baseline information

of employees’ existing knowledge, future needs, and preferred training or
learning style.
b. Provide general training to all staff with an explanation of the general
principles and goals.

c. Encourage employees to consider and share outside-the-box ideas to

improve job efficiency and safety and promote routine feedback.

Step 4: Put Energy into Implementation and Sustainability

Launch the new program with a spirited kick-off event promoting positivity
and overall commitment. Regular communication, consistent support, and
ongoing feedback at all levels of the organisation are critical for the success
of the program.

Step 5: Measure the progress:

This is what keeps the energy maintained during the change. The
measurement has to be consistent, objective, and based on data. It should
clearly bring out where are the lapses in driving the Safety Culture and
which are the areas of success. It should not be judgemental or start
demarcating in terms of ‘success’ or ‘failure.’ In a culture transformation,
there are no individual or sub group successes or failures. The best example
is of a family. The parents (Leaders) are fostering a specific culture of
engagement at home, which they believe would work to the benefit of the
family and the individuals.

The children (employees) and younger relatives of the family are trying to
imbibe those changes, and there is a process for 156

Safety Leadership and Culture Building (15 days) agreeing to imbibe and
demonstrate willingly. Some are faster and some are slower. The
measurement of success should be used to help everyone align to the new
rules of culture.

Supporting the implementation of Safety Culture: Some key steps which

can help in implementation of a Safety culture are as given below: 1.
Communicate

A great way to increase safety communication while building a positive

culture is to hold weekly or monthly safety talks. Increase worker buy-in by
having them lead the talks.

Make safety policies readily available electronically or on paper, and use

your Intranet to communicate safe practices, expectations, and best
practices when it comes to safety in your workplace.

2. Provide Training

Training employees demonstrates your commitment to safety. Trained

employees also embrace safety culture more readily because they are aware
of hazards and the effect that they can have on maintaining workplace safety.
Review key messages from training sessions often to reinforce learning.

3. Lead by Example

Lead by example by following all safety policies and encouraging employees

to do the same. If management commits to safety, employees will follow suit.
Employee buyin is crucial to a positive safety culture. Workers won’t buyin
to safety if they don’t see policies and procedures being 157

How to Set Up Safety Management System in 91 Days followed by their

superiors. Safety is more than talking the talk; it’s walking the walk.

4. Develop and Implement a Positive Reporting Process

Reward employees who report safety hazards or concerns.

A positive safety culture will be much easier to build and maintain when
employees feel comfortable reporting concerns and believe that the
reporting process is positive.

5. Involve Workers, they are more important!

Building and maintaining a safety culture starts from the ground up. Another
way to build strong employee buy-in is to involve them in the process. Ask
them what they would like the reporting process to look like, or get their
feedback on current communication methods.
Addressing Common Safety Culture Challenges Behaviour based safety is
neither an absolute cure nor a quick fix for an ailing workplace safety
program. An organisation implementing a Safety Culture is bound to face
challenges. Here are some things to keep in mind: O

Employees who are overconfident and complacent may require additional

instruction and incentives to change their behaviour.

Turn the lens around and evaluate one’s own at-risk behaviour to avoid
overlooking any areas of concern.

As a Safety Culture is an evolving process, results may not be immediately

evident. Communicate progress to 158

Safety Leadership and Culture Building (15 days) help ensure all levels of
the organisation stay committed to continuing the momentum of a behaviour
based safety culture.
In An Overview
Preventative measures such as administrative and engineering controls are
only effective when used properly.

The safety of every employee relies on the conscious choice made by each
individual whether or not to use those controls appropriately.

BBS programs have successfully reduced accident rates across many

industries over time. BBS is an innovative solution for producing results that
traditional safety programs cannot deliver. Organisations can be confident
that permanent safety improvements will be achieved through cultural
change.

Some things that show you have initiated a Successful Safety Culture:

1. You can see good working relationships at all levels.

Trust is an essential component of an effective safety culture. Mistakes and

missteps, while unfortunate, provide invaluable learning opportunities.
These situations create an opportunity for conversation: What happened?
Why did it happen? How can we ensure it doesn’t happen again?

Employees who have a good relationship with management are more likely
to speak openly and honestly about what is working, what is not, and what
could be improved.

2. Safety is part of the day-to-day mindset.

Safety isn’t treated as something separate from daily 159

How to Set Up Safety Management System in 91 Days work habits – an add-

on to be discussed during weekly safety meetings or at shift changes. Safety
is an attitude, a mindset, that is part of every conversation and decision.

3. Your entire workforce is contributing towards reducing Safety hazards.

Establish systems and processes for correcting hazards as quickly as
possible. Maintaining good internal communication will not only create a
safer workplace, it will improve employee engagement. When responsibility
for safety falls on all employees, from front line to management, employees
are more committed to safety initiatives.

4. When it comes to Safety, there is Brainstorming not

“Blamestorming.”

No one is blamed for near misses or incidents. Instead, brainstorming is

done to identify root causes and the best solutions. At-risk behaviours often
lead to incidents, and there are usually organisational systems and practices
that unintentionally encourage those at-risk behaviours. It is important to
adjust/correct the systems and then establish accountability to encourage
safe behaviours.

5. Employees feel comfortable stopping at-risk behaviour when it’s

observed.

They need to be able to speak up without fear of retaliation or retribution.

Employees should be encouraged to recognize and praise others when safe
behaviour is observed.

While coaching and feedback are important for performance improvement,

positive reinforcement is critical for building safe habits.

160

Safety Leadership and Culture Building (15 days) A strong safety culture is
created when all your employees are actively involved in giving positive
reinforcement for behaviours consistent with the desired culture.

6. Success is celebrated by the team on a regular basis.

Praise and recognition shouldn’t be reserved for just your company’s safety
record. Focus on what is being done every day, all day, to achieve that
record.
7. Discipline seems to be the last resort.

Fear of discipline drives under-reporting, stifles engagement, and actually

works against building a culture of safety. The fear of discipline tends to
deter employees from reporting incidents, which cripples the organisation’s
ability to learn from mistakes and work to become more proactive.

When the use of discipline outnumbers the use of positive reinforcement,

morale drops, trust is weakened, productivity dips, teamwork suffers, and
employees become disengaged.

Intentional, positive reinforcement of desired behaviours leads to rapid

change, employees begin to not only demonstrate desired safety behaviours,
but they reinforce those behaviours in others.

8. Employees pride themselves on being safe.

The last bastion of any strong cultural value is a sense of pride about it in all
employees. When employees speak with pride about the Safety initiatives,
programs and successes in the organisation, it has truly permeated their
value system and holds top priority.

161
How to Set Up Safety Management System in 91 Days Chapter 10:

Recognizing Safety as a

Core value in the

Mission and Vision
Statement: (5 days)

“A core value is like a lighthouse, showing direction in the darkest of nights,

ensuring the organisation navigates through any challenge”

After having done major part of the work, a very important area for
achieving excellence in Safety Management is to insert

“Safety” as core value in the mission and vision statement of the

organization. It helps in understanding the organization’s vision towards
“Safety Processes” and the importance leaders wish to attach to “Safety
Management” in business activities.

This chapter elaborates the concept and logic behind such recommendation.

The Importance of Core Values:

Core values are what support the vision, shape the culture, and reflect what
a company values. They are the essence of the company’s identity – the
principles, beliefs or philosophy of values. Many companies focus mostly on
the technical 162

Recognizing Safety as a Core value in the Mission and...

competencies but often forget what are the underlying competencies that
make their companies run smoothly —

core values. Establishing strong core values provides both internal and
external advantages to the company:

O
Core values help companies in the decision-making processes. For
example, if one of your core values is to stand behind the quality of your
products, any products not reaching the satisfactory standard are
automatically eliminated.

Core values educate clients and potential customers about what the
company is about and clarify the identity of the company. Especially in this
competitive world, having a set of specific core values that speak to the
public is definitely a competitive advantage.

Core values are becoming primary recruiting and retention tools. With the
ease of researching companies, job seekers are doing their homework on the
identities of the companies they are applying for and weighing whether or
not these companies hold the values that the job seekers consider as
important.

Core values are the difference between ‘one of the priorities’ and ‘the most
important’ priority.

Core values are NEVER compromised.

We have listed below a list of 10 core values that are common across
organisations in different industries: 1. Accountability – Acknowledging and
assuming responsibility for actions, products, decisions, and policies. It can
be applied to both individual accountability 163

How to Set Up Safety Management System in 91 Days on the part of

employees and accountability of the company as a whole.

2. Balance – Taking a proactive stand to create and maintain a healthy

work-life balance for workers.

3. Commitment – Committing to great product, service, and other initiatives

that impact lives within and outside the organisation.

4. Community –Contributing to society and demonstrating corporate social

responsibility.

5. Diversity– Respecting the diversity and giving the best of composition.

Establishing an employee equity program.

6. Empowerment – Encouraging employees to take initiative and give the

best. Adopting an error-embracing environment to empower employees to
lead and make decisions.

7. Innovation – Pursuing new creative ideas that have the potential to

change the world.

8. Integrity – Acting with honesty and honour without compromising the

truth.

9. Ownership – Taking care of the company and customers as they were

one’s own.

10. Competence – They know what they are doing.

11. Character – They do the right thing, even when it’s not convenient.

12. Compassion – They care as much about others as they do about

themselves.

164
Recognizing Safety as a Core value in the Mission and...

13. Catalyst – They remove obstacles and make things happen.

14. Courage – They speak truth to authority and take responsibility for the
performance of their team.

Why should Safety be a core value?

“Safety is our top priority” is a phrase that can be heard in almost any
organisation today. There are safety programs in place, composed of policies
and procedures, that are meant to protect workers and corporations in the
event of an incident, and management teams and health and safety
professionals are keen to remind us of this in every meeting and training
session.

But recently there has been a shift in how the corporate world is
implementing safety in the workplace, with many moving away from
traditional safety programs, which usually consist of policy binders, manuals
and forms, and opting instead to weave safety into their workplace
philosophy and culture.

A safety program is a great example of a priority because it is constantly

changing based on the needs and requirements of the organisation that
enforces them, or legislation that governs them. Unfortunately, everyone has
their own priorities, which means that a change in management can bring
along a change in priorities as well.

Cultures, on the other hand, are deeply ingrained in us.

They are a driving force in our thought process as well as in our actions.
Much like our backgrounds, heritages and other similarities, culture unites
like-minded people and allows 165

How to Set Up Safety Management System in 91 Days them to create a

community of sorts based on shared values.

It is just simply a part of who we are.

Whether or not you consider safety a value personally, safety should be part
of every company’s list of core values.

It is nearly impossible for an organisation to create a set of values that are

personal to every individual employee, nor would it make sense to do so.
Safety is the end game, the desired result that is valued not only by workers
but also by their families, friends, and communities outside of the workplace.
It sums up all the different reasons that any one worker might want to be
safe, and help others be safe, on the job. It sums up the common goal.

If your organisation already has a safety program, it already has the

foundation for a safety culture. At the end of the day, the same guiding
principles are at play, just taken to the next level. But it starts at the top. A
safety culture needs a management team who buys in completely and will set
a positive example for everyone else. It needs a Health and Safety team who
is dedicated to continuous improvement and will listen to workers’ concerns.
And it takes workers who are willing to work together to make sure everyone
is doing their part to keep each other safe.

How Does Safety Become a Core Value?

If a culture is held together by common values and beliefs, then surely safety
must be one of those values. Or is it?

Some argue that safety is not a value, but the result of values such as love,
honesty, and trust. This would imply that we act safely because we don’t
want to cause our loved one’s 166

Recognizing Safety as a Core value in the Mission and...

pain, that we are honest about our limitations out of self-preservation or

fear, and that we trust that our employers and colleagues have our best
intentions at heart.

The problem with that is that everyone has a different set of values that
drives them to want to be safe or want to keep others safe. But there is one
common denominator among people in safety culture environments:
everyone sees the value in safety.
In a safety culture, it doesn’t so much matter why workers want to be safe.
What matters is that everyone is willing to work together to make sure
everyone stays safe. If any one person is more focused on productivity and
efficiency than in working safely, the system cannot work.

The concept that safety is a value can simply be viewed as an ethic that
guides the way an individual views safety and safety-related behaviour.

In the workplace, it means that safety is not simply viewed as a top priority
on par with productivity; rather, it is an ethic that guides everything
employees do. Safety is never compromised.

Instead of telling workers why they should want to be safe, safety cultures
allow them to use their own values as their motivation, which will then
become a collective goal and value that unites employers and employees.

Implementing Safety as a Core Value: In most industries, Safety is a

constant challenge similar to other aspects of running a successful business.
However, there’s a big difference in how a company thinks and behaves 167

How to Set Up Safety Management System in 91 Days when safety is a value

as opposed to a program or a customer requirement. A company that has
safety as a core value has a safety culture. This means that safety has
become a way of life.

Developing and implementing a safety culture versus a simple safety

program includes changing the way safety is viewed within the organisation.
Check out Table 1 for some of the differences between safety as a
requirement or program, and safety as a value or culture.

A Culture with Safety as a Core value often includes: O

Top Leadership engagement (this means YOU) O

A team approach from employees and management O

Higher safety goals, such as no lost work time O

Family involvement through a focus on off-the-job safety and health

O

Ongoing safety education and training O

Careful planning, both pre-project and pre-task O

Regular evaluation of safety activities, and individual or departmental

recognition/reward

Accident/incident investigations to seek prevention solutions

A zero-tolerance program for safety violations that includes drug and

alcohol testing.
It Starts With Management
Establishing a safety culture is no easy task. Understanding what people
believe, what they assume to be true, and what 168

Recognizing Safety as a Core value in the Mission and...

they value is a part of developing a safety culture. It’s also a part of

engaging leadership at various critical levels throughout the organisation.

Senior management is engaged in safety when they include it as part of the

company’s mission statement, when it’s listed as one of the company’s core
values, and when it’s measured as one of the company’s critical success
factors.

Senior management communicates how they value safety when they list it
first on their agendas, talk about it in every chance they get, include it in
their performance incentive systems, and “walk the walk” themselves by
setting a good example. Senior management’s involvement is critical, as it
sets the expectations for how all levels of management are to behave.

The age-old saying that “safety is everyone’s responsibility”

actually becomes a reality when safety is a value of the company.

Teamwork is needed to have a safe culture. Management can demonstrate

this teamwork by working with the employees to learn how to be safe and to
constantly implement safer methods and processes.

In addition, a company that values safety doesn’t stop with the employees,
but involves all family members. Off the-job safety, health, and wellness
training can go a long way in demonstrating management’s concern for
employees, and getting employees to buy-in to the culture.

When safety is a value, education and training aren’t just for new employees.
Contractors who have a safety culture provide on-going education and
training to all employees.
While almost all contractors do “tool box training” for field 169

How to Set Up Safety Management System in 91 Days and shop employees,

companies with a safety culture include office and staff personnel on regular
safety training sessions.
Planning and Execution
Dwight D. Eisenhower once said, “A plan is nothing, but planning is
everything.” Companies with a safety culture plan for safety every day,
week, month, and year. Before any project is started, they do safety pre-
project planning. Also, pre-task planning is done religiously to ensure that
safety is part of the way we will do the work each day.

W. Edwards Deming, the noted quality leader, taught the basic steps for
continuous improvement: Plan>Do>Check>Act (PDCA). For safety to be
an integral part of a company’s culture, plans to implement safe programs
must be in place. And, of course, plans have no usefulness if not
implemented.

Beyond implementation, at a company with a safety culture, management

also evaluates (checks to see if the plan worked) and then acts, based on
what is learned from the evaluation. Management constantly reviews the
leading and lagging safety indicators to see where special emphasis may be
needed.

When a new safety program is implemented, it’s management’s responsibility

to share the results across the company, recognize safe acts, and reward
excellent safety performance. Consider team incentives: poor safety means
no bonus money. Yes, it can be that straightforward and still be very
effective.

170

Recognizing Safety as a Core value in the Mission and...

Prevention vs. Blame
Accidents/incidents happen in every company. When they do occur, most
contractors go through a serious investigation of how it happened and often
point fingers at who’s at fault.

When accidents/incidents happen in a company with safety as a value,

they’re also investigated. But blame is not the issue; the goal is to look for
root causes and take actions to prevent any future events.

One way to prevent accidents is a zero-tolerance approach for safety

violations. At one major sheet metal/

mechanical contracting firm, any employee caught working in an unsafe

manner gets a pointed discussion about what could have happened to them if
they had an accident, then is sent home for the day to think about it. He or
she isn’t eligible for any overtime the rest of that week. A second time the
same worker violates a safety policy, the result is a two-week suspension. A
third strike on the employee and he or she is “out the door.”

With a safety culture, drug and alcohol testing is done when an employee
starts working for the company, randomly throughout the year, and any time
there is an accident. Testing includes management as well as front line
employees. There’s no room for partiality.

Does having safety as a value really pay off? To companies that value safety,
this is a silly question. It pays in avoiding the cost of accidents, and the
related cost of lost productivity. It pays off in a lower EMR (experience
modification rate) from the insurance company and, therefore, lower
workers comp 171
How to Set Up Safety Management System in 91 Days costs. It pays off when
customers recognize the contractor’s safety efforts and qualify the company
for more contracts.

But it pays off most when each employee goes home safe each night.

(Reference:https://www.skybrary.aero/index.php/File:SC_Diagram_

Capture.JPG)

Five drivers of a positive safety culture 1. A genuine and visible safety

commitment — Positive safety cultures are characterised by a shared
perception that leaders at all levels are genuinely committed to health and
safety. Trust and credibility are key. Be seen to be investing in safety, make it
a priority, and step out onto the ‘shop floor.’ Spending time talking with
employees about health and safety makes your commitment visible and
encourages a positive perception of safety commitment.

172
Recognizing Safety as a Core value in the Mission and...

2. Team safety support — Group expectations are powerful predictors of

individual behaviour. In positive safety cultures, there is a shared
expectation to work safely, without exception. Team members watch each
other’s backs and pull each other up — correcting unsafe behaviour and
promoting safety within the team.

3. High-quality safety communication — Utilise opportunities (e.g., pre-

starts) to talk about safety and encourage two-way communication. In doing
so, communication opportunities become job relevant and respond to team
happenings, changing work conditions, etc.

4. Embracing safety responsibilities — Who owns safety in your

organisation? In some organisations, responsibility is deferred to the safety
team with a ‘it’s their job, not mine’ mentality. In positive safety cultures, the
safety team are subject matter experts; but ultimately, each individual takes
personal ownership over safety.

5. Providing the tools needed to do the job safely —

Ensure the necessary gear to work safety is provided, fit for purpose and
easily accessible. In positive safety cultures, employees actively participate
in procurement decisions, providing feedback as expert users to ensure gear
meets practical needs.

Five drivers of a negative safety culture 1. Poorly implemented safety

systems — Confusion around the purpose of a system, excessive complexity,
lack of job relevance, and inaccessibility are just a few of 173

How to Set Up Safety Management System in 91 Days the barriers to

successful adoption of safety systems. If you notice employees taking a ‘tick
and flick’ approach or sidestepping systems all together, these are likely
signs of a negative safety culture.

2. Procedural unfairness — In negative safety cultures, there is a

perception that some employees get away with safety transgressions, while
others are punished harshly.

Blaming and unfair discipline are rife, and frontline leaders typically lack
the soft skills required to have effective performance conversations.

3. Barriers to reporting — Employees are unlikely to see the value in

reporting incidents when there is lack of visible or timely action by
management. A lack of feedback on reported incidents and perceived
negative repercussions also hinder reporting.

4. Risk habituation and complacency — When unsafe work practices

become the norm, the workforce becomes risk ignorant. Similarly, attitudes
such as ‘risk is simply part of the job’ and ‘anything goes’ during high
demand or peak periods lead to knowingly working unsafely and taking
shortcuts.

5. Change (mis)management — Mismanaged change is usually

characterised by a top-down, non-consultative approach. Coupled with poor
communication and inconsistent implementation, trust between the
workforce and management erodes, leaving employees cynical of the
organisation’s commitment to safety and worker welfare.

174
Effective Communication to drive a Safety Culture: (7 days) Chapter 11:
Effective Communication
to drive a Safety Culture:

(7 days)

“Communication is the nervous system of the Organisation.

It has to be working at its highest efficiency, all the time for the Organisation
to perform effectively.”

Successful organizations believe in effective communication. One needs to

communicate, communicate and communicate. After setting up all processes
recommended in previous ten chapters, it is necessary to start a drive for
communicating the Safety initiatives taken, to sensitize all stakeholders and
engage them in “Safety Culture” building efforts. Current chapter is
dedicated to this important area.

The Importance of Communication:

Communication is a very critical part of Safety Culture Building. As we have

understood, a Safety Culture comprises of the following:

a. Safety as a Core value

175
How to Set Up Safety Management System in 91 Days b. Clear processes,
guidelines and charters c. A Safety implementation structure d. Clear
identified Safety behaviour e. A group interaction process to drive the Safety
culture f. Strong initiative and Visible leadership by all Managers All of the
above require strong communication to thrive and interconnect with each
other. When we talk of behaviour change of a group or organisation, every
tool has to be used.

Types of communication for building a Safety Culture:

(Reference:https://www.educationcorner.com/the-learning-pyramid.html)
The learning pyramid shows the various ways that learning can be
inculcated in an individual or group. To drive a Safety culture, ALL the
above elements are used in various ways to accelerate the learning.
Communication is at the centre of all these initiatives.

176

Effective Communication to drive a Safety Culture: (7 days) a. Lectures:

The first step is to help employees understand the basics of a Safety core
value, what is perceived as good safety, processes, guidelines and the
reward/

punishment system. This intervention does not add to more than 5% of an

individual’s learning, but is critical to form the base of the further learning
to come in the future. Also, these formal engagements (usually face to face)
create a unique psychological readiness for the employee to learn more,
similar to a ‘launch program’ of any important initiative.

b. Reading (Self learning): This is the second level of learning and is

usually a mixed bag. Self-learning is an acquired skill, and while some
people have it, others do not take it seriously. It’s not possible to train people
in Self learning, but the organisation drives this process by throwing
information at the employees. This is done using various formats like emails,
online training programs, booklets, handouts, etc. Over a period of time, the
organisation reviews and segregates those employees who have added to
their learning on their own initiative by finding the time and inclination to
read through the material. These ‘early adopters’ are identified as
champions who will lead the other learning interventions.

c. Audio/Visuals: This level is usually done by carpet bombing the

employees. There is a subconscious element of learning here. The audio or
images are seen by the employee in and around his workplace. He is not
required to spend time on it, but just allow it to enter his field of
consciousness. With repeated exposure, these 177

How to Set Up Safety Management System in 91 Days messages embed

themselves, percolating down to the subconscious, thus altering behaviour
over time. These all kinds of Safety posters put up in various locations of the
workplace are constant reminders to the employees of the importance of the
Safety core value and how to adhere to it. With technology, newer
interventions like podcasts, messages, etc. are also used to add to the inflow
of such ‘stimulants.’ People are more interested in seeing information rather
than reading about it.

Images and videos are the foundations of the internet.

Moreover, the incidents related to safety can be better understood when

shown visually either in the form of a true video or animated.

d. Adding images and visuals as part of EHS training materials can really
spice up any workplace safety data that you might want to share with your
staff. In fact, anything technical or complicated can be more effectively
explained in a training video. It’s also another way of making data easier to
understand. While animations are a brilliant way to show things you can’t
see working such as accident scenarios or closed off equipment.

e. Alerts are unbeatable for getting attention and driving action around high
priority messages, such as serious hazards or weather warnings. A Video
Alert vibrantly summarizes main learning points for staff following training
sessions.

f. Screensavers promote positive behaviour by reinforcing health and safety

messages through striking visuals and emotive language. After incidents
occur, use them as a promotional campaign to address the issue.

178

Effective Communication to drive a Safety Culture: (7 days) g.

Demonstration: From this intervention onwards, the learning engagement
becomes participative and requires a human engagement (either physical,
online, but live or recorded). Demonstrations are a great way to learn. This
is especially effective in groups. As per Bandera’s famous ‘bobbing doll
experiment’ people tend to copy each other. All behaviours are learnt and we
imbibe them from other influential people in our lives. When people are in
groups, they are happy to learn from someone who is part of the group (in
group) and identified as a champion who ‘knows the right way to do it.’ It’s
like learning from a brother who is an equal and not from a teacher, boss or
parent. This learning is easily accepted and imbibed. Such demonstrations
should be done by ‘in group’ demonstrators who are seen as ‘empathisers’

and who truly understand the challenges and issues of the group members.

h. Discussion group: The organisation now crafts group engagements,

which are perceived as ‘informal and yet flexible in a loosely structured
format.’ These engagements are allowed to move at their own pace,
encouraging brainstorming, conflicts, innovative ideas and points of view.
These group engagements truly keep the Safety culture alive. This is akin to
the culture in a family. When the family meets at dinner, there is no structure
to the format. Yet, the open and free discussion at the dinner table helps
reemphasize the family values, resolve emerging conflicts, align on issues
and decide on action going forward. In a similar fashion, peer groups are
encouraged to discuss and thrash out the challenges 179

How to Set Up Safety Management System in 91 Days facing the new Safety
behaviour. The supervisor also wears his ‘boss’s hat’ loosely, allowing the
team the breathing space to think and share openly. If done well, these
discussion groups can accelerate the Culture transformation very well.

i. Practice by doing: This is where the learning is finally translated into

practice. Employees are motivated to practice what they have learnt. The
environment has been primed to drive the desired behaviour in the form of
formal rewards, informal encouragement, and disciplinary measures for
noncompliance. Though the organisation may set up such ‘drivers’ but the
most effective catalyst for behaviour change is feedback from peers. When
employees in a group start pointing out ‘good’ and ‘bad’ behaviour to each
other, the group members embrace the desired behaviour very quickly. It
becomes a ‘in group’ vs ‘out group’ thinking where groups compete with
each other in terms of adhering to the new behaviour. An employee’s non
adherence could lead to the group’s failure and the possibility of becoming
an ‘outcast’ or being thrown out of the group. An effective communication
process facilitates such group thinking by formalizing group competitiveness
in that area.

j. Teaching others: Initially, the identified ‘champions’ in each group are

asked to train other members. This helps increase the group’s learning and
confidence. More importantly, the trainer is the best way to teach others.

How to introduce the topic, contextualize it, bring in various important

elements, give positive feedback to the learner and show sufficient empathy
so that it is 180

Effective Communication to drive a Safety Culture: (7 days) accepted by the

learner. As time progresses, other group members are also encouraged to
teach. Slowly, the ‘teaching moments’ become more informal. So instead of
training in a structured way, it is seen that group members start
teaching/training/mentoring each other where it is required. As all of them
are equals, they do not see any loss of power or influence in learning from
others.

Eventually, the group becomes a cohesive whole which is literally ‘self-

learning’ and adding to its knowledge, using every informal or formal
opportunity of interaction.

This continual process of communication magically transforms the groups in

the organisation, speeding up the Culture change process.

The leadership plays a critical role here. If there is too much control, this
organic process would get stifled, and the learning gets hampered. On the
other hand, if this process is not guided, it may go wayward, creating rifts or
insecurity in the group. The leadership has to keep influencing the group
through the right communication, especially with the hierarchical
supervisors and the Safety champions (group members who have moved
ahead on the learning curve). Most importantly, the group should get a
consistent communication from the leaders. They should be fed a continual
stream of visible leadership, stories (of how employees did a great job of
adhering to the correct behaviour) rewards/punishment, new information
and guidelines.

181
How to Set Up Safety Management System in 91 Days Chapter 12:
Conclusion
“You don’t need to take all the steps, only the next one.”

This book is meant for MSMEs and CGDs, and we hope that you found the
contents practical and usable. It is not only a recommendation but necessity
for sustainable business organization to establish a good Safety
Management System. There are multiple examples where-in organizations
had to shut down there businesses after facing an incident/

accident/ disaster. All stakeholders also wish to see and work with such
organizations only, which are safety conscious. If you are a MSME or CGD
company we would request you to follow the recommendations given in this
book and reap the benefits of higher productivity, good employee
engagement and business sustainability.

The good news is that we can manage with a simpler structure which
provides sufficient safety without burning a hole in our pocket. Safety can be
implemented in the priority of topics as given below: 182

Conclusion
# Safety as a core value in the Mission and Vision Statement

# Health and Safety Policy

# Standard Operating Procedure (SOP)

# Safety Management System (SMS)

# Safety Governance Mechanism

# Safety Leadership and Culture Building

# Digitalisation of Safety

# Capturing best practices from other organisations It is important to

include Safety in the mission and vision statement as that drives all the
communication and helps establish the critical importance of Safety in the
organisation.

Next comes the Safety operating procedures, as they drive the

implementation of the critical/important new Safety initiatives in the
organisation. The third one is the Safety Management system, which ensures
that that Managers (Supervisors) are following a structured process of
disseminating and engaging in Safety practices. The Governance
Mechanism further establishes the communication, feedback and reward/

punishment process for Safety.

Once these structures are in place, the Safety Leadership and Culture
building can be started and given impetus.

The digitalisation of Safety can be done parallelly so that managing the

Governance process and Safety procedures is easier. Also, for more effective
communication and feedback.

Finally, the continual process of learning of best practices from other

organisations and bring in improvement on a 183

How to Set Up Safety Management System in 91 Days regular basis.

The book has been written keeping in mind specific needs of crores of
MSMEs in India and upcoming large no.

of CGD companies, fighting with many ‘Safety challenges’

on a day to day basis. It is a practical guide for setting up

“Safety Management System” in the organization.

We hope it could fulfill the desired expectations of the readers. However, we

will be happy to get your feedback and valuable suggestions for
incorporating the same in subsequent editions.

184

Annexures
Annexures
TYPICAL CITY GATE STATION (CGS)

Filter

KOD

PSV

Isolation

Valve

INLET

Stand by

Stand by

Odomant

Injection

Stand by Stream

OUTLET

Meter

NRV

Slam-Shut Valve

Active/Monitor Regulation

Creep Valve
185

How to Set Up Safety Management System in 91 Days Challenges in CGD

NG Pipeline

Pipelines in Old cities: Space constraint, busy roads, Inadequate

infrastructure, numerous utilities.

Non availability of integrated clearance of pipe laying.

O

Less control on assets.

Heavy urbanisation.

Less awareness of Public.

Highly outsourced and unreliable manpower.

Third party excavation.

Delay in emergency response.

O
Immediate media coverage in case of incidents.

186

‘About the Authors’

Dr. S P GARG

Fire Protection & Safety Engineer, with Doctorate in “Safety Management

System”, having experience of more than 36 years in Oil & Gas Industry

Fellow Member, Institution of

Engineers, Kolkata

Former Corporate Head and Executive Director (HSE), GAIL(India) Ltd

Co-chairman FICCI Committee on Disaster Management

Board of Governor, National Safety Council, Mumbai O

President, Indian Society of HSE Professionals ( i-HSE) O

Recipient of President’s Fire Service Medal for Meritorious services

O

Chaired PNGRB Committee on revision of “Emergency Response and

Disaster Management Plan (ERDMP) Regulations”.

Was part of Indian delegation to United Nations Global Platform on

Disaster Risk Reduction, conference at Geneva, Switzerland from 13th –
17th May, 2019.

Participated in many National and International Conferences as

Speaker/Co-Chairman/ Chairman and Presented more than 40 Technical
Papers O

Was one of the Panelist on DD News, Television discussing Chemical

Industrial Disaster Management, on 9th Aug, 2020.

sp.garg7826@gmail.com

187
K K Gupta
Sh K K Gupta is an Electrical Engineer from DCE (1972 Batch), PGDHA ,
FIEI

and Chartered Engineer (India) IEI,

FIETE, Certified Project Manager IPMA.

He superannuated as Executive Director from IOCL a Fortune 500 company

and has rich experience of over 37 Years working in IOCL in various

capacities which include Captive Power plant O & M, Refinery O & M,
Project Management, HSE, Learning & Development, CSR, Management
Services, QA& QC etc. He had served as ED(HSE) in Corporate Office in
IOCL and also GM (QC and S&EP) in Marketing Division HO of IOCL.

After his superannuation in 2011 he associated as Advisor(HSE) Gail India

Ltd., Advisor (HSE) Indraprastha Gas Ltd, Confederation of Indian Industry
as certified assessor on HSE

and Sustainability, Oil Industry Safety Directorate, PNGRB, M/S

Deloitte, National Productivity Council, Cairn Energy Barmer, M/S Obul

Consultants for implementation of BBS in GAIL, National Safety Council,
Tata Projects, DMA, Indian Society of HSE Professionals, SESI, BESAFE
etc.

He has travelled to many countries and has presented several papers in

National/International Seminars.

kkgiocl@gmail.com

188
Rajat Tewari,

Co-Founder and CEO, TranZend LLP

O Rajat Tewari brings rich

experience of 30 years with reputed multinationals like DuPont, Bausch

& Lomb, Coats (FMCG, Lifestyle Brands, Commodities) in Learning

& Development Consulting, Shaping

Organizational Culture, Operational

Risk Management (Safety),

Leadership Talent Development,

Operational Effectiveness, Business Management, Sales/

Marketing/Branding and Corporate Strategy

Rajat’s core strengths are in Organizational Culture,

Behaviour Transformation and Leadership skil s.

His passion and focus is to ensure that the Culture Transformation delivers
tangible, positive business results for the client organization.

Rajat brings in depth experience and competency in areas of Learning and

Development, Instructor Led Training,

Instructional Design, Performance Management and

Behaviour Based Safety

As a certified Executive Coach, Rajat applies skills of listening, rapport,

questioning and challenging to help the coachee progress holistically
towards the desired goals.

As a certified NLP practitioner and Hypnotherapist, Rajat strives to bring

these powerful tools into the corporate training and development area for
better results.

189

OMBA (XLRI -93 batch)

OPCC – ICF

B.E (Mech)-MSU, Baroda

O

Diploma in Training and Development –ISTD

Diploma in Instructional Design- Symbiosis O

Certified NLP Practitioner

Certified Hypnotherapist

Organisational Culture Certification

rajattewari@hotmail.com

190
Document Outline
prelium
Chapter_1
Chapter_2
Chapter_3
Chapter_4
Chapter_5
Chapter_6
Chapter_7
Chapter_8
Chapter_9
Chapter_10
Chapter_11
Chapter_12
Table of Contents
prelium
Chapter_1
Chapter_2
Chapter_3
Chapter_4
Chapter_5
Chapter_6
Chapter_7
Chapter_8
Chapter_9
Chapter_10
Chapter_11
Chapter_12