MANAGEMENT SYSTEMS

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OCCUPATIONAL HEALTH & SAFETY Environmental Regulations for Managers

November 21, 2003 Presented by: Paul Amyotte, P. Eng. Prepared by: William Erving and Paul Amyotte, P.Eng.

Outline
History of Occupational Health and Safety  Vancouver Shipyards Case Study  Management Functions  Example OH&S Management System  NS OH&S Act  Management Systems - CSChE PSM - AIHA OH&SMS - BS 8800, BSI 18001, OHSAS 18001, (ISO - ISO 14001  Implementing an OH&S Program  Additional Resources  Conclusion

18001)

“It is the sum of our contributions to safety management that determines whether the people we work with live or die.”
- Piper Alpha inquiry report

This includes the organizational structure. practices. achieving. planning activities. procedures. processes and resources for developing. reviewing and maintaining the organization’s OH&S policy.What is an OH&S Management System? “Part of the overall management system that facilitates the management of the OH&S risks associated with the business of the organization.BSI/OHSAS 18001:1999 .” . responsibilities. implementing.

Hammurabi Code is established. considered by many to be first OH&S act Middle Ages.History of OH&S   1760 BC.Effects of workplace hazards begin to be identified. but because of the nature of industry at the time standards are not put in place .

publishes “Discourse on the Diseases of Workers”. The concern of industry was profit above all else. Virtually no compensation existed for the untrained workers of these facilities. workers faced new hazards. considered the father of occupational medicine.As the factory system was introduced to industry.History of OH&S  Industrial Revolution. injuries and deaths were acceptable losses when labour was plentiful and cheap. . Ramazinni.

History of OH&S   1908.” Soon after. Also postulated that accident prevention was the responsibility of management.H.W. . 1931.Theodore Roosevelt states “The number of accidents which result in the death or crippling of wage earners is appalling. Heinrich publishes “Industrial Accident Prevention” proposing the idea that actions of people cause more accidents than workplace conditions. worker’s compensation was established as well as the National Safety Council in US. This concept still influences OH&SMS today.

The Occupational Safety and Health Act passes (OSHA in US) 1978.” 1981.OSHA’s Voluntary Protection Program established .Dan Petersen publishes “Techniques of Safety Management” further building upon the concepts of Heinrich.History of OH&S    1970. an unsafe condition and an accident are all symptoms of something wrong in the management system. Theorizes “An unsafe act.

The need for comprehensive OH&S management policy in the workplace has never been greater.Present OH&S Policy In the modern workplace today’s employee faces new hazards and dangers unlike anything seen before. . Accompanying these new risks is the realization by management that OH&S policy is needed to compete in today’s marketplace.

ca) [twelve case studies] . fitters. maintenance and repair of all types of ocean-going vessels Employs 300 people represented by the Marine and Shipbuilders Local 506 40% of employees are skilled tradespersons such as welders. construction. and electricians Canadian Labour and Business Centre (www.Vancouver Shipyards Case Study    Company Background Main services include the design.clbc.

and little or no accountability” .Vancouver Shipyards Case Study      Impetus for Healthy Workplace Initiatives High levels of accidents and injuries Costs of unsafe work practices Mid 1990’s to late 1990’s: injury rates and claims higher than industry average Numerous Workers Compensation Board fines in excess of $10.000 Situation described as “poor management systems. sloppy practices. a lack of commitment to health and safety by management and employees.

Vancouver Shipyards Case Study
Impetus for Healthy Workplace Initiatives Six-month review found:  Approach to health and safety was reactive rather than proactive  Low morale and lack of trust between management and employees  Misconception among employees that WCB claims are an entitlement paid for by the WCB, rather than an insurance policy paid for by the company

Vancouver Shipyards Case Study
Impetus for Healthy Workplace Initiatives Six-month review found:  Management did not understand the complexities of safety, including the regulatory environment, safety staffing requirements and expertise, and the true costs of accidents  Decaying infrastructure, with much of the mobile and fixed equipment failing to meet safety standards

Vancouver Shipyards Case Study
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Overhaul of Health and Safety New corporate safety manager recruited Sought the assistance of the WCB of BC through its Focus Form Strategy which provides in-depth assistance Committed to written strategy to reduce workplace injuries Invested own resources in developing and maintaining an effective health & safety program Health and safety given equal consideration with operational, economic and personnel issues

responsibilities and lines of accountability among employers.Vancouver Shipyards Case Study A New Health and Safety Management System  Policy: health and safety policy and commitment statements to be produced and signed by senior management and brought to the attention of all employees  Organization: outlines roles. committees. labour/management cooperation and adequate health and safety training . and management at all levels. Also addresses the need for two-way communication.

Vancouver Shipyards Case Study    A New Health and Safety Management System Planning and Implementation: provides guidelines for proactive health and safety planning. and internal inspections and risk assessments Measuring Performance: guidelines to determine whether and to what extent health and safety plans have been implemented and stated objectives achieved Audit and Review: outlines procedures for annual assessment of the health and safety management system . setting of objectives.

Vancouver Shipyards Case Study Wellness Initiatives at Vancouver Shipyards  Employee health and lifestyle training pilot project  On-site gymnasium and steam room  Musculo-skeletal injury prevention program  North American Occupational Health and Safety Week (NAOSH) activities .

000 in 2001 Won 2001’s North American Occupational Safety and Health General Industry Award .Vancouver Shipyards Case Study    Impacts and Analysis 70% reduction in the number of disability claims from 1998 to 2001 Claims costs fell from $2.2 million in 1998 to a projected $500.

Vancouver Shipyards Case Study .

Management Functions   “The first dusty of business is to survive and the guiding principle of business economics is not the maximization of profit – it is the avoidance of loss. now part of DNV) . leading and controlling “Practical Loss Control Leadership” by Bird and Germain (ILCI.” Peter Drucker Manager: One who attains organizational objectives through others by performing the specialized functions of planning. organizing.

Management Functions     PLANNING: predetermining a course of action ORGANIZING: arranging and relating the work to be done so that it can be done most effectively LEADING: creating the climate that causes people to take effective action CONTROLLING: measuring and relating performance and results .

Management Functions  Four essential management SYSTEM functions: PLAN DO CHECK ACT Done with an ATTITUDE that reflects a positive corporate culture toward health and safety.  .

and that the vast majority of accidents have their root causes in management system deficiencies “Practical Loss Control Leadership” by Bird and Germain (ILCI. now part of DNV) .Example OH&S Management System   From the mid-1980’s (perhaps earlier) Based on the principles that accidents arise from multiple causes.

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NS OH&S Act  Is there a need for an ATTITUDE with respect to OH&S?   Internal Responsibility System (IRS)  Everyone shares responsibility for health and safety in workplace  Primary responsibility for creating and maintaining safe and healthy workplace depends on authority and ability to do so OH&S Policy  Must express employer’s commitment to OH&S www.ns.ca/enla .gov.

CHECK. DO. ACT with respect to OH&S?  Program (among other requirements)  Training  Procedures  JOSH Committee  Hazard Identification  Inspections  Monitoring/Follow-up/Control of Hazards  Incident Investigation  Maintenance of Records and Documentation  Monitoring of implementation and effectiveness of the program .NS OH&S Act  Is there a need for a SYSTEM of PLAN.

MANAGEMENT SYSTEMS

CSChE PSM

AIHA OH&SMS

Canadian Society for Chemical Engineering; Process Safety Management American Industrial Hygiene Association; Occupational Health and Safety Management System

BS 8800, BSI/OHSAS 18001 (ISO 18001)

ISO 14001

British Standard; British Standards Institute; Occupational Health and Safety Assessment Series

CSChE PSM
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Free resource available at www.chemeng.ca Provides an overview of process safety management for facilities handling hazardous materials Based on the tools developed by the Center for Chemical Process Safety (CCPS) of the American Institute of Chemical Engineers (AIChE) Presentation here courtesy of Graham Creedy of Canadian Chemical Producers’ Association (CCPA)

History of safety philosophy in the chemical industry
We can consider in four phases:  Late 19th – early 20th century  Origin of much of basic safety thinking in the explosives industry (protection of capital assets)  Second world war through 50s and 60s  Concepts of loss prevention and investment in people (often rule-based)  70s and 80s (Process Safety Management)  Recognition of seriousness of consequences and mechanisms of causation lead to focus on the process rather than the individual worker  90s and beyond  Realization of significance of sociocultural factors

use. process or store hazardous materials in a manner free from episodic or catastrophic incidents Process safety management is the application of management systems to the identification. understanding and control of process hazards to prevent process-related injuries and incidents CCPS: Guidelines for Technical Management of Chemical Process Safety  .Process safety management Definitions  Process safety is the operation of facilities that handle.

119 Process Safety Management Rule.What is meant by “Process”?  "Process" means any activity involving a highly hazardous chemical including any use. definitions . or the on-site movement of such chemicals. storage. manufacturing. handling. or combination of these activities US OSHA 1910.

Difference between PSM and traditional health & safety Traditional workplace health and safety Focuses on the individual actions while considering interaction with equipment  Occupational health exposures  Significant legal and regulatory mandate Objective: to eliminate injuries and illnesses to personnel  Process safety management Focuses on process: materials. equipment and systems  Individuals and procedures are considered part of the system Objective: to eliminate process-related incidents  .

Functions of management system Planning Organizing Direction Leadership Controlling Measurement Implementing Structure Results .

Features and characteristics of a management system for process safety Planning Explicit goals and objectives Well-defined scope Clear-cut desired outputs Consideration of alternative achievement mechanisms Well-defined inputs and resource requirements Identification of needed tools and training Organizing Strong sponsorship Clear lines of authority Explicit assignments of roles and responsibilities Formal procedures Internal coordination and communication Implementing Detailed work plans Specific milestones for accomplishments Initiating mechanisms Controlling Performance standards and measurement methods Checks and balances Performance measurement and reporting Internal reviews Variance procedures Audit mechanisms Corrective action mechanisms Procedure renewal and reauthorization .

Examples of PSM management system concerns at different organizational levels .

4.Scope (PSM elements) Accountability Process Knowledge and Documentation Capital Project Review and Design Procedures Process Risk Management Management of Change Process and Equipment Integrity Human Factors Training and Performance Incident Investigation Company Standards. 11. 12. 8. 10. . 6. 2. Codes and Regulations Audits and Corrective Actions Enhancement of Process Safety Knowledge 1. 5. 9. 7. 3.

Personnel Safety & Health Process Safety Environmental Control Overlaps among safety. health and environmental areas .

systems.1. make sure alternatives are acceptable Be accessible for guidance Communicate and lead .g. quality. organization Be ready for exceptions Where freedom is allowed. cost) Objectives must be supported by appropriate resources Plan for continuity in operations. Accountability         Management commitment at all levels Status of process safety compared to other organizational objectives (e. output.

get out of the business! .4. improve) Be ready if it happens If you can't do any of the above. better still. and meet it Control it there (or. Process Risk Management       Know what the hazards are Understand the risks Decide what is acceptable.

Hazard and risk  Process hazard  A physical situation with potential to cause harm to people. property or the environment  Risk (acute)  probability x consequences of an undesired event occurring .

Pre-screening using a list  The first screen is usually a list of materials. gasoline) or Property (flash point. Section 200)  . LC50 ) plus  Threshold quantity on site at any one time Usually specified by regulation (Canadian Environmental Protection Act. either by   Name (chlorine.

response and recovery) implement plan. including testing. must notify EC by March 2004 If largest container of a listed substance also exceeds threshold.The Canadian Environmental Protection Act and control of major accident hazards  Part 8 of the Act deals with environmental emergencies Regulation under Section 200 effective December 9. by December 2004 . 2003 If a site has any of 174 listed substances in more than threshold quantity. must:      develop emergency plan by June 2004 (plan must address prevention. preparedness.

Management of Change        Change of process technology Change of facility Organizational changes Variance procedures Permanent changes Temporary changes Note that none of the above cover latent errors .5.

Active and latent failures  Active   Immediately adverse effect Similar to “unsafe act”  Latent   Effect may not be noticeable for some time. Unforeseen trigger conditions could activate the pathogens and defences could be undermined or unexpectedly outflanked . if at all Similar to “resident pathogen”.

Case study: Flixborough (1974) (Courtesy of Jessica Shinkle/2001)   Vapor cloud explosion .fueled by release of 30 tons of cyclohexane Largest single loss by fire or explosion in the United Kingdom  killed 28 people  injured 89 others  $63 million in property damage .

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Temporary modification Bellows 1 2 3 4 5 6 .

Why did the bypass piping fail?     No safety review and inadequate supervision Job was beyond professional capabilities of the workers Only drawing was a full-size sketch in chalk on the workshop floor No one understood the forces that would be imposed on the pressurized piping .

IDENTIFY CHANGE DETERMINE SIGNIFICANCE OF CHANGE LOW SIMPLE RISK ASSESSMENT Flowchart of a Management of Change Program Question: Do you see the four essential management system functions at work? MEDIUM/ HIGH REVIEW WITH TEAM LEADER UNCERTAIN LOW RISK APPROPRIATE RISK ASSESSMENT APPROVAL TRAINING AND COMMUNICATION IMPLEMENT CHANGE FOLLOW-UP .

AIHA OH&SMS      Overall Requirements The establishment of an OH&SMS The establishment of policy. responsibility. authority reviews and resources A documented OH&SMS with procedures. planning and performance measures Determination of conformance with laws. policies and goals with continuous improvement Design control for workplace situations by qualified personnel with safety reviews .

AIHA OH&SMS      Overall Requirements Procedures for establishing and controlling OH&S documents and changes Review of OH&S aspects of purchased goods and contractors Effective and relevant OH&S communications. exposures and documents Hazard trace for feedstock used in other processes back to point of manufacture Process control to measure and monitor hazards to minimize or eliminate hazards to employees .

resulting in corrective actions Inspection. maintenance and calibration of test equipment Sampling data and reporting mechanisms explicitly documented Communicate nonconforming situations to management and employees until acceptable state can be achieved Procedures for implementing corrective and preventive OH&S actions .AIHA OH&SMS      Overall Requirements Inspection of OH&S activities and of records.

AIHA OH&SMS      Overall Requirements Procedures for handling hazardous materials Procedures for documenting. storing and disposing of OH&S records Plan and implement OH&SMS audits Identify needs and provide for relevant OH&S training Ensure outside contractors are included in OH&S activities . securing.

BS 8800     Established in 1996 this guide to OH&SMS is similar to ISO 14001 and the AIHA OH&SMS Stresses root cause analysis Guidance annexes allow the user to implement the standard requirements in a practical way Basis for BSI 18001/OHSAS 18001 (ISO 18001) .

BSI/OHSAS 18001 Overview .

BSI/OHSAS 18001      OH&S Policy Planning Implementation and Operation Checking and Corrective Action Management Review .

BSI/OHSAS 18001       OH&S POLICY Complies to at least minimum legislated regulations Appropriate policy must be created and implemented specifically for an organization’s need Available to all parties and communicated to staff Documented. implemented & maintained Periodic reviews are necessary to establish continued appropriateness and effectiveness Continual improvement .

BSI/OHSAS 18001     PLANNING Planning for hazard identification. risk assessment and risk control Legal and other requirements Objectives OH&S management programs .

Risk Assessment and Risk Control  Be proactive rather than reactive  Provide for the classification of risks  Monitor risk assessment to ensure effectiveness and timelines of required actions are met  Use the results of the assessments when setting objectives  Keep the information up-to-date .BSI/OHSAS 18001 Planning for Hazard Identification.

BSI/OHSAS 18001 Risk Matrix (eg) .

Should be verified on a continuous basis that procedures or controls are in place. VL – Very Low – No mitigation required. M . L – Low .BSI/OHSAS 18001  Risk Matrix (eg)    H – High – Should be mitigated with engineering and/or administrative controls to a a risk ranking of L or VL within a specified time frame such as 6 months.Medium – Should be mitigated with engineering and/or administrative controls to a a risk ranking of L or VL within a specified time frame such as 12 months. .

and time scales to OH&S programs .BSI/OHSAS 18001     Legal and Other Requirements Ensure all legislated regulations are met Objectives Establish OH&S objectives and be certain they are met OH&S Management Programs Periodically review and update OH&S programs Assign responsibility. authority.

awareness and competence Consultation and communication Documentation and data control Operational control Emergency preparedness and response .BSI/OHSAS 18001       IMPLEMENTATION AND OPERATION Structure and responsibility Training.

BSI/OHSAS 18001      Structure and Responsibility Define. document and communicate responsibility and authority Provide essential resources Demonstrate commitment to OH&S program Training. Awareness and Competence Ensure that education and training are in place for tasks that impact OH&S Establish and maintain training programs .

BSI/OHSAS 18001      Consultation and Communication Procedures to communicate changes in OH&S policy must be put in place Employee input to be documented Documentation and Data Control Maintain information on OH&S policies as well as providing other relevant standards Periodically revise and review OH&S policy information Ensure documents are available where needed .

BSI/OHSAS 18001      Operational Control Establish control measures where needed Stipulate and document operating procedures Emergency Preparedness and Response Establish plans and procedures to mitigate injuries and illness associated with emergency Periodically test procedures where practicable Review plans and procedures .

BSI/OHSAS 18001     CHECKING AND CORRECTIVE ACTION Performance monitoring and measurement Accidents. incidents. non-conformances and corrective and preventative action Records and records management Audit .

BSI/OHSAS 18001      Performance Monitoring and Measurement Qualitative and quantitative measure Achievement of objectives Proactive measures that monitor compliance with the OH&S programs. operational criteria and legal requirements Reactive measures to monitor accidents. ill health and other evidence of deficient performance Calibrate monitoring equipment and document it . incidents.

BSI/OHSAS 18001 Accidents. Incidents. Non-conformances and Corrective and Preventive Action Define responsibility for investigating accidents Take action to mitigate consequences Initiate and complete corrective and preventative actions Confirm effectiveness of actions taken Implement and record needed changes to documented procedures Question: Do you see the four essential management system functions at work?      .

BSI/OHSAS 18001   Records and Records Management Establish procedures for handling OH&S records Conformance dictates that records be  Legible and identifiable  Traceable to the activity  Readily retrievable  Protected from deterioration .

BSI/OHSAS 18001  Audit Maintain a program to  Determine whether OH&SMS conforms to BSI/OHSAS 18001 guidelines and other initiatives  Review the results of previous audits  Provide information to management  Audits must be conducted by an independent source .

BSI/OHSAS 18001    MANAGEMENT REVIEW Review OH&SMS to ensure suitability. adequacy and effectiveness Documentation of the review must be collected Changes to the OH&SMS are to be identified by the audit system .

ISO 14001      Policy and Planning Environmental policy Environmental aspects Legal and other requirements Objectives and targets Environmental management program .

products and services Includes a commitment to continual improvement and prevention of pollution Includes a commitment to comply with relevant environmental regulations and legislation Provides environmental objectives and targets Is documented and communicated to all employees . scale and environmental impacts of its activities.ISO 14001      Top Management Shall Define the Organization’s Environmental Policy and Ensure That It Is appropriate to the nature.

ISO 14001     Environmental Aspects Establish and maintain procedures for identifying environmental impacts which can be controlled Determine which activities have a significant impact on the environment Consider these activities in setting environmental objectives Ensure information is updated on environmental impact of company activities .

.ISO 14001  Legal and Other Requirements The organization shall establish and maintain a procedure to identify and have access to legal and other requirements to which the organization subscribes. that are applicable to the environmental aspects of its activities. products or services.

including the commitment to reduce pollution . the views of interested parties and financial. operational. and business requirements shall be taken into consideration when setting targets Objectives and targets shall be consistent with the environmental policy.ISO 14001    Objectives and Targets Establish and maintain documented environmental objectives and targets at each function and level within the organization Environmental aspects. technological options. legal.

ISO 14001    Environmental Management Program Designation of responsibility within the company substructure to achieve goals and objectives Ensure resources and a timeframe are provided to ensure completion of objectives Existing management programs shall be amended to ensure environmental management applies to all new projects .

ISO 14001        Implementation and Operation Structure and responsibility Training. awareness & competence Communication Environmental system documentation Document control Operational control Emergency preparedness & response .

documented and communicated Resources essential to the environmental management system shall be provided Management shall appoint individuals to   Ensure that environmental management system requirements are maintained according to ISO 14001 Report on performance of the environmental management system so that necessary revisions to company policy may be made .ISO 14001    Structure and Responsibility Roles. responsibility and authorities shall be defined.

Awareness and Competence All personnel whose work may create a significant impact upon the environment shall receive training Employees shall be made aware of the    Environmental impact they can have Importance of conformance with the EMS Dangers associated with departure from specified operating procedures .ISO 14001   Training.

documenting and responding to relevant communication from external parties  The organization shall consider processes for external communication on its significant environmental aspects and record its decision .ISO 14001  Communication Establish and maintain procedures for   Internal communication between the various levels and functions of the organization Receiving.

ISO 14001 Environmental Management System Documentation  Establish and maintain information to  Describe the core elements of the environmental management system and their interaction  Provide direction to related documents .

ISO 14001  Document Control Ensure that documents  Are easy to locate  Are periodically reviewed and revised  Are available at all locations necessary  Which are obsolete are promptly removed from points of issue and use  Retained for legal and or knowledge preservation are identified as such .

ISO 14001    Operational Control Establish and maintain documented procedures to cover situations where their absence could lead to deviations from environmental goals and objectives Stipulate operating criteria for procedures Establish and maintain procedures for communicating requirements to suppliers and contractors .

and for preventing and mitigating the environmental impact of accidents Review and revise emergency preparedness and response procedures Test such procedures where practicable .ISO 14001    Emergency Preparedness Establish and maintain procedures to identify potential for and respond to accidents and emergency situations.

ISO 14001      Checking and Corrective Action Monitoring and measurement Nonconformance and corrective and preventative action Records Environmental management system audit Management review .

on a regular basis. the key characteristics of operations and activities that can have a significant impact on the environment Monitoring equipment shall be calibrated and records of this process shall be kept Establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation .ISO 14001    Monitoring and Measurement Establish and maintain documented procedures to monitor and measure.

taking action to mitigate any impacts caused and for initiating and completing corrective and preventative action  Corrective and preventative action shall be appropriate to the magnitude of problems and commensurate with the environmental impact encountered  Record all changes in the documented procedures resulting from corrective and preventative action .ISO 14001 Nonconformance & Corrective & Preventative Action  Establish and maintain procedures for defining responsibility and authority for handling and investigating nonconformance.

ISO 14001     Records Establish and maintain procedures for the identification. identifiable and traceable to the activity involved Environmental records shall be stored and maintained in such a way that they are easily retrievable and protected against damage Records shall be maintained to demonstrate conformance to the requirements of ISO 14001 . maintenance and disposal of environmental records Environmental records shall be legible.

ISO 14001    Environmental Management System Audits Provide information on whether or not the environmental management system meets the Requirements of ISO 14001 Allow the company to determine if the environmental management system has been properly implemented and maintained Scheduling shall be based on the environmental importance of the activity involved and the results of previous audits .

ISO 14001    Management Review Top Management shall at intervals review the environmental management system to ensure its continuing suitability. adequacy and effectiveness All reviews shall be documented The management review will address the need for changes to the environmental management system .

Implementing an OH&S Program Four Keys to a Successful OH&S Program     Management Commitment and Employee Involvement Worksite Hazard Analysis Hazard Prevention and Control Safety and Health Training .

production and sales Incorporate safety activities into employee performance evaluations Provide training to all employees in OH&S Provide adequate resources for the OH&S program Require management audits of the OH&S program .Implementing an OH&S Program Management Commitment and Employee Involvement      Company safety policy must be a priority equal to that of development.

Implementing an OH&S Program    Worksite Hazard Analysis Identify all worksite hazards Address all worksite hazards in documented company OH&S policy Use tools such as a risk matrix to evaluate worksite hazards .

Implementing an OH&S Program      Hazard Prevention and Control Define safe work procedures for employees Control and eliminate hazards Justify purchase of employee personal protective equipment Perform employee safety and health training Conduct accident investigations .

Implementing an OH&S Program      Safety and Health Training Senior management must be taught about basic safety program activities Middle management's role in OH&S must be defined Supervisors should be trained in the same areas as their employees and have OH&S goals and objectives Employee training consists of how to avoid accidents and injuries to themselves and others Evaluate the training program .

L.ualberta. Edmonton.ca Minerva  www. Wilson and D. DiBerardinis (editor).on. AB (2003) www. Wiley.ccohs. University of Alberta Press. L.uap. NY (1999)  Industrial Safety and Risk Management.ca . McCutcheon.org Texts d  Handbook of Occupational Safety and Health.ca Canadian Centre for Occupational Health & Safety  www.J. 2n ed.Additional Resources       PowerPoint presentations  Application of a Loss Causation Model to the Westray Mine Explosion (Amyotte & Oehmen)  Risk Assessment or Hazard Management? (Dalzell) OHS Canada (magazine)  Managing Health and Safety (November 2003) Industrial Accident Prevention Association  www.iapa.minervacanada.

CHECK & ACT with a SMILE AND RESOLVE on a RISK BASIS with the aim of CONTINUAL IMPROVEMENT within EACH OH&S PROGRAM ELEMENT as well as THE ENTIRE OH&S PROGRAM .Conclusion PLAN. DO.