OFFICIAL
NEBOSH
MANAGEMENT OF HEALTH AND SAFETY
UNIT NG1:
For: NEBOSH National General Certificate in Occupational Health and Safety
UNIT NGC1:
For: NEBOSH National General Certificate in Occupational Health and Safety
NEBOSH National Certificate in Construction Health and Safety
NEBOSH National Certificate in Fire Safety and Risk Management
Open Book Examination
Available for 24 hours from 28 October 2020, 09:00 GMT
Guidance to learners
This is an open book examination. It is not invigilated, and you are free to use any learning
resources to which you have access, eg your course notes, or a website, etc.
By submitting this completed assessment for marking, you are declaring it is entirely your own work.
Knowingly claiming work to be your own when it is someone else’s work is malpractice, which carries
severe penalties. This means that you must not collaborate with or copy work from others. Neither
should you ‘cut and paste’ blocks of text from the Internet or other sources.
The examination begins with a realistic scenario to set the scene. You will then need to complete a
series of tasks based on this scenario. Each task will consist of one or more questions.
Your responses to most of these tasks should wholly, or partly, draw on relevant information from the
scenario. The task will clearly state the extent to which this is required.
The marks available are shown in brackets to the right of each question, or part of each question.
This will help guide you to the amount of information required in your response. In general, one mark
is given for each correct technical point that is clearly demonstrated. Avoid writing too little as this
will make it difficult for the Examiner to award marks. Single word answers or lists are unlikely to
gain marks as this would not normally be enough to show understanding or a connection with the
scenario.
You are not expected to write more than 3 000 words in total.
Try to distribute your time and word count proportionately across all tasks.
It is recommended that you use the answer template.
Please attempt ALL tasks.
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 1 of 11
OFFICIAL
SCENARIO
You have a dual role as an experienced and respected Process Operator and a representative of
workers at a large, high hazard site, run by an international chemical manufacturing organisation.
The organisation has a reputation for having a world-class health and safety culture, with many other
industries using them as a benchmark. It is a legally compliant organisation that sets clear objectives
and checks that they are met. It employs and retains motivated workers who are aware of their
clearly defined and documented responsibilities and want to continuously improve in their roles.
Absence and sickness rates are low. The organisation listens to workers when they raise concerns
and responds professionally to external customer complaints. The organisation also takes pride in
recording low accident and incident rates and investigating any near misses to learn lessons and
prevent more serious outcomes. Across the organisation there are clear lines of internal and external
communication. This allows effective resolution of complaints. The organisation is fully insured even
though the premium is high. The organisation conducts frequent internal audits and is also externally
audited.
The process you operate is running at a reduced production rate, due to a technical problem with a
large storage tank containing a highly toxic product. You have an idea what the problem is, but
knowing the limits of your authority, you feel the issue should be escalated to someone more senior.
Local site managers, engineers, supervisors and operators meet to discuss the situation. They
conclude that the tank has an internal blockage, that would normally require a complete process
shutdown to clear. However, the planned maintenance shutdown is 12-months away. They decide
to seek advice from the corporate management team to explore whether there is a different solution
that would resolve the blockage problem, but keep production going.
The local site and corporate management teams meet by video conference. The corporate
management team includes a very experienced senior engineer with 25-years’ company service.
This engineer has overseen process plant modifications, at many international sites, with zero lost
time incidents. They all agreed that modifications could safely be made to the tank, without the need
to shut it down, and that the necessary resources would be made available for this work.
The senior engineer is sent to the site to advise on, and manage, the changes that are needed to the
tank; and on the day of arrival presents a solution to you. You are unfamiliar with the technology to
be used for the modification and your reaction is one of disbelief, and you politely ask if the engineer
is serious. The engineer invites you to a meeting to conduct a systematic and detailed risk
assessment of the tank modification task. The Health and Safety Adviser, worker representatives
and Plant Manager will also be at the meeting.
At the meeting, the engineer introduces the proposed tank modification and leads the risk
assessment exercise. The risk assessment includes consideration of the highly toxic chemical, the
release of which would be catastrophic for workers, as well as people in adjacent businesses,
residential houses and schools. The engineer confirms that this proposed modification method is a
safe and widely used solution where the safety improvements are worth the cost. The risk
assessment then continues with discussion and agreement on risk evaluation, existing control
measures and any additional control measures necessary. Some of these control measures include
safe systems of work, a permit-to-work system, supplementary emergency arrangements and
suitable induction training for all contractors. Collectively, these precautions and control measures
reduce high risk to low risk.
A summary of the risk assessment is circulated to all workers likely to be affected by the proposed
modification. The full version of the risk assessment will be made available on request.
Prior to commencing the work, a permit-to-work is issued to the contractors carrying out the tank
modification. The permit-to-work includes an explanation about the associated risk assessment and
how the plant has been safely prepared for this non-routine modification. The contract workers
accept the permit-to-work with the necessary precautions, including wearing of specified personal
protective equipment. Precautions listed on the permit-to-work are also communicated to all
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 2 of 11
OFFICIAL
contractors and other plant workers who may be affected. The permit-to-work explains that
precautions will be enforced, along with any other site rules, by active monitoring. This will be done
while you carry out routine plant checks and simultaneously check on the progress of the
modification.
To confirm safe working and clarify overall expectations, you, along with an independent site contact
have been nominated to monitor and liaise with the contractors. The independent site contact will
also actively monitor and check additional expectations, such as contractor site entry and exit control,
resolution of any queries and the supervision standard. You and the independent site contact will
check to see whether the modification work is being controlled and is progressing as planned. This is
consistent with the organisation’s safe system of work based on the findings of the risk assessment
and the method statement provided by the contractor, the aim being to complete the job safely
without incident.
Findings from inspections form part of the overall health and safety performance review. The
performance review enables an overall assessment of opportunities for continuous improvement
within the site and reveals any need for change.
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 3 of 11
OFFICIAL
Task 1: Discussing moral reasons for managing health and safety
1
Comment on the organisation’s health and safety morals.
(10)
Note: You should support your answer, where applicable, using relevant
information from the scenario.
Statistics show that people experience injuries and fatalities every year in their workplaces while
trying to earn their living1 which consequently brings pain and suffering to the workers, their families,
dependents and colleagues. It is right and ethical that the employer provides a safe and healthy
working environment for its workers. The organisation takes pride in recording low accident and
incident rates and investigates near misses to learn lessons and put arrangement in place to prevent
more serious outcomes. The organizations has shown that it cares about the welfare of its workers
by listening to its workers concerns and also responding to external customer complaints which may
include neighbours such as other businesses, residential properties and schools. There is clear line
of communication within and with external parties to allow effective resolution of complaint. Even
though the premium is high the organization has made sure there is employer liability insurance in
place to alleviate, through lump sum payment or sick pay, some of the pains and suffering in the
event of fatality or injury at workplace. The workers are motivated, absence and sickness rates are
low suggests a positive culture in the organization and that the organization provides decent work
according to ILO 1919 2. An aspect of decent work is that it is safe and healthy to do and doesn’t
cause foreseeable harm to the individual which could be physical injury or mental illness. The society
at large places some moral obligation on employers to ensure its employees do not to suffer injuries
and fatalities at work.
The employers needed to take reasonable care to provide safe and healthy plant and equipment,
systems of work, places of work and competent fellow workers3. The organization carries out
frequent internal and external audits to monitor its processes in order to provide reasonable care.
1
Accidents and fatalities from Health and safety 2019 workplace fatalities report.
International Labour Organization (ILO)
3
Wilson and Clyde Coal co. v English (1938)
2
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 4 of 11
OFFICIAL
Task 2: Roles and responsibilities
2
For a health and safety management system to work properly you need to
have clear roles and responsibilities.
Comment on the evidence from the scenario that would contribute to the
effectiveness of the roles and responsibilities.
(10)
The health and safety at work act 1974 creates duty holders and identifies who they owe a duty
towards. The employer owes a duty to its employees to ensure, as far as is reasonably practicable,
the employees health, safety and welfare at work. The organisation also owes a duty to ensure the
health and safety of non-employees like contractors, its neighbours and external parties that is
operations might affect. The employee also has a duty to themselves and must cooperate with the
employer. The organization is legally compliant and sets clear objectives that it monitors to ensure it
is followed. Being legally compliant with more than 5 employees suggest there is a health and safety
policy that outlines roles and responsibilities for the management of health and safety. This is
evidenced by being aware of the limits of authority and escalating the issue to someone more senior
even though the employee had an idea what the problem was with the storage tank. Furthermore, the
roles such as local site manager, engineers, supervisors and operators were involved to draw on
their expertise and the final decision to involved corporate management was sought because of the
scale of the issue. The views of interested parties at each functional level were considered to ensure
that the business, operational and financial requirements were reviewed.
The senior engineer in order to carry out risk assessment also sought the input from the health and
safety advisor, worker representatives, plant manager and myself - the experienced process operator
as part of the solution. The open communication as evidenced by how the reaction of unbelief to the
unfamiliar new technology for the modification and consequent systemic and detailed risk
assessment enhanced the effectiveness of the roles and responsibilities.
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 5 of 11
OFFICIAL
Task 3: Influencing health and safety culture
3
Based on the scenario only, what are the indicators of health and safety
culture in the organisation?
(20)
The health and safety culture of an organization is the shared attitude, values, beliefs and behaviours
relating to health and safety within the organization. Indicators in line with development of positive
safety culture such as control, communication, co-operation and competence were obvious within the
organization and based on the scenario some of the activities are
 The organisation has a reputation for world class health and safety culture and hence a
benchmark for the industry because its records are better than the industry average. Low records
of accident and incident rates. Near misses are investigated to prevent more serious outcomes. It
is vital that employees feel able to express safety concerns. Organization is willing to commit
resources and time to safe practices. The organization is proud of its safety culture. There is
strong policy and clear leadership from the senior management.
 Sickness rate and Absenteeism are low which suggests high morale and the workers are healthy
and carrying out their tasks in a safe environment. The employees think safety is important and
therefore work safely because they want to, not because they have to. Very low staff turnover
because organization employs and motivates workers to stay for long time.
 Organization is legally compliant as objectives are set and checks are also made to ensure
compliance with safety rules. Complaint or issues about working condition is encouraged as clear
line of communication is available. Health and safety information is available for everyone and
employees are consult on updates as the health and safety adviser, workers representative and
plant manager were invited to the risk assessment meeting.
 There was cooperation and agreement between the local site and corporate management on the
safe modification which influenced the rest of the organization. The commitment to and effort to
remedy incident and prevent reoccurrence is substantial.
 Corporate management led by example as they were interested in site management input during
the video conference which shows that everyone in the company is fully committed to employee
health and safety.
 The organization ensured the contractor had induction training for the competence and
knowledge necessary to carry out their jobs safely and effectively.
There are also indicators for negative culture where most employees feel that health and safety is not
important and see it as unnecessary or waste of time.
 The organisation with negative safety culture will prioritise revenue and profit over safety with little
interest in its safety reputation because its records will be below the industry average. There will
be high records of accident and incident rates with superficial or minimal investigation.
 Blame culture will stifle incident reporting as employees will be afraid to express safety concerns.
Management will actively discourage complaints or follow up action is not taken.
 There will be lack of clear leadership from the senior management and workers will behave in
unsafe manner.
 Sickness rate and Absenteeism will be high due to unsafe working conditions and consequent
low morale low will lead to absenteeism. Safety conscious worker will either conform or leave.
 Workers will not follow rules because either they do know the rules or compliance to safety rules
is not encouraged or supervised.
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 6 of 11
OFFICIAL
Task 4: Why lessons should be learnt from incidents
4
Other than a general improvement of health and safety, what specific reasons
are there for this organisation to learn lessons from incidents?
(10)
The prevention of incidents is an important objective and failure to learn from previous incidents often
results in larger incidents. Some of the specific reasons for this organization to learn lessons from
this incident is if the root cause to the technical problem with the large storage tank is not identified
and controlled, this situation or even a worse case is likely to occur next time with the attendant risk
and cost implication to the organization. Learning from incidents requires a process for the
organization to seek and understand any safety events that occurred in order to prevent
reoccurrence and which can lead to changes in behaviour or technical process. The implementation
of lesson learnt outcomes such as control measures to mitigate risks is also a process of continuous
improvement to make organization even more reliable.
This organization has a positive safety culture as it is obvious that management encourages
communication and employees can discuss their issues with managers openly and through multiple
channels of communication such video conferencing and meetings.
For instance, asking for structured incident investigations to identify direct and root causes of
incidents, and allocating enough resources and time for incident investigations are typical leadership
behaviours that improve both practices and processes.
Learning lessons entails acting on conclusions of accident investigations and organisational
weaknesses picked up during monitoring, audit and review processes. Factors when things go wrong
are related to leadership, attitudes and behaviours and risk management. Some reasons are for
lessons learnt
- To identify the immediate and root causes. Investigating the root cause of the tank issue will help
uncover and correct any breaches in health and safety legal compliance organization may not
have been aware of. The fact that the organization investigated and took remedial action to
prevent occurrences a positive attitude to health and safety.
- To identify corrective action to prevent a reoccurrence. Employees will need to understand how
the unsafe event that caused the incident will be controlled. An investigation can help you identify
why the existing risk control measures failed and what improvements or additional measures are
needed.
- To record the facts of the incident which can help other parts of your organisation learn
- For legal reasons or For claim management as organization can demonstrate commitment to
managing health and safety
- Management response can improve employee morale and thinking towards health and safety
 To enable risk assessments to be reviewed and updated. There is need for organisation’s risk
profile to be clear. The benefits of workers consultation and involvement in the solution.
Competent and necessary checks in place to ensure they remain so.
- For disciplinary purposes if gross negligence is identified as root cause
- For data-gathering purposes and snapshot of what really happens and how work is really done
- improve the management of risk in the future
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 7 of 11
OFFICIAL
Task 5: Risk assessment
5
The risk assessment for the proposed storage tank modification has been
completed.
Based on the scenario only, comment on whether the risk assessment is
‘suitable and sufficient’ in the following areas
(a)
who might be affected.
(4)
(b)
the precautions are reasonable, and the remaining risk is low.
(6)
Note: The HSE Document ‘Managing for Health and Safety’ (HSG65) states
that a risk assessment must be ‘suitable and sufficient’.
The aim of the risk assessment is to ensure that hazards are eliminated, or risks minimised by the
correct application of relevant standards. According to MHSWR, every employer must make a
suitable and sufficient assessment of the risk to both their employer and non-employees. Based on
the scenario, the five steps of risk assessment were followed by the organisation to make sure the
risk assessment is suitable and sufficient.
a) The release of highly toxic chemical which could be catastrophic was identified as a safety hazard
that might give rise to immediate physical injury. The people that could be harmed by the release
of the toxic chemicals included the workers ie employees and contractors, and also members of
the public were identified ie people in adjacent businesses, residential houses and school. The
engineer confirmed the modification method is safe and widely used where safety improvements
are worth the cost. A summary of the risk assessment was circulated to all workers likely to
affected by the proposed modification for their review and input. This was an opportunity to
capture any additional hazard that was missed initially. The full version of the risk assessment
was also available on request. There was no need for focus on specific individual as there was no
mention of vulnerable people in the scenario
b) Risk is the likelihood that a hazard will cause harm, in combination with the severity of injury or
damage. Risk = Likelihood x Severity.
For this site storing bulk hazardous substances, the risk assessment should be a quantified risk
assessment and COMAH should apply. The level of risk posed by the release of the toxic
chemical was not acceptable as it was considered catastrophic hence the need to introduce
control measure to mitigate the risk. The choice of control measures is affected by if it is long
term/short term, applicability, practicability, cost, proportionality, effectiveness of control, legal
requirements and associated standards, the competence of workers and training needs relevant
to preferred controls. Based on hierarchy of controls (ISO 45001), because the hazard cannot be
eliminated or substituted hence the reliance on engineering, administrative controls and PPE the
least effective due to behaviours - for example safe system of work, permit-to-work system,
supplementary emergency arrangements and suitable induction training for contractors and PPE.
All these measures and controls reduce high risk to low risk.
The permit to work was issued to contractors and explains that precautions will be enforced by
active monitoring. Furthermore, to confirm safe working and clarify expectations an independent
site contact will monitor and liaise with contractor. The site contact will also monitor and check
contractor site entry and exit control, queries and supervision standard. Further checks on
modification work to make sure it is controlled and progressing according to the organization’s
safe system of work.
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 8 of 11
OFFICIAL
Task 6: Permit-to-work system
6
The organisation has an effective permit-to-work (PTW) system.
Why should a PTW be used to help manage this storage tank modification?
(10)
Note: You should support your answer, where applicable, using relevant
information from the scenario.
Permit-To-Work (PTW) system is a formal, documented safety procedure that ensures all necessary
actions are taken before, during and after a particularly high-risk work. The organization wants the
tank modification to be carried out safely without the need to shut the factory down. The PTW is also
provides a means for the organization to coordinate different work activities for the tank modification
and avoid conflicts eg plan hot works for when operational pipelines are normally discharged for
factory operations.
The PTW will facilitate the organization’s plan by identifying the hazards and controls needed to do
the tank modification safely and then passing the responsibility for the work area from the
organization to the contractor that received the PTW. On completion, the contractor will hand back
the area to the organization to be checked before resumption of normal work.
The PTW for the tank modification included explanations about the associated risk assessment
completed at the meeting and how the plant has been safely prepared for the non-routine
modification. It helps focus attention on the high-risk nature of the work to ensure correct precaution
are in place before, during, and after the work; and also that the right people know about the job. It is
very likely the storage tank modification will entail hot work (involving naked flames or ignition
source), working at height, confined space entry and work on operational pipelines and it is vital that
these high-risk works are carried out the right way or else there might be fatalities.
The contractors doing the tank modification must sign the permit to show that they understand the
risks and precautions necessary for any of the high-risk work they are involved with. PTW as an
administrative control is very reliant on behaviour and therefore factors such as competence, training,
procedures, and communications need be considered and enforced. For the tank modification, the
precautions will be enforced by active monitoring.
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 9 of 11
OFFICIAL
Task 7: Managing contractors
7
The contractors, who specialise in the tank modification method, are ready to
start work having been issued with a permit-to-work.
Based on the scenario only, discuss how effectively the contractors are being
managed by the organisation during the modification.
(10)
The key areas of managing a contractor are Selection, the Planning and coordination of the work,
and the Monitoring and managing the work
As part of the planning and coordination, How the work will be managed and supervised was
considered by the organization before the work started. As part of monitoring and managing during
the modification work, arrangement was made to ensure that the contractor complies with safe
working practices and standards that were developed during planning stage; examples - sign in/out,
induction training for contractors and controlling high-risk activities with permit to work system. An
independent site contact (ISC)was nominated to monitor and liaise with the contractor to confirm safe
working and ensure adequate mitigation of the risks. The ISC will also actively monitor contractor site
entry and exit control, facilitate resolution of any query and supervise compliance to the standard. In
addition, myself and the ISC will check to make sure modification work is controlled and progressing
as planned which is in line with the organization’s safe system of work as identified by the risk
assessment and contractor’s method statement. The aim is to ensure work is completed safely
without incident.
The PTW is an effective means of communication between the contractors that will carry out the
modification and site management as it shows the importance of health and safety within the
organization. The permit to work explains that the precautions will be enforced, along with any other
site rules, by active monitoring. This was done by carrying out routine plant checks and
simultaneously checking on the progress of the modification.
The nominated ISC will address health and safety failings objectively by engaging directly with the
contractor or my organization without partiality. The organization has clear lines of communication to
report concerns or complaints.
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 10 of 11
OFFICIAL
Task 8: Health and safety performance (management) review
8
The organisation’s world-class reputation is partly due to carrying out an
annual health and safety performance review.
What types of information should this review consider?
(20)
Note: You should support your answer, where applicable, using relevant
information from the scenario.
The senior management of the organization should review the operation of the health and safety
management system to ensure it is being implemented and suitable. The Health and safety
performance review enables the organization assess opportunities for continuous improvement and
also confirms if the health and safety arrangements is still relevant. For example, the review will
check the validity of the policy or if health safety management system is effective. The review also
allows opportunity to promote the organizations health and safety successes. it’s important to include
top management in this annual review process because it’s top management that has the authority to
make necessary decision about actions, resources, and resource allocation. The challenge for
organisations is to communicate their performance in ways which are meaningful to their various
stakeholders.
The types of information to be reviewed are
1. Legal compliance – it is stated that the organization is legally compliant, but it is still necessary to
review if management of health and safety is still effective or getting worse. The health and safety
policy is a legal requirement as there are more than 5 employees and must be reviewed regularly
to stay compliant. It should have a general statement of intent, organization and arrangement
sections.
2. Accident and incident data – review accident/incident trends, near-miss data, investigation
reports. The records show that organization has low incident and accident rates. It is necessary to
find ways to reduce even further and continue to be used as the industry benchmark.
3. Safety tours and sampling and inspection – a review of inspection reports from checks to see
whether the tank modification of work is being controlled and progressing as planned. Any other
reports from Active monitoring ie plant checks and Reactive monitoring eg incident reports
4. Absence and sickness data – this data shows absence and sickness is low. Still important to seek
ways to improve eg is culture supportive of health and safety, in the face of competing demands
like covid19.
5. Audit reports – reports from both the internal and external audits should be reviewed
6. Achievement of objectives – the modification of the tank storage can be measured against a
target. There is need to demonstrate that management of health and safety is effective to external
stakeholders such as regulators, insurance companies, shareholders, and general public.
Corporate social responsibility is also another incentive.
7. Enforcement action – any enforcement notices or prosecution is reviewed.
8. Previous management reviews - to identify areas that need to address as part of continuous
improvement process.
9. Legal and best practice developments – there could be new technology or best practice such as
the unfamiliar technology to be used for the modification of the tank. Training record to be
reviewed as well
10. Other information types may include quality assurance, complaint or issues raised by workers or
their representatives, trends and progress toward risk reduction, input from employees and
employee representatives
End of examination
Now follow the instructions on submitting your answers.
NG1_NGC1-0002-ENG-OBE-QP-V1 Oct20 © NEBOSH 2020
page 11 of 11