NEBOSH INTERNATIONAL DIPLOMA UNIT IA UNIT IA: INTERNATIONAL MANAGEMENT OF HEALTH AND SAFETY NEBOSH INTERNATIONAL DIPLOMA UNIT IA: INTERNATIONAL MANAGEMENT OF HEALTH AND SAFETY CONTRIBUTORS Dr Terry Robson, Bsc (Hons), PhD, CFIOSH, MRSC, CChem ACKNOWLEDGMENTS © RRC International All rights reserved. RRC International is the trading name of The Rapid Results College Limited, Tuition House, 27-37 St George’s Road, London, SW19 4DS, UK. These materials are provided under licence from The Rapid Results College Limited. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form, or by any means, electronic, electrostatic, mechanical, photocopied or otherwise, without the express permission in writing from RRC Publishing. For information on all RRC publications and training courses, visit: www.rrc.co.uk RRC: NIDA.1 ISBN: 978-1-909055-53-7 First edition Spring 2015 RRC International would like to thank the National Examination Board in Occupational Safety and Health (NEBOSH) for their co-operation in allowing us to reproduce extracts from their syllabus guides. This publication contains public sector information published by the Health and Safety Executive and licensed under the Open Government Licence v.2 (www.nationalarchives.gov.uk/doc/open-government-licence/version/2). Every effort has been made to trace copyright material and obtain permission to reproduce it. If there are any errors or omissions, RRC would welcome notification so that corrections may be incorporated in future reprints or editions of this material. Whilst the information in this book is believed to be true and accurate at the date of going to press, neither the author nor the publisher can accept any legal responsibility or liability for any errors or omissions that may be made. Contents UNIT IA INTRODUCTION ELEMENT IA1: PRINCIPLES OF HEALTH AND SAFETY MANAGEMENT REASONS FOR MANAGING HEALTH AND SAFETY Moral Legal Economic Revision Question 1-3 1-3 1-3 1-4 1-4 SOCIETAL FACTORS WHICH INFLUENCE HEALTH AND SAFETY STANDARDS AND PRIORITIES Significant Factors Principle of Corporate Social Responsibility Revision Question 1-5 1-5 1-6 1-6 INTRODUCTION TO MANAGEMENT SYSTEMS Definitions Key Elements of an Effective Health and Safety Management System Principles and Benefits of Risk Management on a Global Perspective Organisational Models for Health and Safety Management Benefits and Limitations of Integrated Management Systems Key Typical Components of OHS Management Systems Quality and Environmental Management Systems Arguments For and Against Integration of Management Systems Reasons for the Introduction of Formal Health and Safety Management Systems Role of the Health and Safety Policy Requirements for a Written Health and Safety Policy and for Recording Arrangements General Principles and Objectives of a Health and Safety Policy Document Common Health and Safety Management Systems in Global Organisations Influence of Corporate Responsibility and Business Ethics Role of Health and Safety in Global Corporate Social Responsibility (CSR) Guidelines and Standards Revision Questions 1-8 1-8 1-8 1-8 1-9 1-12 1-13 1-14 1-16 1-16 1-17 1-18 1-18 1-18 1-19 1-19 1-21 ROLE AND RESPONSIBILITIES OF THE HEALTH AND SAFETY PRACTITIONER Influence on Health and Safety Management Systems Health and Safety Involvement and Conduct Competence and the Requirements for Continuing Professional Development Responsibility to Evaluate and Develop Their Own Practice Ethics and the Application of Ethical Principles Dealing with Conflicts of Interest Revision Questions 1-22 1-22 1-23 1-23 1-23 1-24 1-25 1-25 SUMMARY 1-26 EXAM SKILLS 1-28 Contents ELEMENT IA2: LOSS CAUSATION AND INCIDENT INVESTIGATION THEORIES OF LOSS CAUSATION Accident/Incident Ratio Studies Domino and Multi-Causality Theories Immediate, Underlying and Root Causes Reason’s Model of Accident Causation Revision Questions 2-3 2-3 2-4 2-7 2-8 2-9 QUANTITATIVE ANALYSIS OF ACCIDENT AND ILL-HEALTH DATA Calculating Loss Rates from Raw Data Statistical and Epidemiological Analyses in the Identification of Patterns and Trends Presenting and Interpreting Loss Event Data Principles of Statistical Variability, Validity and the Use of Distributions Revision Question 2-10 2-10 2-11 2-11 2-15 2-16 REPORTING AND RECORDING OF LOSS EVENTS (INJURIES, ILL HEALTH, DANGEROUS OCCURRENCES) AND NEAR MISSES Reporting Requirements and Procedures Internal Reporting and Recording Revision Questions 2-17 2-17 2-19 2-27 LOSS AND NEAR-MISS INVESTIGATIONS Purposes of Accident Investigation Investigation Procedures and Methodologies Communications Focusing on Remedial Actions and Lessons Learnt Use of Failure Tracing Methods as Investigative Tools Revision Questions 2-28 2-28 2-30 2-34 2-34 2-34 SUMMARY 2-35 EXAM SKILLS 2-37 Contents ELEMENT IA3: MEASURING AND REVIEWING HEALTH AND SAFETY PERFORMANCE PURPOSE OF PERFORMANCE MEASUREMENT Assessment of the Health and Safety Objectives and Arrangements Review of Current Management Systems Revision Question 3-3 3-3 3-6 3-7 MONITORING SYSTEMS Need for Active and Reactive Measures Objectives of Monitoring Limitations of Accident and Ill-Health Data as a Performance Measure Distinctions Between, and Applicability of, Performance Measures Revision Questions 3-8 3-8 3-8 3-9 3-9 3-10 MONITORING AND MEASUREMENT TECHNIQUES Range of Measures Available to Evaluate an Organisation’s Performance Key Elements and Features of Measurement Techniques In-House and Proprietary Audit Systems Use of Computer Technology to Assist with Data Storage and Analysis and Production of Reports Comparisons of Performance Data Use of Benchmarking Revision Questions 3-11 3-11 3-12 3-13 3-13 3-15 3-15 3-16 REVIEWING HEALTH AND SAFETY PERFORMANCE Formal and Informal Reviews of Performance Review Process Revision Question 3-17 3-17 3-17 3-18 SUMMARY 3-19 EXAM SKILLS 3-21 Contents ELEMENT IA4: IDENTIFYING HAZARDS, ASSESSING AND EVALUATING RISKS SOURCES OF INFORMATION TO SUPPORT HAZARD IDENTIFICATION AND RISK ASSESSMENT Accident/Incident and Ill-Health Data and Rates External Information Sources Internal Information Sources Uses and Limitations of Information Sources Revision Questions 4-3 4-3 4-4 4-4 4-4 4-5 HAZARD IDENTIFICATION TECHNIQUES Hazard Detection Techniques Importance of Worker Input Revision Question 4-6 4-6 4-7 4-7 ASSESSMENT AND EVALUATION OF RISK Key Steps in a Risk Assessment Temporary Situations Types of Risk Assessment Organisational Arrangements for an Effective Risk Assessment Programme Acceptability/Tolerability of Risk Revision Questions 4-8 4-8 4-11 4-11 4-13 4-14 4-15 FAILURE TRACING METHODOLOGIES A Guide to Basic Probability Principles and Techniques of Failure Tracing Methods in the Assessment of Risk Revision Questions 4-16 4-16 4-17 4-29 SUMMARY 4-30 EXAM SKILLS 4-32 Contents ELEMENT IA5: RISK CONTROL COMMON RISK MANAGEMENT STRATEGIES Concepts Within a Health and Safety Management Programme Selection of Optimum Solution Based on Relevant Risk Data Revision Question 5-3 5-3 5-6 5-7 FACTORS TO BE TAKEN INTO ACCOUNT WHEN SELECTING RISK CONTROLS General Principles of Prevention Categories of Control Measures General Hierarchy of Control Measures Factors Affecting Choice of Control Measures Cost-Benefit Analysis Revision Questions 5-8 5-8 5-10 5-10 5-11 5-11 5-13 SAFE SYSTEMS OF WORK AND PERMIT-TO-WORK SYSTEMS Safe Systems of Work Use of Risk Assessment in Developing and Implementing a Safe System of Work Permit-to-Work Systems Revision Questions 5-14 5-14 5-16 5-17 5-22 SUMMARY 5-23 EXAM SKILLS 5-24 Contents ELEMENT IA6: ORGANISATIONAL FACTORS INTERNAL AND EXTERNAL INFLUENCES Internal Influences on Health and Safety Within an Organisation External Influences on Health and Safety Within an Organisation Revision Questions 6-3 6-3 6-5 6-6 TYPES OF ORGANISATIONS Concept of the Organisation as a System Organisational Structures and Functions Organisational Goals and Those of the Individual: Potential Conflict Revision Question 6-7 6-7 6-7 6-11 6-12 THIRD PARTY CONTROL Integration of Goals of the Organisation with the Needs of the Individual Identification of Third Parties Reasons for Ensuring Third Parties are Covered by Health and Safety Management Systems Basic Duties Owed To and By Third Parties Selection, Appointment and Control of Contractors Responsibilities for Control of Risk Associated with Contractors on Site Revision Questions 6-12 6-12 6-13 6-13 6-14 6-15 6-16 6-16 CONSULTATION WITH WORKERS Provision of Information Relating to Hazards/Risks to Third Parties Role of Consultation Within the Workplace Formal Consultation Informal Consultation Role of the Health and Safety Practitioner in the Consultative Process Behavioural Aspects Associated with Consultation Development of Positive Consultative Processes Revision Questions 6-16 6-16 6-17 6-18 6-19 6-20 6-20 6-21 6-22 HEALTH AND SAFETY MANAGEMENT INFORMATION SYSTEM Health and Safety Management Information Systems Within the Workplace Types of Data Within a Health and Safety Management Information System Requirements and Practical Arrangements for Providing Health and Safety Information Revision Questions 6-23 6-23 6-24 6-25 6-25 HEALTH AND SAFETY CULTURE AND CLIMATE Culture and Climate Impact of Organisational Cultural Factors on Individual Behaviour Indicators of Culture Correlation Between Health and Safety Culture/Climate and Health and Safety Performance Measurement of the Culture and Climate Revision Questions 6-26 6-26 6-27 6-28 6-28 6-28 6-30 FACTORS AFFECTING HEALTH AND SAFETY CULTURE AND CLIMATE Promoting a Positive Health and Safety Culture Factors that May Promote a Negative Health and Safety Culture or Climate Effecting Cultural or Climate Change Problems and Pitfalls Relating to Change Revision Questions 6-31 6-31 6-32 6-33 6-35 6-35 SUMMARY 6-36 EXAM SKILLS 6-38 Contents ELEMENT IA7: HUMAN FACTORS HUMAN PSYCHOLOGY, SOCIOLOGY AND BEHAVIOUR Meaning of Terms Influences on Human Behaviour Key Theories of Human Motivation Factors Affecting Behaviour On-Line and Off-Line Processing Knowledge-, Rule- and Skill-Based Behaviour (Rasmussen) Revision Questions 7-3 7-3 7-3 7-3 7-5 7-7 7-7 7-9 PERCEPTION OF RISK Human Sensory Receptors Process of Perception of Danger Errors in Perception Caused by Physical Stressors Perception and the Assessment of Risk Perception and Sensory Inputs Individual Behaviour in the Face of Danger Revision Questions 7-10 7-10 7-11 7-11 7-12 7-12 7-14 7-16 HUMAN FAILURE CLASSIFICATION HSG48, Classification of Human Failure Contribution of Human Error to Serious Incidents Revision Question 7-17 7-17 7-20 7-24 IMPROVING INDIVIDUAL HUMAN RELIABILITY IN THE WORKPLACE Motivation and Reinforcement Selection of Individuals Revision Question 7-25 7-25 7-26 7-27 ORGANISATIONAL FACTORS Effect of Weaknesses in the Safety Management System on the Probability of Human Failure Influence of Safety Culture on Behaviour and Effect of Peer Group Pressures and Norms Influence of Formal and Informal Groups Organisational Communication Mechanisms and their Impact on Human Failure Probability Procedures for Resolving Conflict and Introducing Change Revision Questions 7-28 7-28 7-29 7-30 7-33 7-37 7-37 JOB FACTORS Effect of Job Factors on the Probability of Human Error Application of Task Analysis Role of Ergonomics in Job Design Ergonomically-Designed Control Systems Relationship Between Physical Stressors and Human Reliability Effects of Fatigue and Stress on Human Reliability Revision Questions 7-38 7-38 7-39 7-39 7-42 7-43 7-44 7-44 BEHAVIOURAL CHANGE PROGRAMMES Principles of Behavioural Change Programmes Organisational Conditions Needed for Success in Behavioural Change Programmes Example of Typical Behavioural Change Programme Contents Revision Question 7-45 7-45 7-46 7-47 7-48 SUMMARY 7-49 EXAM SKILLS 7-52 Contents ELEMENT IA8: REGULATING HEALTH AND SAFETY COMPARATIVE GOVERNMENTAL AND SOCIO-LEGAL AND CORPORATE REGULATORY MODELS 8-3 Role, Function and Limitations of Legislation 8-3 Nature, Benefits and Limitations of ‘Goal-Setting’ and ‘Prescriptive’ Legal Models 8-4 Loss Events in Terms of Failures in the Duty of Care to Protect Individuals and Compensatory Mechanisms that May be Available 8-5 Mechanisms Used to Enforce Health and Safety Legislation 8-8 Laws of Contract 8-10 Revision Questions 8-11 ROLE AND LIMITATIONS OF THE INTERNATIONAL LABOUR ORGANISATION IN A GLOBAL HEALTH AND SAFETY SETTING 8-12 Role and Status of Ratified Conventions, Recommendations and Codes of Practice in Relation to Health and Safety 8-12 Roles and Responsibilities of ‘National Governments’, ‘Enterprises’ and ‘Workers’: R164 Occupational Safety and Health Recommendation 1981 8-14 Use of International Conventions as a Basis for Setting National Systems of Health and Safety Legislation 8-15 Revision Questions 8-15 ROLE OF NON-GOVERNMENTAL BODIES AND HEALTH AND SAFETY STANDARDS 8-16 Relevant Influential Parties 8-16 Importance of the Media in a Global Economy 8-17 Benefits of Schemes Which Promote Co-Operation on Health and Safety Between Different Companies 8-18 Effects on Business of Adverse Stakeholder Reaction to Health and Safety Concerns 8-18 Origins and Meaning of ‘Self-Regulation’ 8-19 Role and Function of Corporate Governance in a System of Self-Regulation 8-20 How Internal Rules and Procedures Regulate Health and Safety Performance 8-21 How Non-Conformity to an Accredited Health and Safety Standard can be Used as a Form of Enforcement Within a SelfRegulatory Model 8-22 Revision Questions 8-23 SUMMARY 8-24 EXAM SKILLS 8-25 REVISION AND EXAMINATION SUGGESTED ANSWERS Introduction COURSE STRUCTURE UNIT IA This textbook has been designed to provide the reader with the core knowledge needed to successfully complete the NEBOSH International Diploma in Occupational Health and Safety, as well as providing a useful overview of health and safety management. It follows the structure and content of the NEBOSH syllabus. The NEBOSH International Diploma consists of four units of study. When you successfully complete any of the units you will receive a Unit Certificate, but to achieve a complete NEBOSH Diploma qualification you need to pass the three units within a five-year period. For more detailed information about how the syllabus is structured, visit the NEBOSH website (www.nebosh.org.uk). Assessment Unit IA is assessed by a two-part, three-hour exam. Section A consists of six 10-mark compulsory questions, and Section B consists of five 20-mark questions, of which you must choose three. NEBOSH set and mark this exam paper. International Management of Health and Safety UNIT IB International Management of Hazardous Agents in the Workplace UNIT IC International Workplace and Work Equipment Safety UNIT ID Application of International Health and Safety Theory and Practice More Information As you work your way through this book, always remember to relate your own experiences in the workplace to the topics you study. An appreciation of the practical application and significance of health and safety will help you understand the topics. Keeping Yourself Up to Date The field of health and safety is constantly evolving and, as such, it will be necessary for you to keep up to date with changing legislation and best practice. RRC International publishes updates to all its course materials via a quarterly e-newsletter (issued in February, May, August and November), which alerts students to key changes in legislation, best practice and other information pertinent to current courses, Please visit www.rrc.co.uk/news/newsletters.aspx to access these updates. NEBOSH International Diploma in Occupational Health and Safety Unit IA: International Management of Health and Safety Element IA1 Principles of Health and Safety Management Element IA2 Loss Causation and Incident Investigation Element IA3 Measuring and Reviewing Health and Safety Performance Element IA4 Identifying Hazards, Assessing and Evaluating Risks Element IA5 Risk Control Element IA6 Organisational Factors Element IA7 Human Factors Element IA8 Regulating Health and Safety Revision and Examination User Guide Before you start to use this textbook, take a moment to read this User Guide. At the start of each element you will find a Contents table and a list of Learning Outcomes. These are important because they give you an idea of the different topics you will be studying and what you are aiming to achieve. KEY INFORMATION Each main section of material starts with a Key Information box. This box presents an overview of the important facts, ideas and principles dealt with under the section heading. There is no depth or detail here, just the basics. After the Key Information box comes the main content. The main content has been designed to explain and describe the topics specified in the relevant section of the syllabus to the expected level. Examples have been given to illustrate various ideas and principles in a variety of different workplaces. TOPIC FOCUS MORE… Topic Focus boxes provide depth and detail by concentrating on a very specific topic area. More... boxes contain sources of further information. (Websites are current at the time of writing.) Although this book includes everything you need, it is worth looking at these additional sources if you can. This will give you a broader and deeper understanding. GLOSSARY Glossary boxes contain descriptions or definitions of words or phrases that are included in the main content. HINTS AND TIPS Hints and Tips boxes contain simple ideas that can help you as you work through the materials and prepare for the end-of-course exam. REVISION QUESTIONS At the end of each section you will find Revision Questions. These are not past exam questions, but should be useful for self-assessment. You can mark your answers against the Suggested Answers provided. SUMMARY Each element finishes with a Summary. This presents a very concise reflection of the key ideas and principles contained in the element. When you have finished studying an element you might use the summary to test your recall of the detailed information contained within the element. When you have studied all of the elements in a unit you should move on to look at the Revision and Examination Guide. EXAM SKILLS After each element you will find a short Exam Skills section containing an exam-style question (or two) for you to practise answering. Guidance on how to answer is provided, together with a Suggested Answer for you to compare with your own. v2.1 PRINCIPLES OF HEALTH AND SAFETY MANAGEMENT ELEMENT 1 LEARNING OUTCOMES On completion of this element, you should be able to demonstrate understanding of the content through the application of knowledge to familiar and unfamiliar situations and the critical analysis and evaluation of information presented in both quantitative and qualitative forms. In particular you should be able to: Explain the moral, legal and economic reasons for a health and safety management system. the societal factors which influence health Outline and safety standards and priorities. Explain the principles and content of effective health and safety, quality, environmental, and integrated management systems with reference to recognised models and standards. the role and responsibilities of the health and Outline safety practitioner. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-1 Contents REASONS FOR MANAGING HEALTH AND SAFETY Moral Legal Economic Revision Question 1-3 1-3 1-3 1-4 1-4 SOCIETAL FACTORS WHICH INFLUENCE HEALTH AND SAFETY STANDARDS AND PRIORITIES Significant Factors Principle of Corporate Social Responsibility Revision Question 1-5 1-5 1-6 1-6 INTRODUCTION TO MANAGEMENT SYSTEMS Definitions Key Elements of an Effective Health and Safety Management System Principles and Benefits of Risk Management on a Global Perspective Organisational Models for Health and Safety Management Benefits and Limitations of Integrated Management Systems Key Typical Components of OHS Management Systems Quality and Environmental Management Systems Arguments For and Against Integration of Management Systems Reasons for the Introduction of Formal Health and Safety Management Systems Role of the Health and Safety Policy Requirements for a Written Health and Safety Policy and for Recording Arrangements General Principles and Objectives of a Health and Safety Policy Document Common Health and Safety Management Systems in Global Organisations Influence of Corporate Responsibility and Business Ethics Role of Health and Safety in Global Corporate Social Responsibility (CSR) Guidelines and Standards Revision Questions 1-8 1-8 1-8 1-8 1-9 1-12 1-13 1-14 1-16 1-16 1-17 1-18 1-18 1-18 1-19 1-19 1-21 ROLE AND RESPONSIBILITIES OF THE HEALTH AND SAFETY PRACTITIONER Influence on Health and Safety Management Systems Health and Safety Involvement and Conduct Competence and the Requirements for Continuing Professional Development Responsibility to Evaluate and Develop Their Own Practice Ethics and the Application of Ethical Principles Dealing with Conflicts of Interest Revision Questions 1-22 1-22 1-23 1-23 1-23 1-24 1-25 1-25 SUMMARY 1-26 EXAM SKILLS 1-28 1-2 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Reasons for Managing Health and Safety KEY INFORMATION • There are three fundamental reasons for organisations to manage health and safety risk: • Moral – as human beings we should feel obliged to look after each other’s safety. • Legal – there are strict legal obligations imposed on employers and employees relating to the safety of employees and others affected by the business. • Economic – businesses that address health and safety risk are invariably more successful than those that do not. Loss events such as accidents or ill health lead to significant direct and indirect costs. MORAL It is widely accepted that moral reasons should be the prime motivator for managing risk, although whether this is actually the case is open to debate in some cases. There is a need to maintain a moral code within our society. Without it, employers may be tempted to treat the health and safety of the workforce as being of less importance than financial profit. Moral reasons are based on the concept of an employer owing a duty of reasonable care to his employees. A person does not expect to risk life and limb, or physical health, as a condition of employment. Society expects every employer to demonstrate a correct attitude to health and safety to his workforce. It is unacceptable to place employees in situations where their health and safety is at risk. Statistics relating to accidents/ incidents and ill health help to reinforce the message that health and safety should be effectively managed. These statistics also demonstrate that, proportionately, those who work for small businesses are at significantly greater risk than those who work for large organisations. This is clearly morally wrong. Over the years many moral obligations have been turned into health and safety law. For example, the International Labour Organisation’s (ILO) Occupational Safety and Health Convention 1981, C155, identifies some basic general legal duties of employers towards their employees in Article 16: “1. Employers shall be required to ensure that, so far as is reasonably practicable, the workplaces, machinery, equipment and processes under their control are safe and without risk to health. 2. Employers shall be required to ensure that, so far as is reasonably practicable, the chemical, physical and biological substances and agents under their control are without risk to health when the appropriate measures of protection are taken. 3. Employers shall be required to provide, where necessary, adequate protective clothing and protective equipment to prevent, so far as is reasonably practicable, risk of accidents or of adverse effects on health.” Copyright © International Labour Organisation 1981 In addition to the obvious duties owed by an employer to his workers, he also has a moral obligation to protect other people whose health and safety may be affected by his undertaking, e.g. contractors or members of the public. There are strong legal reasons for employers to manage risk: LEGAL • Punitive - where the criminal courts impose fines and imprisonment for breaches of legal duties. These punishments can be given to the company, or to individuals within the company. In an ideal world organisations would all “self regulate” or “self police”, so that organisations identified and enforced the most appropriate health and safety standards for their activities. This has several advantages, two of which are that each business is in the best position to regulate its own activities and it would also avoid the need to have a separate (and costly) regulator. Unfortunately not all organisations are sufficiently motivated or enlightened. © RRC International • Preventive - enforcement notices (improvement or prohibition) can be issued by enforcement inspectors. • Compensatory - where employees are able to sue in the civil courts for compensation. Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-3 Reasons for Managing Health and Safety ECONOMIC Accidents and ill health are costly. These costs may be calculable, arising directly from the accident, such as sick pay, repairs to damaged equipment, fines and legal fees, or more difficult to assign a monetary value to, such as lost orders and business interruption. In practice, the costs that are more difficult to calculate are often substantially more than those that are easier to assess. All employers are required to have certain types of insurance against accidents, ill health, or other problems, such as: • Employers’ liability insurance. • Public liability insurance. • Motor vehicle insurance. These insurances will cover some of the costs of accidents and ill health, e.g. compensation claims from employees and damage to motor vehicles. However, many of the costs cannot be insured against, such as: • Product and material damage. Some of these costs are of indeterminate value. This underlines the difficulty an organisation may have in attempting to find out the true cost of accidents to the business. The company may not have enough people with the correct level of expertise and time to perform the analysis. They may not even appreciate that some costs exist and so miss them entirely. The culture of the organisation might mean that many incidents are never reported and so never find their way into statistics used as a basis for costing. Some costs may not be known accurately for a long time, e.g. where a civil case is ongoing and there may be a substantial compensation award. Obtaining realistic cost estimates of the impact of more subtle items, such as loss of morale (leading to lower productivity) and loss of goodwill/public image (resulting in lower sales), may be next to impossible. There are clearly financial benefits to be gained from positive health and safety management. Employers with good health and safety management systems in place are likely to save substantial sums on the costs of accidents that would otherwise have happened. • Lost production time. • Legal costs in defending civil claims, prosecutions or enforcement action. • Overtime and other temporary labour costs to replace the injured worker. • Time spent investigating the accident and other administration costs (including supervisor’s time). • Fines from criminal prosecutions. • Loss of highly trained and/or experienced staff. • Effects on employee morale and the resulting reduction in productivity. • Bad publicity leading to loss of contracts and/or orders. In a study by the UK’s Health and Safety Executive it was shown that uninsured (hidden) costs can be 8 to 36 times the known insured costs. This was illustrated as an “iceberg” model – where much of the costs (the uninsured ones) lay hidden beneath the water. REVISION QUESTION 1. Identify five costs of accidents that insurance will not cover. (Suggested Answer is at the end.) 1-4 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Societal Factors Which Influence Health and Safety Standards and Priorities KEY INFORMATION • Economic climate - wealthy countries can afford to give occupational health and safety a higher priority than the developing nations. • Government policy - those who work tend to be healthier than those who are unemployed; improving workers’ health will help keep people at work, and they can then contribute financially to society. • Risk profile - higher risk activities demand greater standards than those for lower risk activities. • Globalisation - businesses that operate across the world may adopt different standards depending on the requirements of the host countries. • Migrant workers - in recent years immigration policies have increased the proportion of migrant workers. • Societal expectations of equality - health and safety standards and priorities may include the requirement to make adjustments to the workplace to accommodate workers with disabilities. • Corporate social responsibility - the voluntary actions that businesses undertake to address not only their own needs but also those of the wider society. Level of Sickness Absence SIGNIFICANT FACTORS Economic Climate The wealthiest countries of the world, where individuals have access to the basic necessities for life such as food, clean water and shelter, have the funding to create and enforce good Occupational Health and Safety (OHS) standards. In countries where individuals do not have these resources, it is inevitable that OHS is given a relatively lower priority. Government Policy and Initiatives The government has a major influence on OHS policy through its ability to create legislation. In 2008 the UK government published a document entitled Working for a Healthier Tomorrow which made the following points: • Life expectancy in the UK is higher than ever, yet millions of working days are lost to work-related illness. • Evidence suggests that the working population is healthier than those who do not work. Families without a working member are likely to suffer persistent low income and poverty. • Improving the health of the working age population is critically important for everyone to secure higher economic growth and its associated benefits. © RRC International In the UK, sickness absence has gradually reduced, but is still substantial, with around 150 million days lost to sickness absence each year. Incapacity benefits (being replaced by Employment and Support Allowance) are paid to those who are unable to work because of ill health or disability. Societal Expectations of Equality Health and safety standards and priorities can be determined by changes in societies’ expectations of equality. In the UK the Equality Act 2010 aims to protect disabled people and prevent disability discrimination. The Equality Act provides legal rights for disabled people in the area of employment, requiring employers to make reasonable adjustments to the workplace to accommodate workers with disabilities. Consequently, acceptable access and egress to a workplace may need to include provision of ramps and lifts in order to comply with these expectations of equality and the legal obligations associated with them. Industry/Business Risk Profile Not surprisingly, higher risk work activities require higher standards of control than those that create lower risks. For example, nuclear power stations each operate under a site licence and demand very rigorous OHS standards. Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-5 Societal Factors Which Influence Health and Safety Standards and Priorities Globalisation of Business Many businesses of all sizes operate both nationally and internationally, and so resolving differences in culture and communication may create different expectations and standards. Migrant Workers As a result of more flexible immigration policies, the proportion of migrant workers in workforces is generally increasing and cultural and communication issues may influence OHS standards. PRINCIPLE OF CORPORATE SOCIAL RESPONSIBILITY Corporate social responsibility is the term used to describe the voluntary actions that a business can take, over and above compliance with minimum legal requirements, to address both its own competitive interests and the interests of the wider society. Businesses should take account of their economic, social and environmental impacts, and act to address the key sustainable development challenges based on their core competencies wherever they operate – locally, regionally and internationally. REVISION QUESTION 2. Explain what is meant by the term ‘corporate social responsibility’. (Suggested Answer is at the end.) 1-6 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Introduction to Management Systems KEY INFORMATION • Risk management is useful to organisations and enables them to consider potential business impacts of foreseeable events, formulate and carry out risk elimination/control, improve corporate governance, achieve business objectives in a more targeted/efficient way, and retain/improve shareholder confidence. • Most organisations have management systems for one or more aspects of management and two important models are: –– ILO-OSH-2001 Guidelines on Occupational Health and Safety Management Systems (ILO, 2001). –– OHSAS 18001 Occupational Health and Management Systems: Specification (British Standards Institution, 2007). • The key components in an effective health and safety management system are: –– Management commitment. –– Policy. –– Organising. –– Planning and implementing. –– Performance review. –– Audit. –– Continual improvement. • Total quality management and environmental management systems are detailed in: –– ISO 9000 series. –– ISO 14000 series. • For organisations wishing to have control over safety, environment and quality, it may be possible to implement an integrated management system (IMS) rather than individual systems, but there are arguments for and against integration. • The management system models offer a framework against which to allocate resources and responsibilities, set and monitor performance standards and establish systems for feedback and implementation of corrective action in order to minimise loss. • The health and safety policy sets the whole framework of the safety management system and is an important vehicle for the communication of health and safety information. • A health and safety policy may be a requirement of national legislation in some regions. • The health and safety policy usually comprises a statement of intent, an organisational structure and the systems and procedures in place to manage risks and should include objectives that will contribute to business performance. • The introduction of common health and safety management principles, standards and systems in organisations operating on a worldwide basis has both benefits and limitations. • Corporate responsibility, where businesses take account of their social, economic and environmental impacts, and business ethics should have a positive effect on health and safety management. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-7 Introduction to Management Systems DEFINITIONS Hazard KEY ELEMENTS OF AN EFFECTIVE HEALTH AND SAFETY MANAGEMENT SYSTEM A hazard is something (an object or situation) with the potential to cause harm. TOPIC FOCUS It can sometimes be helpful to categorise hazards into types such as: All management systems, whether they are designed to manage health and safety or any other function, have the same common elements: • Physical, e.g. rotating blade of a circular saw. • Chemical, e.g. strong acids and alkalis. • Biological, e.g. contagious disease. • Psychosocial, e.g. excessive workload. • Plan - implies having a considered policy. • Do - concerns the arrangements for putting the plan into practice. • Check - means it is necessary to assess or monitor performance. • Act - means performance should be reviewed leading to continuous improvement in the management system. Notice how each of these elements is described in the models we now look at. PRINCIPLES AND BENEFITS OF RISK MANAGEMENT ON A GLOBAL PERSPECTIVE Risk Risk is the likelihood that a specified harm from a particular hazard is realised. Risk is a computation of the likelihood of harm being done and the severity of that harm. The term ‘risk’ carries the idea of ‘chance taking’. Risk may be taken after careful consideration of the consequences or just out of ignorance. The result of risk-taking can be fortunate or disastrous, or anything in between. “Risk management” has been defined as: “the culture, processes and structures that are directed towards realising potential opportunities whilst managing adverse effects” (from the AS/NZ 4360 Risk Management Standard). Everything we do in life involves some element of risk. Good businesses take calculated risks all the time. They seek to maximise their opportunities and minimise the adverse effects. The following figure shows the place of health and safety risks in business (based on an IOSH publication on Business Risk Management). Danger Danger is a liability or exposure to harm; a thing that causes peril. The term ‘danger’ is a general word, but carries the idea of harm to a person. Health and Safety Risks in Business 1-8 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Introduction to Management Systems Health and safety management should not be seen as something separate from business. For example, poor health and safety management can have a severe impact on brand/image/reputation, insurance premiums, etc. Health and safety is largely concerned with pure risks (i.e. where there is only loss – such as disease, damage, injury). Loss control is also concerned with pure risks, but is wider in scope, additionally encompassing fire, security, environment and business recovery considerations. Risk management is wider still and is concerned with speculative risks (i.e. where there could be loss or gain). It involves additional consideration of finance, insurance, brand/reputation, business continuity, etc. Corporate governance is even wider and is concerned with holistic risk (i.e. looking at risks as a whole, taking account of the interaction/impact of different risks on the business). It adds to risk management by using management systems, and incorporates such things as Corporate Social Responsibility (CSR) and Socially Responsible Investing (SRI). ORGANISATIONAL MODELS FOR HEALTH AND SAFETY MANAGEMENT Most organisations have management systems for one or more aspects of management. Two models are outlined below. OHSAS 18001 Occupational Health and Safety Management Systems: Requirements. British Standards Institution, 2007 OHSAS 18001 is a certifiable health and safety management system standard that was introduced in 1999 and revised in 2007. Its purpose is to help organisations create management systems that their stakeholders can see have required characteristics. Although published in the UK by BSI, OHSAS 18001 was also subject to separate international negotiation and agreement. Compliance with certifiable standards is demonstrated through audit by a certifying body, which itself should be accredited by the UK Accreditation Service (UKAS). Risk management involves the following distinct activities: • Risk identification: by using inspections/checklists, task analysis, SWOT (strengths, weaknesses, opportunities, threats), etc. • Risk evaluation: based on economic, social, legal considerations with data on frequency of occurrence, severity of business consequences, etc. • Risk elimination and control: avoidance, transfer, retention, reduction. GLOSSARY CERTIFICATION The process by which a company wishing to move to, say, a safety management system based on OHSAS 18001 gets certified, registered or approved to that standard. CERTIFICATION BODY An organisation such as BSI or LRQA (Lloyd’s Register Quality Assurance) which carries out the certification process. • Monitoring. • Audit. • Review. ACCREDITATION Monitoring/audit and review are common to many management models. Risk management is useful to organisations. Amongst other things, it enables them to: • Look at potential business impacts of foreseeable events. • Respond to changes in risk perception. • Formulate and carry out risk elimination/control. The process by which certification bodies have their processes assessed to see if they meet the Regulatory Authority’s (or Accreditation Body’s) standards (in the UK, this is the United Kingdom Accreditation Service (UKAS)). So, an individual organisation gets certification to a standard like OHSAS 18001; the certifying body that awards that standard (e.g. LRQA) can do so because it has accreditation from UKAS. • Improve corporate governance (by incorporating risk elimination/control strategies into the organisation’s general processes). • Achieve business objectives in a more targeted/ efficient way, e.g. working towards regulatory compliance. • Retain/improve shareholder confidence. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-9 Introduction to Management Systems The following figure is based on that included in the OHSAS 18001 standard. Planning This is needed for the effective identification of hazards and assessment and control of risks. This means that the organisation needs procedures to cover risks in all activities, and for identifying any applicable law. The organisation should establish health and safety objectives consistent with the health and safety policy and establish a management programme to achieve those objectives. The management programme will include designation of roles/ responsibilities, timescales, etc. Implementation and Operation Occupational Health and Safety Assessment Series 18001 (OHSAS 18001): health and safety management model The necessary organisational structure and resources need to be put in place to implement the plans, though top management retain ultimate responsibility. People should be competent to perform their designated roles, and this may involve training and maintaining awareness. The organisation requires systems in place to make sure that health and safety information is communicated to/from employees. Employees should also be consulted on health and safety matters and be involved in the development and review of policies and procedures. This model is based on ISO 14001 and HSG65 (a health and safety management system favoured by the UK HSE) and requires an organisation to determine its existing health and safety activities, and to develop programmes and systems that focus on the elimination of risk to staff and other parties. These processes are then developed into a management system that aims to ensure that health and safety performance is continuously monitored and improved. It is important to document the systems and exercise control over those documents (so that they are accessible, periodically reviewed, kept up to date (version control), retained (e.g. legal requirements for document retention)). There should be documented procedures where necessary to control risks arising from the range of operations within the organisation. In particular, there should be plans and procedures (which should be regularly tested) to cover potential emergencies. Companies cannot simply claim that they have a standard that meets the requirements of OHSAS 18001 – they have to go through a certification process, overseen by an independent external certification body such as BSI or LRQA, which sends an auditor to verify that the company’s system meets the OHSAS 18001 standard. This is a major difference when compared with ILO-OSH-2001 (see below), which does not require such external certification. OH and S Policy This should state the overall health and safety objectives of the organisation and express commitment to improving health and safety performance. To demonstrate that commitment, the policy should be authorised by top management. The policy should commit the organisation to continual improvement and compliance with legislation. It should be communicated to all employees and other interested parties and kept up to date by periodic review. It should also be documented. 1-10 Checking and Corrective Action The organisation needs procedures to ensure that it regularly measures and monitors health and safety performance (proactive, reactive, qualitative, quantitative). Procedures should also be in place to record and investigate accidents/non-conformances and to make sure that remedial actions are implemented and that such actions have been effective. Occupational health and safety data (including audit and review results) should be recorded. There should be an audit programme to identify whether the occupational health and safety management system is operating as planned and is effective. Company employees can conduct audits. These are known as internal audits and are a method of self-regulation, which enable the company to assess its own performance against the standard. External audits are conducted by people from outside the company and give a valuable third-party viewpoint, which many people see as being more impartial. The certification body will be one such external organisation and will conduct audits when certification to a particular standard is about to expire. | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Introduction to Management Systems Management Review Organising This is the job of top management. The whole system should be periodically reviewed to make sure it continues to be effective. This relies on results gathered during the “checking and corrective action” stage. The review may, in turn, lead to changes in the policy, objectives and other elements of the management system. It should, like everything else, be documented. Whilst the employer retains overall responsibility for health and safety, specific roles should be delegated/allocated throughout the organisation, including delegation of responsibility, accountability and authority. The structure and processes need to be in place to, amongst other things: ILO-OSH-2001 Guidelines on Occupational Health and Safety Management Systems. ILO, 2001 • Actively promote co-operation and effective two-way communication in order to implement the safety management system. • Establish arrangements to identify and control workplace risks. The figure below illustrates the elements of this system and is reproduced by kind permission of the International Labour Organisation (ILO). Note that the basic elements are very similar to OHSAS 18001 in concept. It is intended that the safety management system should be compatible with, or integrated into, other management systems within the organisation. • Provide supervision. • Provide adequate resources, etc. Particularly recommended is the appointment of a senior individual to oversee the development and maintenance of the occupational health and safety management system elements as a whole, promoting participation and periodic performance reporting. Competence and training are stressed as key elements needed to implement such a programme. Occupational health and safety management system documentation (policy, objectives, key roles/responsibilities, significant hazards and methods of prevention/control, procedures, etc.) should be created and maintained. Additionally, records should be kept, e.g. accident data, health surveillance and other monitoring data. Planning and Implementation This should start with an initial review to understand the organisation’s current position. It should: identify applicable laws, standards, guidelines; assess health and safety risks to the organisation; determine if existing (or planned) controls are adequate; analyse health surveillance data, etc. This initial review provides the baseline for future continuous improvement. Model Health and Safety Management System (ILO-OSH-2001) Copyright © International Labour Organisation 2001 Policy Developed in consultation with workers, this should be signed by a senior member of the organisation. It should commit the organisation to protecting the health and safety of employees, compliance with applicable laws and guidance, consultation with employees and their participation, and continuous improvement. The guidance stresses forcefully the importance of employee consultation and participation in all elements of the safety management system for it to be effective. As such the ILOOSH guidelines strongly recommend the establishment of a health and safety committee and the recognition of safety representatives. © RRC International The next stage is the planning, development and implementation of the safety management system (based on the results of initial or subsequent reviews). This should involve the setting of realistic, achievable objectives and the creation of a plan to meet those objectives, as well as selecting appropriate measurement criteria which will later be used to see if the objectives have been met and for the allocation of resources. Preventive and protective measures should be planned and implemented to eliminate and/or control risks to health and safety. These should follow the general hierarchy of control: eliminate; control at source (using engineering and organisational measures); minimise (safe systems of work, including administrative controls); and PPE if risks cannot be adequately controlled by collective measures. Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-11 Introduction to Management Systems Management of change is also important. Changes may occur internally (new processes, staff, etc.), as well as externally (legal changes, mergers, etc.), and it is important to manage those changes in a systematic way. Risk assessment is a key part of that, as well as ensuring that people are consulted and that any proposed changes are properly communicated to those likely to be affected. Plans should also cover foreseeable emergencies (prevention, preparedness and response aspects), such as fire and first aid. Procurement procedures should make sure that health and safety requirements (national and organisational) are an integral part of purchasing and leasing specifications. You should also ensure that the organisation’s health and safety requirements are applied to contractors (including contractor selection and their work on site (hazard awareness, training, co-ordination and communication, accident reporting, site rules, compliance monitoring, etc.)). Evaluation Procedures need to be in place to monitor, measure and record the performance of the health and safety system. You should use a mixture of qualitative and quantitative and active and reactive performance measures, and not just rely on accident rate data! Active monitoring includes things such as inspections, surveillance, compliance with laws, achievement of plans, etc. Reactive monitoring includes reporting and investigation of accidents/ ill-health and occupational health and safety system failures. Accidents, etc. should be properly investigated to determine the root cause failures in the system. Investigations should be properly documented and remedial action implemented to prevent recurrence. The organisation should have an audit policy (scope, competency, frequency, methodology, etc.). Audits seek to evaluate the performance of the occupational health and safety management system elements (or a sub-set) and should at least cover: policy; worker participation; responsibility/accountability; competence and training; documentation; communication; planning, development, implementation; preventive and control measures; management of change; emergency preparedness; procurement; contracting; performance monitoring/ measurement; accident investigations; audits; management review; preventive and corrective action; and continuous improvement. 1-12 Like audits conducted under OHSAS 18001, audits under ILO-OSH-2001 can be internal or external although, unlike OHSAS 18001, external audits are not mandatory. In the case of ILO-OSH-2001, external audits are not conducted by a certification body, since there is no certification requirement. Instead, if the company wants one, independent auditors who are specifically commissioned for the task can carry them out. The audit should ultimately make conclusions about the effectiveness of the occupational health and safety management system. A management review should evaluate the overall occupational health and safety management system and progress towards the organisation’s goals. It will use data from monitoring, measuring and auditing of the system as well as take account of other factors (including organisational changes) that may influence the system in the future. It will establish if changes are needed to the system (or components of it). The results need to be recorded and communicated. Action for Improvement Occupational health and safety management system performance monitoring, audits and management reviews will necessarily create a list of corrective actions. You must ensure that, firstly you establish the root causes of the problems requiring correction, and secondly, there is a system in place for making sure that actions are carried out (and checks made on their effectiveness). Continual Improvement The organisation should strive to continually improve. It should compare itself with other similar organisations. BENEFITS AND LIMITATIONS OF INTEGRATED MANAGEMENT SYSTEMS For organisations wishing to have control over more than one aspect of risk management, e.g. safety, environment and quality, it may be possible to implement an Integrated Management System (IMS) rather than individual systems. Though it may make sense in theory, implementing an IMS is not an easy task, and there are a variety of factors to be taken into account. | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Introduction to Management Systems TOPIC FOCUS Arguments for integration: • A well-planned IMS is likely to operate more cost-effectively than separate systems, and facilitate decision-making that best reflects the overall needs of the organisation. • An IMS offers the prospect of more rewarding career opportunities for specialists in each discipline. • The objectives and processes of management systems are essentially the same. • Integration should lead to the avoidance of duplication, e.g. in personnel, meetings, electronic record-keeping, software, audits and paperwork. • Integration should reduce the possibility of resolving problems in one area at the expense of creating new difficulties in other disciplines. • An IMS should involve timely overall system reviews where momentum in one element of an IMS may drive forward other elements that might otherwise stagnate. In contrast, independent systems could develop without regard to other management system elements, leading to increased incompatibility. • A positive culture in one discipline may be carried over to others. Arguments against integration: • Existing systems may work well already. Integration may threaten the coherence and consistency of current arrangements that have the support of everyone involved. • Relevant specialists may continue to concentrate on the area of their core expertise and further specialist training may not be needed. • Uncertainties regarding key terms – already a problem in health and safety – would be exacerbated in an IMS. • System requirements may vary across topics covered, e.g. an organisation may require a simple quality system, but a more complex health and safety or environmental performance system. An IMS could introduce unreasonable bureaucracy into, in this case, quality management. • Health, safety and environmental performance are underpinned by legislation and standards, but quality management system requirements are largely determined by customer specification. • Regulators and single-topic auditors may have difficulty evaluating their part of the IMS when it is interwoven with other parts of no concern to the evaluator. • A powerful, integrated team may reduce the ownership of the topics by line management. • A negative culture in one topic may unwittingly be carried over to others. Planning and Implementing KEY TYPICAL COMPONENTS OF OHS MANAGEMENT SYSTEMS For OHSAS, “Planning” is broken out as a separate step, but “Implementing” is covered under “Implementation and Operation”. Management Commitment Without commitment from the top, the management system will not be effective. This is usually described in sections on “Policy” and “Organising” in management system models. Policy Performance Review ILO-OSH covers this under “Evaluation”. OHSAS covers this under “Checking and Corrective Action” and “Management Review”. This is the same for OHSAS 18001 and ILO-OSH. Audit Organising This is part of ILO-OSH and OHSAS and is usually discussed in the section on reviewing/evaluating performance of the system as a whole. For OHSAS this is part of the “Implementation and Operation” step. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-13 Introduction to Management Systems Continual Improvement The processes involved in effective health and safety management systems should lead to the continuous monitoring and improvement of health and safety performance. QUALITY AND ENVIRONMENTAL MANAGEMENT SYSTEMS BS EN ISO 9001:2008 - Quality Management Systems ISO 9001 specifies requirements for a quality management system where an organisation has to demonstrate its ability to consistently provide a product or service that meets customer and applicable regulatory requirements. Just like OHSAS 18001, organisations can be audited against this standard and their compliance certified accordingly. ISO 9001 is part of a family of standards in the same series. In particular it is based upon, and needs to be understood in the context of, the eight quality principles outlined in ISO 9000 and ISO 9004: 1. Customer Focus – understand customer needs (current and future), meet customer requirements, exceed customer expectations (customer satisfaction). 2. Leadership – create and maintain internal environment which encourages involvement. 3. Involvement of people – full involvement/ contributions by everyone. 4. Process approach – it is more efficient to manage activities and resources as a process (inputs-processoutputs). Processes should at least cover the following areas: management responsibility, resource management, product realisation, measurement, analysis and improvement. 5. Systems approach to management – it is more effective and efficient to manage interrelated processes as a system. 6. Continual Improvement – of the overall performance should be a permanent objective. 7. Factual approach to decision-making – decisions are more effective if based on analysis of data/information. 8. Mutually beneficial supplier relationships – the interdependency of client and supplier. 1-14 The standard consists of five main clauses which are interrelated: • Quality Management System (QMS) Establish, document, implement, maintain and continually improve a QMS. Have in place the relevant documentation (quality policy, objectives, manual, procedures, records) and processes to control those documents and records (i.e. version control). • Management Responsibility This covers: commitment, customer focus, quality policy, planning, responsibility, authority, communication, and management Review. • Resource Management Provision of: resources, competence/training/ awareness, infrastructure, work environment. • Product Realisation This is everything from inception to delivery of the product, so covers: planning of processes, customer/ product requirements, customer communication, design/development, purchasing, production/service provision, monitoring/measuring equipment. • Measurement, Analysis and Improvement Customer satisfaction, internal auditing, monitoring and measurement of processes and product, control of non-conforming product, analysis of data, improvement (continual improvement, corrective actions, preventive action). ISO 9001 promotes the adoption of a process approach that may be used to identify and manage numerous linked activities. GLOSSARY PROCESS APPROACH This is where individual activities and their related resources are identified and managed as a process (each with their inputs and outputs). An organisation can be viewed as a system comprising a network of these interrelated processes (where outputs of one process can be the inputs for others). An advantage of the process approach is the on-going control it provides over the linkage between the individual processes, as well as over their combination and interaction. You can see the process approach outlined in the following: | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Introduction to Management Systems Model of a process-based quality management system This model shows that customers play a major role in defining requirements as inputs and the monitoring of customers’ satisfaction requires the evaluation of information relating to customer perception. One major insurance company has made the point that ISO 9001 is a good way of involving top management in safety matters. Senior management usually complain that safety is beyond their sphere of experience, yet they are familiar with the approach of ISO 9001 from a quality control viewpoint. Therefore, if the provision of a “safe system of work” is discussed from the ISO 9001 stance, senior managers are already familiar with the terminology adopted and are more likely to become involved. In this way, safety is integrated into the total performance of the company and not treated as a separate issue. BS EN ISO 14001: 2004 – Environmental Management Systems – Requirements with Guidance for Use BS EN ISO 14001 is a stand-alone, auditable environmental management system standard for certification. Study the next figure carefully. The steps represent the stages in the process. Once again, a general management framework approach is applied, and there are clear similarities with ISO 9001 and OHSAS 18001 (the latter in part being based on ISO 14001 in any case). The similarity and compatibility of the safety management systems and the quality management systems mean that management committed to quality systems have few problems in widening the scope to include safety and health. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-15 Introduction to Management Systems ARGUMENTS FOR AND AGAINST INTEGRATION OF MANAGEMENT SYSTEMS We discussed these earlier when we considered the benefits and limitations of integrated quality, environmental, and health and safety management systems. REASONS FOR THE INTRODUCTION OF FORMAL HEALTH AND SAFETY MANAGEMENT SYSTEMS The management system models we have discussed offer a framework for management to focus on in order to manage health and safety – policy, organising, planning and implementing, measuring performance, reviewing performance, auditing the system. Management involves: The ISO 14001 model 1. Environmental Policy This obviously needs very careful consideration. Set the policy and have effective means of measuring the performance. 2. Planning Detailed consideration of how the policy is to be carried out. The planning must include forward planning, and plans for continual improvement. 3. Implementation and Operation A vital point in implementation is the total commitment of all managers to the full implementation of Total Quality Management. 4. Checking As with all management systems there will need to be periodic checks. These must be clearly spelt out, stating what is checked, how, and who takes action. 5. Management Review This is the main review of efficiency and effectiveness. Management action and changes may need to be implemented. 6. Continual Improvement The circle has to be closed. If changes need to be made then these will involve the policy, the planning and the implementation stages • Policy-making. • Setting objectives and performance standards. • Providing resources. • Making judgments - considering alternatives. • Coming to decisions. • Taking action. • Accountability. • Monitoring and control. Safety legislation places on management the major responsibility for the health and safety of workers and others on a company’s premises. While most of these duties cannot be delegated, the day-to-day activities clearly are. In this section, we examine some practical management issues in more detail. Appropriate Allocation of Resources The provision of both financial (for equipment, training, consultancy, etc.) and manpower (enough and with the right skills) resources is essential in the management of health and safety. Risk assessment is a powerful tool for identifying priorities for which resources need to be allocated. However, management expects that the benefits will outweigh the costs because accidents and compensation for occupational illness can be very expensive items. Costs of accident and ill health prevention need to be carefully controlled and effective. An important factor in this equation is that the costs of accident prevention have a ‘lead time’. Money has to be spent in advance of the benefits being felt. Safety training, which is also a requirement of legislation, shows results some time after the expenditure has been incurred. 1-16 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Introduction to Management Systems The safety practitioner needs to think very carefully about ways of calculating the cost of accidents and ill-health, so that there are definite figures available to demonstrate the benefits of any accident reduction which has been achieved. We look at cost/benefit analysis in a later element. Appropriate Allocation of Responsibilities Responsibilities should be linked to specific outputs. Good performance standards should identify: • Who is responsible - either by name or position. Those given responsibilities should be competent to carry out the tasks. • What they are responsible for - what needs to be done and how it is to be done. Part of management control is making sure that responsibilities for specific tasks and roles are allocated to individuals within the organisation. • When the work should be done - is it a regular occurrence, such as a monthly inspection, or irregular and only when certain tasks are carried out? Responsibilities must: • What the expected result is - do any legal requirements have to be satisfied, such as attaining a certain level of noise? The result may, alternatively, be the achievement of a specified organisational output, such as training. • Be clear (especially important when third parties are involved) – people should know what they are responsible for. • Be allocated to individuals who have the necessary competence. • Be supported with necessary resources. • Go hand in hand with accountability. Everyone will have responsibility for health and safety to some extent, but some will have specific additional responsibilities, such as: • Preparing plans to implement the health and safety policy. • Carrying out risk assessments in accordance with specific regulations. • Periodic monitoring of health and safety performance. • Providing training. • Checking contractors’ health and safety performance before awarding contracts. • Providing first aid after an accident. To ensure that the standards are being achieved, it is important to monitor them. This will allow shortcomings to be identified and action taken to correct them. Monitoring should be seen as an integral part of the management system and not as ‘checking up’ on individuals. Feedback and Implementation of Corrective Action For any system to be effective, it is necessary to have a complete loop that allows for action to be taken where discrepancies are identified. By feeding back, to the appropriate people within the organisation, information obtained during monitoring and audit processes, suitable corrective action can be implemented. Without this important function, the whole management system will fail to develop and become a paper exercise with no discernible improvement in safety. ROLE OF THE HEALTH AND SAFETY POLICY Setting and Monitoring Performance Standards In order to determine how well an organisation is performing in any function it is necessary to have something to measure. It is important to ensure that everybody knows what is expected of them in controlling risks within the organisation. Performance standards should ensure that the intentions of the safety policy are transferred into action. Standards should be measurable, achievable and realistic. Standards should: • Set out clearly what people need to do to contribute to an environment which is free of injuries, ill health and loss. In Relation to a Health and Safety Management System The policy sets the whole framework of the Safety Management System (SMS). From an SMS point of view, the policy is just a statement of intent – a demonstration of commitment. It frames the company vision on health and safety. The policy should state the overall health and safety objectives of the organisation and express commitment to improving health and safety performance; to demonstrate that commitment, it should be authorised by top management. It should commit the organisation to continual improvement and compliance with legislation, and should be communicated to all employees and other interested parties, and kept up to date by periodic review. • Help identify the competencies which individuals need to fulfil their responsibilities. • Form the basis for measuring individual, group and organisational performance. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-17 Introduction to Management Systems As a Vehicle for the Communication of Health and Safety Information Effective health and safety policies contribute to business performance by: A health and safety policy: • Supporting human resource development. • Tells people about a company’s approach to managing health and safety. • Minimising the financial losses which arise from avoidable unplanned events. • Communicates the organisation’s commitment to health and safety to existing employees (preferably by means of their own copy). • Recognising that accidents, ill health and incidents result from failings in management control and are not necessarily the fault of individual employees. • Can be used: • Recognising that the development of a culture supportive of health and safety is necessary to achieve adequate control over risks. –– In the induction of new employees (to stress the importance of safety). –– To involve workforce representatives in writing and amending the policy, when necessary. –– At regular briefing sessions to communicate information relating to different sections of the policy. REQUIREMENTS FOR A WRITTEN HEALTH AND SAFETY POLICY AND FOR RECORDING ARRANGEMENTS A health and safety policy may be a requirement of national legislation in some regions. Even if it is not a legal requirement, it is required by ILO-OSH 2001 (which supports ILO conventions) and OHSAS 18001. The policy should be documented (paper or electronic) and authorised by top management (e.g. chief executive officer). The policy is meaningless on its own; it needs to be implemented through “organisation” and “arrangements” within a safety management system. • Ensuring a systematic approach to the identification of risks and the allocation of resources to control them. • Supporting quality initiatives aimed at continuous improvement. COMMON HEALTH AND SAFETY MANAGEMENT SYSTEMS IN GLOBAL ORGANISATIONS Simplistically, implementation steps must include: • Choose a safety management system – what might influence your choice? • Initial status review (gap analysis). • Make it happen – harder than it sounds! The gap analysis will need a number of inputs, such as: • Information relating to risk assessment. • Review of occupational safety and health performance (accident statistics, etc.). GENERAL PRINCIPLES AND OBJECTIVES OF A HEALTH AND SAFETY POLICY DOCUMENT • Information on current occupational safety and health management arrangements and procedures. The health and safety policy is usually made up of: • Competence and training needs. • A statement of intent that sets out the aims and objectives of the organisation regarding health and safety. • Worker participation. • An organisational structure that details the people with health and safety responsibilities and their duties. • The systems and procedures in place to manage risks. • Standards (legal, guidance on best practice, codes of practice). This is then used to formulate an occupational safety and health management plan to cover: • Policy. • Risk assessment. • Management arrangements for occupational safety and health. • Competence and training needs. 1-18 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Introduction to Management Systems Most safety management systems come with extensive practical guidance in subsidiary documents, which tell you how to get started and continue the process. It takes time, resources and commitment to achieve the perfect system and then implement it. Accept that your initial system will not be perfect and use the in-built mechanisms of audit, performance measurement, review, etc. to continually improve the system. Fundamental to this process is the safety culture within the organisation (see later elements). Some of the drivers, benefits and limitations of implementing common systems, principles and standards within a global organisation include: • A formal occupational health and safety management system approach is increasingly favoured by regulators throughout the world, and may be legally required in some regions. • Modern goal-setting legislation implies the need for an occupational health and safety management system as a form of “self-regulation”. • Multi-national organisations favour a consistent, standardised approach throughout the organisation – just like the business management system (“globalisation”). • Possible cultural/social and legal barriers. • Possible resistance to change (adequacy of existing systems, bureaucracy, cost). INFLUENCE OF CORPORATE RESPONSIBILITY AND BUSINESS ETHICS ROLE OF HEALTH AND SAFETY IN GLOBAL CORPORATE SOCIAL RESPONSIBILITY (CSR) GUIDELINES AND STANDARDS UN Global Compact The Global Compact is a CSR initiative. The ultimate vision is a more sustainable and inclusive global economy. The principles are based on a number of well known agreements: • Universal Declaration of Human Rights. • International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. • The Rio Declaration on Environment and Development. • United Nations Convention Against Corruption. The fundamental “ten universal principles” of the Global Compact (subscription to which is voluntary) are described below (with some examples of possible health and safety management system contributions). Human Rights Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and (e.g. Health and safety management systems can help ensure legal compliance and consistent application of standards in different parts of the world (even where they have lower national standards). Investing in a positive health and safety culture can help retain staff, too.) “Corporate responsibility” (also called corporate social responsibility) is difficult to define and is used to cover a wide range of issues. Essentially it is where businesses take account of their social, economic and environmental impacts (all of which can affect their reputation and profitability). Some impacts of corporate responsibility on safety management include: Principle 2: make sure that they are not complicit in human rights abuses. • Greater board-level leadership (directors). (e.g. Good health and safety management encourages consultation and participation at every level.) • Public reporting of health and safety performance (annual reports to shareholders). • Improved management control systems – (health and safety risks seen within the overall business risk management framework). In practice it means a whole range of initiatives, because it goes beyond mere basic compliance with legal requirements and concentration on short-term costs/ benefits. Corporate responsibility invests in the long-term benefits of more socially positive projects, e.g. work-life balance. We will consider some of these issues again when we look at organisational factors. © RRC International Labour Standards Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle 4: the elimination of all forms of forced and compulsory labour; Principle 5: the effective abolition of child labour; and Principle 6: the elimination of discrimination in respect of employment and occupation. (e.g. This could potentially occur in an occupational health and safety context – so the safety management system should help ensure that selection of an individual for a task is based on such things as suitability, competence and risk, rather than gender, age or physical capability. The safety management system should help adapt procedures, tasks and equipment to the individual by making reasonable adjustments.) Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-19 Introduction to Management Systems Environment Principle 7: Businesses should support a precautionary approach to environmental challenges; Principle 8: undertake initiatives to promote greater environmental responsibility; and (e.g. Even without specific environmental management systems, a safety management system will necessarily have an impact on some environmental issues. For example, the identification and prevention/control of potential chemical spillage scenarios will have a positive benefit for the environment.) Principle 9: encourage the development and diffusion of environmentally friendly technologies. Anti-Corruption Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery. (e.g. A documented SMS should make the processes transparent and some forms of corruption easier to detect.) The idea is that these principles should be embedded in all the activities of a business so that the organisation behaves with a social conscience. Businesses are encouraged to sign up to the principles and report their progress annually in a “Communication on Progress“ report. See if you can think of how your organisation might implement these basic principles in the health and safety context. Social Accountability 8000 This is an auditable standard and shares a number of principles with the UN Global Compact because it is based on some similar global conventions. However, it is wider in scope – it requires compliance with a wide range of ILO conventions, as well as the Universal Declaration of Human Rights and the UN Convention on the Rights of the Child. The standard can be downloaded (in several different languages) from www.sa-intl.org/. Whilst the standard is freely available, specific implementation guidance is not. The basic principles include: 1. Child Labour: no use or support of child labour; remediation of children found to be working; support to enable attendance at school; conditional employment of young workers. 2. Forced or Compulsory Labour: no use or support of forced labour or human trafficking; personnel free to terminate employment. 3. Health and Safety: provide a safe and healthy workplace; prevent accidents; provide PPE; senior manager responsible for OSH; establish a health and safety committee; health and safety training for all workers; system to detect and respond to health and safety risks; 1-20 accident records; access to toilets and potable water; suitable areas for meal breaks; worker’s right to remove himself from imminent danger; reduce risks to new and expectant mothers. 4. Freedom of Association and Right to Collective Bargaining: respect the right to form and join a trade union; where law restricts these freedoms, allow freely elected representatives; no discrimination on account of participation in worker organisations. 5. Discrimination: no discrimination on account of race, caste, origin, religion, disability, gender, sexual orientation, union or political affiliation, or age; no threatening or abusive behaviour. 6. Disciplinary Practices: treat personnel with dignity and respect; no corporal punishment, mental or physical abuse. 7. Working Hours: comply with the law and industry standards; no more than 48 hours per week; one day off for every seven-day period; voluntary overtime not exceeding 12 hours per week; overtime mandatory only if part of a collective bargaining agreement. 8. Remuneration: right to living wage – at least legal minimum; no disciplinary deductions; overtime paid at premium rate. 9. Management System: to gain and maintain certification, organisations must go beyond simple compliance and integrate the standard into their management systems and practices. SA8000:2014 is the recently revised version which makes no substantive changes but clarifies the language used, is more consistent throughout the elements and explicitly addresses abusive practices that have become more common since 2008. Global Reporting Initiative (GRI) The stated vision of the GRI is to make reporting on economic, social and environmental performance as routine as financial reporting. The GRI is therefore a standard framework for reporting, and contains some specific occupational health and safety Reporting Performance Indicators (RPI). The GRI reporting can be used to produce the UN Global Compact’s annual “Communication on Progress” report. Companies routinely report finances. Company finances are, of course, part of economics but economics is wider than that. In this context, we are interested in the impact of the business on the wider economic system as a whole, as well as social and environmental impacts/performance. You can download a full copy of the reporting guidelines from www.globalreporting.org. | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Introduction to Management Systems Health and safety has a clear role in supporting the GRI, which in turn supports the Global Compact, and so corporate social responsibility. In terms of health and safety (which is considered part of the “social” reporting category), there are some specific items of note for disclosure in reporting: • Management approach to occupational health and safety. • Goals and performance. • Organisation responsibility (i.e. the organisational roles/structure assigned to dealing with it). • Training and awareness aspects. • Monitoring and follow-up (corrective actions, etc.). RPIs identified for disclosure on occupational health and safety include: MORE… A full copy of the reporting guidelines can be downloaded from: http://www.globalreporting.org The European Agency for Safety and Health at Work guide, Management Leadership in Occupational Safety and Health – a practical guide, gives business leaders practical information on how safety and health can be improved through effective leadership, worker involvement and ongoing assessment and review and is available at: https://osha.europa.eu/en/publications/reports/ management-leadership-in-OSH_guide/view • G4-LA5 - Percentage of total workforce represented in formal joint management–worker health and safety committees that help monitor and advise on occupational health and safety programmes. –– Includes reporting the level at which each committee typically operates within the organisation. • G4-LA6 - Type of injury and rates of injury, occupational diseases, lost days, and absenteeism, and total number of work-related fatalities, by region and by gender. –– Reporting to cover all employees, supervised workers, independent contractors and the rules applied in recording and reporting accident statistics. • G4-LA7 - Workers with high incidence or high risk of diseases related to their occupation. • G4-LA8 - Health and safety topics covered in formal agreements with trade unions. –– Reporting to include local and global agreements and the extent (as a percentage) to which health and safety topics are covered. (Based on original source G4 Sustainability Reporting Guidelines, Global Reporting Initiative, 2013) REVISION QUESTIONS 3. List the elements in the following safety management systems: (a) ILO-OSH-2001 Guidelines on Occupational Health and Safety Management Systems. ILO, 2001. (b) OHSAS 18001 Occupational Health and Safety Management Systems: Requirements. British Standards Institution, 2007. 4. Describe the general principles and objectives of a health and safety policy document. 5. Outline the arguments for and against integration of management systems. (Suggested Answers are at the end.) © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-21 Role and Responsibilities of the Health and Safety Practitioner KEY INFORMATION • Health and safety practitioners develop policy, promote a positive culture, plan to meet objectives, implement and monitor the policy, and review and audit the whole system. • Health and safety practitioners require good person management and influencing skills. • It is important that health and safety practitioners maintain and develop their individual competencies. • The Institution of Occupational Safety and Health (IOSH) and the International Institute of Risk and Safety Management (IIRSM) have codes of conduct which members are expected to comply with. INFLUENCE ON HEALTH AND SAFETY MANAGEMENT SYSTEMS Health and safety practitioners are those likely to be appointed by employers to help them in managing health and safety in the organisation. Health and safety practitioners need to have the status and competence to advise management and employees, or their representatives, with authority and independence. They are well placed to advise on many aspects of the safety management system, such as: • Formulating and developing health and safety policies and plans, not just for existing activities but also with respect to new acquisitions or processes. • Be involved in establishing organisational arrangements, systems and risk control standards relating to hardware and human performance, by advising line management on matters such as legal and technical standards. • Establish and maintain procedures for reporting, investigating, recording and analysing accidents and incidents. • Establish and maintain procedures, including monitoring and other means such as review and auditing, to ensure senior managers get a true picture of how well health and safety is being managed (where a benchmarking role may be especially valuable). • Present their advice independently and effectively. • Profiling and assessing risks and organising activities to implement the plans. In terms of organisational structure/relationships, health and safety specialists must: • Measuring performance by assessing how well the risks are being controlled and investigating the causes of accidents, incidents or near misses. • Support the provision of authoritative and independent advice. • Reviewing performance, revisiting plans, policy documents and risk assessments to see if they need updating and taking action on lessons learned, including from audit and inspection reports. To do this properly, health and safety practitioners need to: • Be properly trained and suitably qualified. • Have a direct reporting line to directors on matters of policy, and the authority to stop work if it contravenes agreed standards and puts people at risk of injury. • Have responsibility for professional standards and systems. On large sites or in a group of companies, they may also have line management responsibility for other health and safety specialists. • Maintain adequate information systems on topics including law, health and safety management, and technical advances. As far as relationships outside the company go, they must liaise with a wide range of bodies, including: • Interpret the law in the context of their own organisation. • Consultants/contractors. • Local officials. • Fire service. • Insurance companies. • Enforcing authorities. 1-22 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Role and Responsibilities of the Health and Safety Practitioner HEALTH AND SAFETY INVOLVEMENT AND CONDUCT RESPONSIBILITY TO EVALUATE AND DEVELOP THEIR OWN PRACTICE Health and safety practitioners need to be able to effectively influence the decision-makers, namely the senior management of the organisation, and also have the confidence and respect of all workers. It is therefore essential for them to have good influencing and person management skills which achieve the desired objectives without creating conflict, resentment or animosity. As well as requiring competency in practical risk management, the standards in occupational health and safety practice, which this NEBOSH International Diploma course is designed to meet, also require the practitioner to be able to evaluate and develop his/her own practice. This is in line with the IOSH requirement for continuous professional development, and ensures that the practitioner maintains and develops competency, keeps up to date and remains effective. COMPETENCE AND THE REQUIREMENTS FOR CONTINUING PROFESSIONAL DEVELOPMENT The broad requirements are that practitioners should: • Reflect on their own practice. Meaning of ‘Competence’ • Review their practice against appropriate goals. A competent health and safety adviser can be considered as having “sufficient training and experience or knowledge and other qualities to enable him to properly discharge his professional responsibilities”. • Set and prioritise goals and targets for selfimprovement. • Adapt their own practice in the light of changes in professional practice. Accordingly the term reflects a combination of knowledge and relevant experience, although these terms are not mutually exclusive. Consequently, in order to achieve this, practitioners need to: Continuing Professional Development (CPD) • Identify goals and targets which could be set in a number of ways, e.g. from national standards; from assessment of current competency; from anticipated future demands; from personal aspirations; or to meet organisational needs. CPD is a feature required by most professional bodies and is undertaken when the practitioner is considered competent and satisfies the requirements for full membership of the professional body. It serves the following purposes: • Demonstrating competence and credibility. • Developing an individual’s career and helping with appraisal. • Coping with change by updating skills. • Thinking about competence and identifying gaps in knowledge and experience. • Review their own performance, which might involve evaluating work results, undergoing appraisals or formative assessments, or seeking the views of colleagues and clients. • Develop their personal action plans and monitor their achievements. • Develop and change their own practice, and evaluate the effectiveness of the developments. • Anticipate and identify change, and respond appropriately. This could arise from changes in professional practice, from national and local systems or from changes to organisational policy and procedures. These requirements can be divided into two principal components: evaluation, and identification of selfdevelopment needs. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-23 Role and Responsibilities of the Health and Safety Practitioner Evaluating Own Practice The IOSH has a Code of Conduct which all members are expected to follow. This requires members to: Performance Criteria • Owe a loyalty to the workforce, the community they serve and the environment they affect. The practitioner should be able to: • Evaluate their own practice against set targets and goals. • Abide by relevant legal requirements. • Use a range of valid and reliable evidence to assess their own work, which includes an assessment of behaviour and values by others. • Maintain their competence. • Involve others in the interpretation of evidence. • Accept professional responsibility for their work. • Use evidence to reflect on their own practice and professional issues. • Make those who ignore their professional advice aware of the consequences. • Accept criticism in a positive manner, and assess its validity and importance. • Not bring the professional body into disrepute. • Revise goals and targets in the light of their reviewing evidence and performance. Identifying Self-Development Needs • Give honest opinions. • Undertake only those tasks they believe themselves to be competent to deal with. • Not recklessly or maliciously injure the professional reputation or business of others. • Not behave in a way which may be considered inappropriate. Performance Criteria • Not use their membership or position within the organisation or Institution improperly for commercial or personal gain. The practitioner should be able to: • Avoid conflicts of interest. • Set and prioritise clear and realistic goals and targets for their own development. • Not disclose information improperly. • Base goals and targets on the accurate assessment of all the relevant information relating to their own work and achievements, including developments in professional practice and related areas. • Devise a personal action plan and review it regularly. • Try out developments in their own practice in a way which does not cause problems for others. • Evaluate developments in their own practice and ensure continued self-development. An essential ingredient of competence is recognising its limits - when you begin to get involved in an area which is beyond your competence and you need to either call in external expertise, or upgrade your skills. ETHICS AND THE APPLICATION OF ETHICAL PRINCIPLES At the beginning of this element we discussed the moral reasons for managing health and safety. Ethics is concerned with moral issues, i.e. the judgments we make and our resulting conduct. Just because an action we might take is legal does not necessarily mean it is ethical. This is best explained by identifying the ethical principles we would expect practitioners to adopt, such as: • Ensure information which they hold necessary to safeguard the health and safety of others is made available on request. • Comply with data protection principles and relevant legislation. • Maintain financial propriety with clients and employers and where appropriate be covered by professional indemnity insurance. • Act within the law and notify the Institution if convicted of a criminal offence. MORE… You can find out more about the Institution of Occupational Safety and Health Code of Conduct at: www.iosh.co.uk/~/media/Documents/About%20 us/COR1081%20Code_%20guidance%20and%20 disciplinary%20procedure.ashx • Honesty in dealings with clients, etc. • Respecting others. • Professional integrity, etc. 1-24 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Role and Responsibilities of the Health and Safety Practitioner Similarly the IIRSM has a Code of Ethics which requires members to: • Only advise on or undertake tasks where they are competent to do so. • Ensure professional competence is maintained and developed. In the example above, the likely outcome if the conflict of interest was declared before the appointment was made would be for the manager not to sit on the appointment panel. If, however, the possible conflict was concealed and later became known, then the manager could be accused of unprofessional conduct. • Avoid conflicts of interest. • Inform the appropriate authority of any illegal or unethical safety-related behaviour. • Conduct themselves with fairness when dealing with others and not engage in discrimination. • Act as the faithful agent of their clients or employers and accept responsibility for their own work. • Assist colleagues in their professional development and support them in following the Code. • Not bring the Institute into disrepute. MORE… You will find more information on the International Institute of Risk and Safety Management Code of Ethics at: www.iirsm.org/ DEALING WITH CONFLICTS OF INTEREST A conflict of interest arises when an individual has to make a decision at work that may affect his or her private interests. For example, the safety manager of a large organisation has the task of appointing a new safety adviser. One of the candidates for the post is a good friend of the manager, who expects favourable treatment even though he may not be the best qualified and experienced candidate. The conflict of interest dilemma the manager has is whether to let a personal interest interfere with his professional judgment. What should you do when a conflict of interest arises? There are two aspects to dealing with conflicts of interest: • Identifying and disclosing the conflict of interest, which is primarily the responsibility of the individual who is subject to the conflict. It is clearly better to err on the side of openness even when the situation is not clearcut, particularly in the long term when the conflict may become more widely known and more difficult to resolve, leading to the possible accusation of bias or even dishonesty. • Deciding what action (if any) is necessary to avoid or mitigate any consequences, usually the responsibility of the manager or department in which the conflict has arisen. This may range from taking no action at all to, in extreme circumstances, the resignation or dismissal of the individual concerned. © RRC International REVISION QUESTIONS 6. Identify five external bodies or individuals that a safety professional may be expected to liaise with in the course of their work. 7. Identify five examples of how a safety practitioner would be expected to adhere to ethical principles. (Suggested Answers are at the end.) Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-25 Summary SUMMARY Reasons for Managing Health and Safety This element has introduced you to the general principles of health and safety management. We have looked at the reasons for managing risk and seen that they fall into three categories - moral, legal and economic. Societal Factors Which Influence Health and Safety Standards and Priorities We have identified: • Economic climate. • Government policy and initiatives. • Sickness absence and incapacity. • Industry/business risk profile. • Globalisation. • Migrant workers. • Societal expectations of equality. • Corporate social responsibility. Introduction to Management Systems We have: • Considered the meaning of the terms: –– Hazard - something with the potential to cause harm. –– Risk - expresses the likelihood that the harm from a particular hazard is realised. –– Danger - a liability or exposure to harm; a thing that causes peril. • Examined the principles and benefits of risk management on a global perspective. • Looked at two specific safety management system models which are conceptually very similar: –– ILO-OSH-2001. –– OHSAS 18001. • Considered the benefits and limitations of integrated management systems. • Identified the following key components of an effective health and safety management system: –– Management commitment. –– Policy. –– Organising. –– Planning and implementing. –– Performance review. –– Audit. –– Continual improvement. • Examined the total quality management and environmental management systems: –– ISO 9000 series. –– ISO 14000 series. 1-26 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Summary • Discussed the reasons for the introduction of formal health and safety management systems such as: –– Appropriate allocation of resources and responsibilities. –– Setting and monitoring performance standards. –– Establishment of systems for feedback and implementation of corrective action in order to minimise loss. • Explained the role of the health and safety policy in relation to a health and safety management system and as a vehicle for the communication of health and safety information. • Examined the requirements for a written health and safety policy and for recording arrangements. • Described the general principles and objectives of a health and safety policy document. • Discussed the implementation, benefits and limitations of the introduction of common health and safety management principles, standards and systems in organisations operating on a world-wide basis. • Explained the influence of corporate responsibility and business ethics on health and safety management. • Examined the role of health and safety in global Corporate Social Responsibility (CSR) guidelines and standards (United Nations Global Compact; SA8000; Global Reporting Initiative). Role and Responsibilities of the Health and Safety Practitioner • We have established that health and safety practitioners should: • Be able to advise, develop and influence the decision-makers. • Be able to advise management and employees on various aspects of health and safety. • Be suitably trained and qualified, and able to perform necessary functions. • Establish suitable relationships both within their own organisations and with outside bodies and individuals. • Evaluate and develop their own practice, e.g. continuing professional development. • Adhere to the ethical policy of their professional body. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-27 Exam Skills INTRODUCTION It should go without saying that to achieve the NEBOSH International Diploma you will need to work carefully through your course. But you also need to perform when it really matters - in the exam. As you work through the course you will build up your confidence in preparation for the exam day. Before we get any further, let’s just outline some basic information about the exam itself: • You have three hours to complete the exam, plus 10 minutes reading time. • There are two sections: –– Section A: six compulsory question (10 marks each). –– Section B: you can choose to answer three questions from five on the paper (20 marks per question). So there are 120 marks available in total. The exam questions require you to demonstrate your knowledge and understanding of the elements you have studied as part of your course – and to show that you can apply your knowledge and understanding to both familiar and unfamiliar situations. That might sound daunting, but basic exam technique is really quite simple (as long as you know the information, of course!). Essentially, what you need to do is: • Step 1: Read each question carefully. • Step 2: Review the marks available (consider how long you should spend on the question and how many points of information you need to include). • Step 3: Highlight the key action words. • Step 4: Read the question again. • Step 5: Plan your answer (using mind maps, bullet points, etc.) so that you have a structure to work to. • Step 6: Answer the question in full, keeping a close eye on the time (allow 15 minutes for a Section A, 10 mark question, and 30 minutes for a Section B, 20-mark question). You will find more guidance as you work through the course along with plenty of sample/practice questions. It’s really important that you complete these and get in touch with a tutor if you have any queries or there is anything you are struggling with. HINTS AND TIPS Taking notice of the action verbs when answering questions is essential! NEBOSH has published the following guide to understanding the action verbs: Action Verb Meaning 1-28 Define Provide a generally recognised definition Describe Give a word picture Explain Give a clear account of, or reasons for Give Provide without explanation (used usually with the instruction “give an example of…” Identify Select and name Outline Give the most important features of (less depth than “explain” or “describe” but more depth than “list”) | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Exam Skills We have provided some sample answers that a student may give, together with some possible answer points that the examiners indicated that they would expect to see covered. They are summarised from examiners’ reports, but neither the student response nor the possible answer points are model answers. The possible answers are also NOT provided as a full answer – in an exam you would need to expand upon the bullet points, taking into account the action verbs, in order to answer the question correctly. Providing the examiner with such a brief answer would not attract good marks. HINTS AND TIPS As a rough guide, you will be expected to provide one answer point for each mark available in a sub-question, i.e. two points should be included to gain full marks for a two mark sub-question, eight points for an eight mark sub-question, etc. However, if you have time, try to include an extra answer point or two where you can – this will increase your chances of gaining full marks. Be aware of your timing. It’s important not to spend too long on a particular question and run out of time at the end as a result. The real key to success is answering all the questions you need to and answering them well! You will find more guidance as you work through the course along with plenty of sample/practice questions. It’s really important that you complete these and get in touch with a tutor if you have any queries or there is anything you are struggling with. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-29 Exam Skills QUESTION An organisation is proposing to move from a health and safety management system based on the International Labour Organisation ILO-OSH-2001 model to one that aligns itself with BS OHSAS 18001. Outline the possible advantages AND disadvantages of such a change. (10) APPROACHING THE QUESTION Now think about the steps you would take to answer this question: Step 1: Read the question carefully. Step 2: Next, consider the marks available. This question is worth 10 marks so you are expected to provide around ten/twelve different points of information; the question should take around 15 minutes to answer. Step 3: Now highlight the key words. In this case. the question might look like this: An organisation is proposing to move from a health and safety management system based on the International Labour Organisation ILO-OSH-2001 model to one that aligns itself with BS OHSAS 18001. Outline the possible advantages AND disadvantages of such a change. (10) Step 4: Read the question again to make sure you understand it and have a clear understanding of the two management systems it is asking about. (Re-read your notes if you need to.) Step 5: The next stage is to develop a plan – there are various ways to do this. A common approach is to outline the advantages and disadvantages between the two health and safety management systems. Remember that your answer must be based on the key words you have highlighted. Step 6: Now you are in a position to have a go at answering the question. Provide your answer in table form only at this stage, bullet points and an explanation of each point. Hint – integration of systems is an important factor! HINTS AND TIPS Don’t worry too much about the grammar and spelling in your answer, but the Examiner MUST be able to understand what you are trying to say. There must be a logical flow to the information you provide and this is where your Answer Plan is so important. Also remember that the Examiner MUST be able to read your handwriting – if they can’t read what you have written they can’t award you any marks! SUGGESTED ANSWER OUTLINE Advantages and Disadvantages of moving from ILO OSH 2001 to OHSAS 18001 Possible Advantages • Integration of systems – a move to OHSAS 18001 would facilitate easier integration with BS EN ISO 14001 and ISO 9001:2008 to produce an integrated management system • Publicity – if opting for external certification it is an opportunity to promote the company through having an independently verified system • Benchmarking – easier to benchmark performance with other companies that have this certification • Continual improvement – shows the company is committed to continually improving its performance When you have finished have a look at the following comments and guidance. The following is an answer that a student might have produced in the examination room. 1-30 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 Exam Skills Possible Disadvantages • Although OHSAS 18001 is a well-known standard, it may produce a system that significantly exceeds the minimum legal standard. Regulators, however, tend to prefer the simple and straightforward approach offered by systems based on ILO-OSH-2001, which conform more closely to the basic legal requirements • Costs – costs involved in changing to this system, including registration, optional external certification, changes to standards/paperwork, etc. • Costs in terms of time – changing from one system to the other will involve a lot of time from management, staff and H&S professionals • Paperwork – increased paperwork to get certificated by the awarding body • Possibly too complicated – a system based on OHSAS 18001 may be more than what a small or medium-sized company really needs and may be too difficult to implement for that reason • Audits for OHSAS 18001 compliance may not be conducted by auditors with detailed health and safety knowledge • Audits may not involve the company’s H&S professionals if integrated with other systems such as quality or the environment HINTS AND TIPS A question that asks you to “outline” something, expects you to give the key features of something – a brief explanation or description. © RRC International Unit IA – Element IA1: Principles of Health and Safety Management v2.1 | 1-31 Exam Skills POSSIBLE ANSWER BY EXAM CANDIDATE IILO-OSH-2001 follows a tried and tested approach, which has been used by quality organisations for a number of years and has been championed by the regulators. It is used by companies of all types as a ‘starting point’ for building a safety management system because it has the advantage of being relatively simple and straightforward and does not require the approval of an external body in the same way as other systems such as OHSAS 18001 do. In essence, a company can simply set up its systems using the framework provided by ILO-OSH-2001 without the need to go through potentially costly and time-consuming certification processes. ILO-OSH-2001 may be perfectly satisfactory for a small business that does not need to go to the expense and trouble of developing a more sophisticated system like OHSAS 18001. However, as the business grows, its management systems inevitably become more complex and so it may consider moving to OHSAS 18001, which offers an integrated solution. External, third party certification is available for BS OHSAS18001. If a company chooses to use this option, it will incur initial and on-going costs, including extra paperwork and activities to source information, procedures, etc. However, this could potentially strengthen the organisation’s image, as this is done by an outside agency, rather than being done inhouse, and would be seen as more independent. By achieving the OHSAS 18001 standard, the company would be able to promote its business within the local community and secure orders/work with organisations that require an externally certificated standard. If the organisation already has other certificated systems such as BS EN ISO 14001:2004 or BS EN ISO 9001:2008, they may be able to integrate the systems to save money, as well as helping to embed H&S into the organisation. Other benefits from moving to a system based on OHSAS 18001 include the opportunity to undertake an initial review and measure the organisation’s current practices to establish where improvements can and/or should be made. The process allows a company to actually measure the improvements it has made. The final thing to consider with the new system would be that 18001 looks at ‘continuous improvement’ as one of its central themes, so the organisation can look at getting better performance over a period of time. REASONS FOR POOR MARKS ACHIEVED BY CANDIDATES IN EXAM An exam candidate would achieve poor marks for an answer that did not: • Demonstrate a clear understanding of the differences between the systems. • Identify BS OHSAS 18001 as an integrated management system. • Outline the possible advantages and disadvantages of moving from one management system to another. • Concentrate on advantages and disadvantages of each system and strayed into providing a description of the components of each system. 1-32 | Unit IA – Element IA1: Principles of Health and Safety Management © RRC International v2.1 LOSS CAUSATION AND INCIDENT INVESTIGATION ELEMENT 2 LEARNING OUTCOMES On completion of this element, you should be able to demonstrate understanding of the content through the application of knowledge to familiar and unfamiliar situations and the critical analysis and evaluation of information presented in both quantitative and qualitative forms. In particular you should be able to: Explain theories of loss causation. the quantitative analysis of accident/incident Explain and ill-health data, limitations of their application, and their presentation in numerical and graphical form. Explain the external and the internal reporting and recording systems for loss events (injuries, ill health, dangerous occurrences) and near misses. loss and near-miss investigations; Explain the requirements, benefits, the procedures, the documentation, and the involvement of and communication with relevant staff and representatives. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-1 Contents THEORIES OF LOSS CAUSATION Accident/Incident Ratio Studies Domino and Multi-Causality Theories Immediate, Underlying and Root Causes Reason’s Model of Accident Causation Revision Questions 2-3 2-3 2-4 2-7 2-8 2-9 QUANTITATIVE ANALYSIS OF ACCIDENT AND ILL-HEALTH DATA Calculating Loss Rates from Raw Data Statistical and Epidemiological Analyses in the Identification of Patterns and Trends Presenting and Interpreting Loss Event Data Principles of Statistical Variability, Validity and the Use of Distributions Revision Question 2-10 2-10 2-11 2-11 2-15 2-16 REPORTING AND RECORDING OF LOSS EVENTS (INJURIES, ILL HEALTH, DANGEROUS OCCURRENCES) AND NEAR MISSES Reporting Requirements and Procedures Internal Reporting and Recording Revision Questions 2-17 2-17 2-19 2-27 LOSS AND NEAR-MISS INVESTIGATIONS Purposes of Accident Investigation Investigation Procedures and Methodologies Communications Focusing on Remedial Actions and Lessons Learnt Use of Failure Tracing Methods as Investigative Tools Revision Questions 2-28 2-28 2-30 2-34 2-34 2-34 SUMMARY 2-35 EXAM SKILLS 2-37 2-2 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Theories of Loss Causation KEY INFORMATION • Incident studies have demonstrated that in any organisation there is a relationship between the number of major incidents and those with less serious outcomes. • The Single Cause Domino Theory suggests that in an accident there is a sequence of events or circumstances that precede the harm, i.e. –– Ancestry (i.e. upbringing). –– Fault. –– Unsafe act. –– Accident. –– Injury. • Multi-causal theories suggest that preceding an incident there is a combination of causal factors at each level that may combine to lead to the loss event. • Reason’s model of organisational accidents states that for a major accident to occur a series of defences must be defeated for the hazard to lead to a loss event. Unsafe acts may cause the failure of the defences. Unsafe acts are made more likely by local conditions in the workplace. Other researchers have produced similar accident ratio triangles: ACCIDENT/INCIDENT RATIO STUDIES There is no shortage of data on incidents such as accidents or near misses. Some researchers have studied the figures in detail and concluded that there appears to be a relationship between the numbers of different types of accident. Labour force survey 1990 F. E. Bird used accident data to produce the following accident triangle: UK accident data Bird’s accident ratio triangle © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-3 Theories of Loss Causation DOMINO AND MULTI-CAUSALITY THEORIES One of the duties of the safety practitioner is to keep details of accidents and ill-health conditions and carry out investigations. The law requires certain accidents and occupational diseases to be reported. Often the information that is recorded at the time of an accident is not adequate for the purpose of investigation into the cause, and so is certainly inadequate for the purpose of preventing the accident happening again. For example, the report form may ask for the nature and cause of the injury. This could be written as: Heinrich’s accident triangle The actual figures vary between the different accident triangles, but the important thing to note is that for every major incident or fatality, there are many more less serious or near-miss incidents. Analysis also shows that: • It is invariably a matter of chance whether a given event results in injury, damage, or a near miss, i.e. near misses could so easily become more serious incidents. • Near-miss/less-serious incident data can, therefore, be a useful predictor of accident potential. • All events are due to failure to control – so we can learn from even minor incidents. The data from these triangles has a number of limitations that you need to think about before trying to apply it: • Not every near miss or minor incident involves risks which could actually have led to a serious incident or fatality. • Nature of injury - cut finger. • Cause of injury - caught on a sharp piece of metal. The safety practitioner needs to know a lot more than this such as: • Which finger? • How serious was the cut? • Was this part of the normal job? • Should it have been sharp? • Should it have been there? • How should it have been handled? A good starting point in investigations is to consider the two basic theories for accident causation. Note that domino theory presents a simplified model, which considers only one cause of an accident. Also, in the Heinrich model, the focus is on immediate rather than root causes. Both models are highly reactive and cannot be used to predict the likelihood of accidents. • Be careful comparing: –– Different triangles. –– Different definitions (e.g. lost-time accidents). –– Different industries (with different types of risk). • Statistical significance – you need a certain amount of representative data for a meaningful comparison between your workplace and industry as a whole. 2-4 Single Cause Domino Theory According to Heinrich: “A preventable accident is one of five factors in a sequence that results in an injury. The injury is invariably caused by an accident and the accident in turn is always the result of the factor that immediately precedes it.” | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Theories of Loss Causation The five factors in Heinrich’s accident sequence are summarised in the following table. Heinrich's accident sequence Accident Factors Description 1. Ancestry and social environment Recklessness, stubbornness, greed and other undesirable traits of character that may be passed along through inheritance. Environment may develop undesirable traits of character or may interfere with education. Both inheritance and environment may cause faults of person. 2. Fault of person Inherited or acquired faults of person such as recklessness, violent temper, nervousness, excitability. These constitute reasons for committing unsafe acts or for the existence of mechanical or physical hazards. 3. Unsafe act and/ or mechanical or physical hazard Unsafe performance of persons such as: standing under danger areas, careless starting of machines, removal of safeguards and horseplay; mechanical or physical hazards such as unguarded gears or points of operation, insufficient light, which result in accidents. 4. Accident Events such as falls of persons, striking of persons by flying objects, etc. are typical accidents which cause injury. 5. Injury Fractures, lacerations, etc. are injuries which result directly from accidents. If this sequence is interrupted by the elimination of even one of these factors, the injury cannot occur and the accident has been prevented. In the case of the accident sequence, perhaps the easiest factor to eliminate is Number 3, the “unsafe act and/or mechanical or physical hazard”. The major point that Heinrich makes is that a preventable injury is the natural culmination of a series of events or circumstances which occur in a fixed logical order. Here an analogy can be made with a row of dominoes placed on end, such that if one falls it will cause the next to fall and so on throughout the series (see figure that follows). If one of the dominoes is removed, the chain of events will be halted. In the same way, consider Heinrich’s accident sequence: 1. Ancestry and social environment. 2. Fault of person. 3. Unsafe act and/or mechanical or physical hazard. 4. Accident. 5. Injury. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-5 Theories of Loss Causation Heinrich’s domino sequence Bird and Loftus extended Heinrich’s theory to take into account the influence of management in the cause and effect of accidents, suggesting a modified sequence of events: 1. Lack of control by management. 2. This permits the existence of basic causes (i.e. personal and job factors). 3. In turn, this leads to immediate causes (such as substandard practices, conditions or errors). 4. These are subsequently the direct causes of the accident. 5. Finally, this results in loss (which may be categorised as negligible, minor, serious, or catastrophic). This modified sequence can be applied to every accident and is of basic importance to loss-control management. Multi-Causal Theories There may be more than one cause of an accident, not only in sequence, but occurring at the same time. For example, a methane explosion requires: • Methane in the explosive range of 5% to 15%. • Oxygen, or air. • Ignition source. The ignition will only happen if these three events occur together. Each of the three events may, in themselves, be the end result of a number of different sequences of events. In accident investigation, all causes must be identified. 2-6 Usually simple accidents have a single cause, which is why such events so frequently occur; but the consequences tend to be of a minor nature. A major disaster normally has multiple causes, with chains of events, and combinations of events. Fortunately, they are rare occurrences. The multi-causal model considers that there may be organisational, cultural, managerial, etc. causes that interact and result in an accident. The model is more complex than the single-cause domino theory and can be used not only for accident investigation, but also to prevent accidents if the outcomes of monitoring activities are analysed. The model can also be linked to more advanced analysis techniques, such as fault trees and event trees. The downside is that they are more complex and therefore take longer to carry out. Systems Theory This is another way of looking at a multiple cause situation. Factories and processes can be viewed as systems, i.e. an assembly of parts or components connected together in an organised way to perform a task, with inputs and outputs, and various kinds of control mechanisms. A systems approach is often useful in simplifying complex operations. Part of the system can be taken as a ‘black box’, with only the inputs and outputs considered. System failures are prevented or minimised by components which cannot fail, by backup systems, or by redundancy built into the system (see Element IA4). Accidents happen in our system because it includes fallible components such as machines and human beings. The system is operating in the failure mode. You can see the essential features of the multiple causation approach in the following figure. | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Theories of Loss Causation Features of the multiple causation approach IMMEDIATE, UNDERLYING AND ROOT CAUSES There are various ways of classifying accident causes. Remember that the same term may be used by different people to mean different things – you can check this for yourself by doing an Internet search on the above terms. When analysing accidents it is common to distinguish between immediate causes and underlying causes. The latter are also sometimes called root causes. The term used can vary, but the most important thing to remember is to look beyond the symptoms of the accident. You need to dig down beyond the obvious (immediate) causes to discover why it happened, or why it was allowed to happen. Usually, an accident occurs as a result of multiple chains of events; following these back will lead to underlying causes, tackling which can stop similar accidents happening again. • Immediate cause refers to the direct cause of the accident, i.e. the actual agent of injury or damage, such as the sharp blade of the machine. • Underlying, or root causes are the less obvious systemic, or organisational reasons for the incident. We will now look at unsafe acts and conditions in more detail. © RRC International An unsafe act is human performance that is contrary to accepted safe practice and which may, of course, lead to an accident. Unsafe conditions are basically everything else that is unsafe after you take away unsafe acts. So, this is the physical condition of the workplace, work equipment, the working environment, etc. which might be considered unsafe and could therefore foreseeably lead to an accident if not dealt with. Note that an unsafe act or unsafe condition alone could result in an accident. For example, “messing around” is an unsafe act which could take place in otherwise safe conditions, but could nevertheless result in an accident. Similarly, a person could be working in a perfectly safe manner, using safe equipment and materials, but suffer injuries as the result of the collapse of a floor affected by severe woodworm and dry rot. (You could argue, however, that collapse of the floor was due to an unsafe act, i.e. failure to inspect the floor and supporting joists and to calculate the floor loadings.) According to the accident sequence we discussed earlier, unsafe acts and conditions are caused only by faults of persons, and these faults are created by the environment, or are acquired by inheritance. The faults themselves generally arise because of inappropriate attitudes, lack of knowledge or skill, or physical unsuitability. Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-7 Theories of Loss Causation REASON’S MODEL OF ACCIDENT CAUSATION TOPIC FOCUS TOPIC FOCUS However the barriers are not perfect and can be defeated. Latent and Active Failures Active failures are one cause for the barriers to be defeated. Rather than using the words “immediate”, “underlying” or “root” causes, the terms “latent” and “active” failures are also commonly used. Following research into a series of disasters, James Reason (an occupational psychologist) has developed a model of accident causation for organisational accidents. An organisational accident is rare, but if it happens it often has disastrous consequences (e.g. Piper Alpha, North Sea, 1988). Reason’s model shows that organisational accidents do not arise from a single cause but from a combination of active and latent failures. Adapted Version of Reason’s Model of Accident Causation In the model there is a series of defence barriers between the hazard and a major incident. These not only prevent the incident, (e.g. containment of the hazard, safe operating procedures, etc.) but also provide warning of danger (e.g. an alarm) and mitigate the consequences (e.g. means of escape). These multiple layers characterise complex technological systems such as a chemical plant. Active failures are those unsafe acts which have immediate effects on the integrity of the system and are usually committed by those directly involved in the task. Such individuals often suffer directly as a result of the incident and may often be blamed as well. The cause of the failure will be due to an error (accidental) or a violation (deliberate). Such unsafe acts occur regularly, but few will cause the defences to be penetrated, an example being the chemical plant operator who opens a valve allowing a hazardous substance to escape. The model then shows that the local workplace factors influence the chance of an unsafe act occurring. In the case of the hazardous substance escape, this may be due to a lack of supervision or training, maintenance failure, unworkable procedures, etc. According to the model the local workplace factors are affected by decisions made at a strategic level by senior management, government, regulators, manufacturers, etc. In the case of senior management this might be lack of recognition of the importance of occupational health and safety, which will be reflected in the culture of the organisation by the behaviour that is considered acceptable. The management may give safety a low priority with no commitment and minimal funding. These failures at the strategic levels, both in the organisation and the external environment, are described as latent failures because they remain dormant and possibly unrecognised until they interact with the local factors and the unsafe acts and work environments, and increase the likelihood of an active failure. When the gaps created by active failures align with those created by the latent conditions, the opportunity exists for a serious outcome. (Continued) 2-8 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Theories of Loss Causation Categories of Unsafe Acts Unsafe acts of persons may be categorised under the following headings: • Operating without authority. • Operating or working at an unsafe speed. • Making safety devices inoperative. • Using unsafe equipment, or using equipment unsafely. • Unsafe methods, e.g. loading, carrying, mixing. • Adopting an unsafe position or posture. • Working on moving or dangerous equipment. • “Messing/playing around”, e.g. distracting, teasing, startling. • Failure to wear safe clothing or personal protective devices. • Lack of concentration; fatigue or ill health. From this list you can see that unsafe acts may either be deliberate violations (sometimes called ‘active’) or unintentional errors (sometimes called ‘passive’). We discuss these ‘human factors’ in detail in Element IA7. Categories of Unsafe Conditions The following categories describe unsafe conditions from which an accident may result: • Inadequate guarding; guards of inadequate height, strength, mesh, etc. • Unguarded machinery, or the absence of the required guards. • Defective, rough, sharp, slippery, decayed, cracked surfaces. • Machines/tools designed with insufficient attention to safety. • Unsafe arrangements, poor housekeeping, congestion, blocked exits. • Inadequate lighting, glare, reflection. REVISION QUESTIONS • Inadequate ventilation, contaminated air. • Unsafe clothing - no goggles, gloves or mask. • Unsafe processes - mechanical, chemical, electrical, nuclear. • Hot, humid or noisy environment. 1. Outline the five factors in Heinrich’s accident sequence. 2. How does Bird and Loftus’ theory of accident causation differ from Heinrich’s? 3. According to Reason, what in an organisation are “latent failures”? 4. What important principle of accident causation theory do accident ratio studies illustrate? (Suggested Answers are at the end.) © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-9 Quantitative Analysis of Accident and Ill-Health Data KEY INFORMATION • The amount of injury and ill health in a population may be described by calculating the accident/incident frequency rate, the accident incidence rate, the accident severity rate or the ill-health prevalence rate. • Bar charts, pie charts and line diagrams can be used to represent incident data in a graphical format. • Statistical variation within a population may be described using a normal distribution. CALCULATING LOSS RATES FROM RAW DATA GLOSSARY INCIDENCE Incidence reflects the number of new cases of a particular event in a population over a given time (e.g. a year) and is often used to describe accidents as each accident is a “new” event. TOPIC FOCUS In making comparisons between various industries, or between work areas in the same factory, it is useful to consider the commonly used injury ratios. Accident Frequency Rate This can be calculated from: Number of work-related injuries × 100,000 Total number of man-hours worked PREVALENCE Prevalence is the total number of cases in a particular population as a proportion of the total population. It is often used to represent ill-health statistics and reflects not only new cases but also those who continue to suffer. It is a measure of the number of accidents per 100,000 hours worked. Accident Incidence Rate This is calculated from: Number of work-related injuries × 1,000 Average number of persons employed It is a measure of the number of injuries per 1,000 employees measured over a defined period, e.g. a year. Accident Severity Rate This is: Total number of days lost × 1,000 Total number of man-hours worked It is a measure of the average number of days lost per 1,000 hours worked and gives the average number of days lost per accident. Ill-Health Prevalence Rate ‘Prevalence’ is a term often used to describe ill health in terms of the proportion of persons who have the prescribed ill-health condition at a particular time. The rate is calculated as: The total number of cases of ill health in the population × 100 The number of persons at risk The calculation gives the percentage of the population with the disease. 2-10 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Quantitative Analysis of Accident and Ill-Health Data STATISTICAL AND EPIDEMIOLOGICAL ANALYSES IN THE IDENTIFICATION OF PATTERNS AND TRENDS Epidemiological analysis may identify a pattern in data distribution, but it does not in itself give information on why the pattern is occurring. The pattern must then be analysed to determine whether causal factors can be identified and remedial action taken. Epidemiology is used to identify problems which would not be apparent from single incidents, e.g. to establish whether a number of individual cases of food poisoning are linked, and therefore, may constitute an outbreak. It is only possible to carry out an epidemiological analysis when the same type of information is available for all of the accidents being analysed. Typical data dimensions include location of accident, time of accident or nature of injury, etc. Single dimension analysis looks at just one dimension, e.g. location of accident/incident. The analysis would involve looking for deviations from what would be reasonably expected. For example, if work was spread evenly over a number of sites (with all sites being of comparable size and carrying out similar jobs) then you would expect that the numbers of accidents at each site would be evenly spread. Peaks and troughs should be investigated. Statistics is concerned with systematically collecting, organising and interpreting numerical data. Epidemiology looks at occurrences of disease in different groups of people and tries to identify a cause and prevention/ control strategy. The size of groups looked at can be quite small, e.g. comparing the incidence of a disease between two factories, or very large, in which comparisons are made between the populations of different countries. Epidemiology is so-called because it was initially concerned with the study of epidemics (a widespread outbreak of an infectious disease). Both types of analysis are useful in identifying patterns and trends and giving an insight into any necessary remedial action that may be required to overcome a particular problem. Accident and incident data can be used to measure whether performance is improving or deteriorating and to compare data over time, e.g. this year's figures with last year's. This trend analysis, however, can be affected by a number of factors other than whether the safety management systems in place are effective. For example, an increase in the amount of work carried out by an organisation may lead to more accidents, but this does not necessarily mean that the safety performance has deteriorated. In the same way, a reduction in work may lead to a reduction in accidents whether or not there are any changes to the safety management practices. You can see that the different types of analysis may identify different patterns or trends which are useful in identifying what is happening within an organisation, and can help to identify what actions must be taken to improve safety performance. PRESENTING AND INTERPRETING LOSS EVENT DATA We will consider some typical ways in which data can be presented in this section. Histograms 'Histogram' is the name given to a particular type of bar chart. It is the diagram used to illustrate a frequency distribution and it always has the following features: • All the columns touch each other. • Both axes have scales: –– The horizontal axis carries the variable under consideration. –– The vertical axis shows the frequency with which the values of the variable occur. • The bars are all the same width but the values of the variable need not begin at zero, i.e. the first column of the histogram need not touch the frequency axis. The simplest method of trend analysis is to plot on a graph the number of accidents or incidents against time. The measure of time used, e.g. monthly, quarterly, annually, should be considered, as different time periods may show the trend better than others. It is also possible to include a measure of severity, e.g. by plotting the number of days lost through sickness, or the costs of damage/repair. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-11 Quantitative Analysis of Accident and Ill-Health Data Example 1 The following table shows the simple frequency distribution of the number of days' absence caused by 60 lost-time accidents. (Columns 1 and 2 form the frequency distribution, columns 3 and 4 are calculated as shown from the frequency distribution.) The histogram (the next figure) is based on this table. Days lost per accident Days lost per Accident x No. of Accidents Causing Lost-Time f Man-Days Lost fx Cumulative Frequency fcum 0 3 0 3 1 5 5 8 2 7 14 15 3 12 36 27 4 9 36 36 5 8 40 44 6 6 36 50 7 5 35 55 8 1 8 56 9 3 27 59 10 1 10 60 Totals 60 247 - Lost-time accidents causing specified no. of days’ absence (Note: The “mode” is the most popular frequency, i.e. 3 days.) 2-12 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Quantitative Analysis of Accident and Ill-Health Data Example 2 When the variable can take a very large number of values, it is not practicable to construct either a frequency distribution or a histogram by the method given in Example 1; so we divide the values of x into a number of equal-sized groups and treat each group as a single unit. Such a distribution is known as a grouped frequency distribution. (If any calculations need to be carried out, the groups are represented by the value of x at the midpoint of each as a typical value.) The following table shows the number of employees in the given age groups in an organisation that employs 300 people. The next figure is the histogram based on this table. Number of Employees in Specified Age Groups Age Groups No. of Employees f Cumulative Frequency fcum Mid-Points x 16-20 40 40 18 21-25 45 85 23 26-30 55 140 28 31-35 40 180 33 36-40 35 215 38 41-45 30 245 43 46-50 20 265 48 51-55 15 280 53 56-60 12 292 58 61-65 8 300 63 Totals 300 - - © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-13 Quantitative Analysis of Accident and Ill-Health Data Number of employees in specified age groups Pie Charts Line Graphs These are circular diagrams, where the pie is divided into ‘slices’ representing the fractions into which the total of the variable is divided. To construct the diagram, the quantities must be converted into fractions of 360°. (The fraction is often expressed as a percentage.) The following figure is an example. Rather than using a bar chart or histogram the information can be displayed as a series of data points connected by straight lines. The example below shows the number of accidents occurring in a year. Number of accidents occurring in a year Proportion of lost-time accidents for each department 2-14 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Quantitative Analysis of Accident and Ill-Health Data PRINCIPLES OF STATISTICAL VARIABILITY, VALIDITY AND THE USE OF DISTRIBUTIONS Statistical variability refers to the spread or distribution of a particular variable. Examples include: • Height or weight of adults. • Intelligence of people. • Lifespan of a dog. • Political views expressed before an election. • Attitudes to safety in a workforce. All of these display significant variance. For example, in a given population relatively few people are extremely short or extremely tall, whereas many are “in between” these two extremes and are of “average” height. What would we do if we wanted to answer the question: “What is the height of an adult human being (from the UK)?” If we measured the height of one person chosen at random, then whoever we chose could not possibly give an indication of the variation in height displayed by adult human beings in a population of many millions. To get over this problem we must collect a sample of sufficient size so that we can say that it is likely to be representative of the whole population. This means that the characteristics of the sample are more likely to reflect the characteristics of the whole population under study. In our example in which we are trying to determine the height of adult human beings, the sample should contain some short people, some tall people, approximately equal numbers of men and women, representatives of ethnic minorities, etc. If we make sure the sample is representative, there is a good chance it will provide an accurate indication of the average height of an adult human. The normal distribution is actually a family of symmetrical distributions that have the same general shape (often described as bell shaped or Gaussian). This type of distribution tends to predominate in the ‘natural’ world, e.g. the heights, weights, or intelligence of a sample of adults, the weights of a harvest of plums from a tree, the expected life of a batch of light bulbs, etc. You can see the shape of a typical, normal distribution curve in the following figure. Example of normal ‘bell-shaped’ curve The curve is symmetrical about the average value (or mean); the mean value coincides with the most common (or modal) value at the central hump and the distribution tails off either side of the hump. This is the general shape you would expect to get if you plotted the numbers of people with a particular height (provided you had a large enough sample size). You would expect a symmetrical bell-shaped distribution about the average height of that sample of people. The height of a normal distribution can be specified mathematically in terms of two parameters: • The mean (µ) - where the curve is centred. • The standard deviation (σ) - related to the spread/ girth of the bell-shape. In general, a normal distribution (N) would usually be stated in the following shorthand format (the full equation is actually rather complicated): N (µ, σ 2) σ 2, the square of the standard deviation, is known as the variance. Normal distributions all share certain properties: • Continuous data (i.e. data which can take any value not just integer (whole number) values). • About 68% of the data values fall within 1σ of the mean (i.e. 1 σ each side of the mean). • About 95% of the data values fall within 2σ of the mean. • About 99.7% of the values fall within 3 σ of the mean. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-15 Quantitative Analysis of Accident and Ill-Health Data So, if you have the mean and standard deviation for your data, and your data can be modelled by a normal distribution, you can make predictions about it (using standardised normal tables). These predictions may concern the proportion of the population falling within a particular range of values or the probability of a randomly chosen item falling within a particular range. This is widely used in ergonomics (discussed later in Element A7), where much anthropometric data is assumed to approximate to a normal distribution – and data gaps are filled on this basis. An example of its use might be designing some protective equipment which might fit, say, 95% of the adult population. Use of this distribution would give you guidance on the range of fit that you would have to accommodate. This is provided, of course, the data approximates to a normal distribution. You do, however, have to be cautious when interpreting statistical data. For example, before elections polling companies try to predict the outcome of the poll. It is not practical to ask everybody who is eligible to vote, so they have to identify a much smaller sample that is chosen at random, to ensure it is characteristic of the whole population eligible to vote. If the sample is suitably representative, then this should give a good indication as to the outcome of the election. However, it is never possible to say with certainty whether or not the sample is perfectly representative of the population, so there is the opportunity for error. One cause of such error is the sample being too small and not accurately representing the range of features of the much larger population. The larger the sample the better! Two health and safety examples where the use of representative samples would be beneficial are: • To design a chair ergonomically suitable for workers on a production line we would need to have data relating to the physical features of workers, such as height, weight, length of leg, etc. so that the chair would be suitable for the majority of persons we might wish to employ and would not unfairly discriminate against those who do not have average characteristics. • Organisations may wish to measure the safety climate, a feature which reflects the safety culture. If it was not possible to survey everybody then we could get a good indication by identifying and surveying a representative sample of the workforce. REVISION QUESTION 5. In a factory with 20 employees there were eight work-related injuries recorded over a period of a year. In a year, employees work for 38 hours a week for a total of 47 weeks. Calculate the accident frequency rate. (Suggested Answer is at the end.) 2-16 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses KEY INFORMATION • Requirements for reporting and recording certain loss events are set out in the ILO Occupational Safety and Health Convention (C155) and the accompanying Protocol (P155). Employers should: –– Record and notify occupational accidents, suspected cases of occupational disease, dangerous occurrences and commuting accidents. –– Inform employees about the recording system and notifications. –– Maintain records and use them to help prevent recurrence. • Every organisation should maintain records of all significant incidents and have appropriate internal reporting procedures. The Protocol (P155) to the Convention (which must be ratified separately) is specifically aimed at reporting requirements. We will look at this and the accompanying ILO Code of Practice (Recording and Notification of Occupational Accidents and Diseases 1996) in what follows. P155 defines a number of accident terms: REPORTING REQUIREMENTS AND PROCEDURES Article 11(c) of the Occupational Safety and Health Convention (C155) says: “To give effect to the policy referred to in Article 4 of this Convention, the competent authority or authorities shall ensure that the following functions are progressively carried out:… (c) the establishment and application of procedures for the notification of occupational accidents and diseases, by employers and, when appropriate, insurance institutions and others directly concerned, and the production of annual statistics on occupational accidents and diseases;” “(a) the term ‘occupational accident’ covers an occurrence arising out of, or in the course of, work which results in fatal or non-fatal injury; (b) the term ‘occupational disease’ covers any disease contracted as a result of an exposure to risk factors arising from work activity; (c) the term ‘dangerous occurrence’ covers a readily identifiable event as defined under national laws and regulations, with potential to cause an injury or disease to persons at work or to the public; (d) the term ‘commuting accident’ covers an accident resulting in death or personal injury occurring on the direct way between the place of work and: (i) the worker’s principal or secondary residence; or (ii) the place where the worker usually takes a meal; or (iii) the place where the worker usually receives his or her remuneration.” Copyright © International Labour Organisation 2002 Copyright © International Labour Organisation 1981 © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-17 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses The basic requirements of P155 are that national governments should ensure that employers: • Record and notify occupational accidents, suspected cases of occupational disease, dangerous occurrences and commuting accidents. The minimum notification data should comprise: –– Enterprise, establishment, employer. –– Person injured and nature of injury/disease. –– Workplace, circumstances (accident/dangerous occurrence/disease). • Inform employees about the recording system and notifications. • Maintain records and use them to help prevent recurrence. Notifiable diseases should at least include the prescribed diseases listed under ILO Convention C121. The schedule to C121 contains a list of diseases prescribed in relation to an activity, for which injury benefit should be payable. Examples include: • Conditions due to physical agents and the physical demands of work, e.g. due to ionising radiation, vibration, noise. • Infectious or parasitic diseases (in health, vet work, etc.). • Additional information: –– For accidents: –– Injury - fatal, non-fatal, nature (e.g. fracture), location (e.g. leg). –– Accident and its sequence - location of place of accident, date and time; type, e.g. fall and related agent, e.g. ladder. –– For diseases: –– Name and nature of disease and causative agent; work giving rise to exposure; duration of expo-sure (to agent/process); date of diagnosis. –– For dangerous occurrences: –– The same enterprise/establishment/employer details as before. –– Dangerous occurrence details – date, time, location, type, circumstances. UK arrangements for notifiable occupational accidents and dangerous occurrences require all work-related injuries and incidents to be reported by telephone or online reporting forms only. An example of an official data collection form used in the UK for notifiable accidents can be found at: https://extranet.hse.gov.uk/lfserver/external/F2508IE • Conditions due to substances, e.g. silicosis, asbestosis; arsenic, chromium, lead poisoning; lung cancer and mesothelioma caused by asbestos. The above examples are fairly typical of diseases which would be notifiable in many regions of the world. Below are examples of some UK government notifiable occupational accidents and dangerous occurrences: • Occupational accidents (fatal/non-fatal injuries), e.g. fatality, fracture of certain bones, amputation of certain joints, loss of sight. • Dangerous occurrences, e.g. gas incidents (such as poisonings due to incomplete combustion), crane collapse, scaffolding collapse. The ILO Code of Practice specifies a minimum recommended notification dataset: • Enterprise/establishment/employer details: –– Employer – name/address, telephone number. –– Enterprise – name/address. –– Establishment – name/address, economic activity, size (workers). • Injured/diseased person: –– Name, address, age, sex, employment status, occupation (also date of birth and length of service in cases of disease). 2-18 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses INTERNAL REPORTING AND RECORDING Use Similar information as that kept for reportable incidents should be kept for minor injuries. The safety practitioner needs to design a suitable form to ensure that he gets the information that he needs for investigations. Reporting of near misses requires some careful thought. This could involve a report by the supervisor, or some sampling and interview technique. Accident records are of no help if they are used only to count accidents. They should be used as a tool to help control the accidents that are causing the injuries and damage, and should provide the following useful information: Accident Investigation Records • The conditions, processes, machines and activities that cause the injuries/damage. Accident investigation forms are used to give management an objective tool for measuring and evaluating safety performance. • The relative importance of the various injury and damage sources. • The extent of repetition of each type of injury or accident in each operation. • Accident repeaters, i.e. those workers who tend to be repeatedly injured, or are involved in more accidents. Format The form is completed as a record of the investigation, but different work environments vary so much, that there is no such thing as a standard report form. Generally, the report form should include the following information: • Name and personal details of the person who had the accident. • Date, day and time of the accident. • Where the accident happened, i.e. department and specific location. • How to prevent similar accidents in the future. Sample Forms Here you can see four sample forms of the type you are likely to come across in your work: • Supervisor’s Report of Injury. • Incident Investigation Report. • Injury Report Form 1. • Injury Report Form 2. • Occupation of the person involved. • Job being done at the time. • Nature of the injury or damage. • What inflicted the injury or damage. • Who had control of the cause of the injury or damage. • What actually happened. • What things caused the accident, i.e. physical conditions and acts of persons. • Immediate remedial action. • Recommendations to prevent the accident in future. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-19 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses Dept: Name: Date: Name of victim Date of injury Age Time Sex Works No. Nature of injury Where and how did accident occur? Unsafe acts or conditions Witnesses Corrective/Remedial action Recommendations Supervisor’s Report of Injury 2-20 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses Employee (if involved) Works No. Department Section Incident Date Reported Date DESCRIPTION OF INCIDENT (including location, witnesses, and circumstances surrounding incident) Actual or possible causal factors Corrective/Remedial action Signature Date Supervisor's Name Signature Date Incident Investigation Report © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-21 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses VICTIM: Name Works No. Age Dept Sex Occupation when injured Was this his/her regular occupation? If not, state regular occupation How long employed? ACCIDENT: Date Time Place Description of how accident happened (include name, part, and plant number of machine or tool involved) Was part of m/c causing accident properly guarded? Type of feed Type of guard Was employee following safety rules? If not, why not? Was injury result of lack of ordinary care? If so, how? Did some other person cause the accident? If so, how? How could recurrence be prevented? INJURY: Describe injury and part of person injured Did victim resume work after medical attention? If not, was he/she sent home or to hospital? Home or hospital address (Continued) Injury Report Form 1 (page 1) 2-22 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses WITNESSES: Give name, number and department:Name Works No. Department Name of foreman/chargehand in charge of work Name of immediate supervisor ANY OTHER USEFUL INFORMATION: Further description/cause of the accident together with sketch: Completed by Position Signature Date Injury Report Form 1 (page 2) © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-23 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses Name Works No. Dept Occupation Date of injury Time Foreman/Chargehand Nature of injury Immediate cause of injury Initial treatment Name of first-aider Signature Date Is further treatment required? Yes/No Victim sent home/to hospital? Will injury cause loss of time? Yes/No NATURE OF INJURY WOUNDS: BURNS: SITE OF INJURY laceration Head contusion Face puncture Eyes foreign body Nose wet heat (scald) Teeth dry heat Chin chemical Ear friction Neck (Continued) Injury Report Form 2 (page 1) 2-24 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses NATURE OF INJURY SKIN: SITE OF INJURY dermatitis Throat irritation Shoulder rash Arm FRACTURE Elbow SPRAIN Wrist STRAIN Hand PAIN Fingers POISON Thumb OTHER (detail): Chest Ribs Back Abdomen Hip Groin Leg Thigh Knee Shin Ankle Foot Instep Toe Injury Report Form 2 (page 2) © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-25 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses Form Design Programs Available Accident forms should be designed to suit the work situation, and need to include information that is of use to the safety practitioner. Some ideas which are worth taking into account include: The programs which are of most interest are: • Requiring the reporter to state if the cause of the accident is: A database program can be used to store accident data in a set format, then retrieve and analyse it. It can search through the whole of a year’s company accident records and answer such questions as: –– Unsuitable working environment. –– Physical unsuitability. –– Lack of knowledge or skill. –– Improper attitude. • Requiring that six accident factors be stated: • Spreadsheet. • How many employees had an accident on a Friday? • How many accidents involved a broken arm? • Who had accidents involving a power press? –– The agency - the object or substance involved. –– The agency part. –– The unsafe mechanical or physical condition. –– The accident type. –– The unsafe act. –– The unsafe personal factor. • UK HSE booklets often identify causes found as a result of a detailed study. Deadly Maintenance was an investigation into maintenance accidents, and listed the causes as: Absence of a safe system of work 46% Defective or inadequate equipment 18% Human factors or errors 13% Poor design 4% Unauthorised activity 5% Management failure 6% Not known 8% Taking some of the above ideas, any accident or injury report form should at least require the person reporting an accident to say whether, in their opinion, the cause was: • An unsuitable working environment. • Lack of a safe system of work. • Unsafe or inadequate equipment. • Lack of effective instruction or supervision. • Unsafe personal factors. Computer Records Use of personal computers has revolutionised the storage and manipulation of accident data. 2-26 • Database. A spreadsheet program is rather like a large sheet of graph paper, with many rows and columns, where a number or phrase can be put into each of the spaces. Columns or rows of numbers can be added, or calculations performed, using values in the table. The program can also produce graphs and other pictorial forms of information. These programs can also be combined, with information and data being transferred from one to the other. A large company with a computer department would probably organise their own programs for accident statistics, but there are a number of commercial programs for the purpose in the UK which will accept accident records and produce the accident form F2508 for the HSE. Preparing Data Input It is only possible to retrieve and manipulate data which has been input first. Many programs will accept data directly from the keyboard. The person reporting the injury can be asked a series of questions, with the answers only involving choosing one item from a list. There are advantages in having a special form completed for the purpose. Restricted access to the computer system maintains security of records. The written record can be retained as an additional safeguard. The form must contain all the data required to prepare report forms for the regulator, and there would be certain items the employer would need, such as work area, job type, machinery used, work-in-progress, whether safety precautions were in place, whether personal protective equipment was being worn, etc. Care must be taken in the topics of “cause of injury” and “cause of accident” to avoid confusion and to get information which is useful later. A simple format requiring just a tick next to a statement is preferable. | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses REVISION QUESTIONS 6. According to Protocol P155, what should national governments ensure that employers do in relation to loss events? 7. Outline, with examples, the types of disease or ill-health conditions that should be reported. 8. What useful information can internal accident reporting and recording systems provide? (Suggested Answers are at the end.) © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-27 Loss and Near-Miss Investigation KEY INFORMATION • Useful guidance exists in the form of the UK HSE publication Investigating Accidents and Incidents (HSG245). • Loss incidents should be investigated to identify the immediate and root causes, prevent recurrence, assist in any legal proceedings, and identify any trends. • An investigation includes examining the scene, evaluating relevant documentation and interviewing witnesses. • Failure tracing methods such as fault tree and event tree analysis can be used to identify causes of accidents, particularly where there is an identifiable process. PURPOSES OF ACCIDENT INVESTIGATION Here we examine the purpose of loss events investigations and their role in prevention of recurrence and identification of trends. We also consider investigation procedures and techniques to collect relevant information and draw effective conclusions. The UK HSE have produced a useful guide entitled Investigating Accidents and Incidents (HSG245). As well as identifying reasons and benefits for investigating accidents, it also outlines a four-step investigation process: • Step 1: Gathering the information. • Step 2: Analysing the information. • Step 3: Identifying risk control measures. • Step 4: The action plan and its implementation. We will draw on this guidance in this section. 2-28 The definition of accident includes much more than just those events which cause an injury. We wish to prevent all those events and occurrences which might have caused an injury or damage, as well as those which did. Within the wider concept of risk management we are interested in the prevention of all losses. Here we will mostly be concerned with injury accidents, but the wider concepts need also to be considered. | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Loss and Near -Miss Investigation There will always be an immediate cause for an accident, but we are also interested in finding the underlying and root causes. This is why we need to consider the chain of events leading up to an accident; the domino effect of Heinrich’s theory is a good example. Obviously, any remedy which starts at the earliest stages will not only prevent this accident, but a lot of others which have the same underlying cause. Accident reports tend to concentrate on “cause of injury”, but the safety practitioner is more interested in “cause of accident”. In the case of a multiple cause accident, we need to consider at the very least if it involves an unsafe act, an unsafe condition and an unsafe person, and how these interact. Since an incident could cause a fatality, a serious injury, a minor injury, or just a near miss, all incidents should ideally be investigated. The purpose should be to find the cause, with the intention of preventing a recurrence, rather than to apportion blame. An injury usually involves some degree of blame falling on management, the supervisor, the victim and his/her workmates. There are a number of purposes we can identify for conducting an accident investigation - the main ones follow. Discovery of Underlying/Root Causes The word ‘cause’ has an air of finality about it that discourages further investigation. If a pipe fails, for example, and the cause is said to be corrosion, we tend to think that we know why it failed. This may be true, but it does not help us prevent further failures. We need to know the answers to many more questions: • Was the material of construction specified correctly? • Was the specified material actually used? • Were operating conditions the same as those assumed by the designers? • What corrosion monitoring did they ask for? • Was it carried out? • Were the results ignored? • Underlying cause: the less obvious ‘system’ or ’organisational’ reason for an adverse event happening, e.g. pre-start-up machinery checks are not carried out by supervisors; the hazard has not been adequately considered via a suitable and sufficient risk assessment; production pressures are too great, etc. • Root cause: an initiating event or failing, from which all other causes or failings spring. Root causes are generally management, planning or organisational failings. Consequently you will find that the terminology used can vary, but the most important thing to remember is to look beyond the immediate causes to the management-based failings that allowed the accident to happen. Prevention of Recurrence The purpose of the investigation and report is to establish whether a recurrence can be prevented by the introduction of safeguards, procedures, training and information, or any combination of these. Enforcement agencies look for evidence for blame. Claims specialists look for evidence of liability. Trainers look for enough material for a case study. Safety practitioners look to prevent accidents. Legal Liability There is a whole range of legal requirements aimed at persuading both employers and employees to take reasonable care of themselves and of others who may be affected by their acts or omissions. In health and safety, as in other sectors, everything is fine until something goes wrong, at which point someone usually has to be held accountable. Data Gathering We can only act on the information we are given, irrespective of our position. As a safety practitioner, the way you gather your information will no doubt suit your requirements and your organisation. It is only after all the facts have been established that we can begin to interpret the results. And so on. Identification of Trends As we have discussed earlier, when analysing accidents it is common to distinguish between immediate causes and underlying causes. The latter are also sometimes called root causes and there is some justification for a simple two stage model. However, the UK HSE publication HSG245 Investigating Accidents and Incidents does make the following distinctions: Many accidents may initially appear to be ‘one-offs’, but after looking at all the relevant information, it may appear that there is a history of similar incidents, indicating a trend. It is important to look for existing or developing trends. For example, a spate of similar minor accidents could highlight a problem in an organisation which may be procedural, practical, or human in origin. If not treated, minor accidents could become major, so the ability to spot trends is an important skill. • Immediate cause: the most obvious reason why an adverse event happens, e.g. the guard is missing; the employee slips, etc. There may be several immediate causes identified in any one adverse event. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-29 Loss and Near-Miss Investigation INVESTIGATION PROCEDURES AND METHODOLOGIES Incident Report Forms Incident report forms capture and store the data that you collect in an investigation and act as a systematic prompt for the investigation process. The amount of detail required from the investigation will depend upon the: • Severity of the outcome. • Use to be made of the investigation and the report. The report should be as short as possible, but as long as is necessary for its purpose(s). The report is not expected to allocate blame, although some discussion of this is almost inevitable. Reports are usually ‘discoverable’, which means they can be used by the parties to an action for damages or criminal charges. Whether the report is made on a standard form, or is specially written, it should contain the following information: • A summary of what happened. • An introductory summary of events before the incident in question. • Root cause/immediate causes. The minimum requirement for accident recording will be established by your local/regional laws. We have already established the minimum data set recommended by the ILO, earlier in this element. We will now look at the four-step accident investigation methodology described within the UK HSE guide Investigating Accidents and Incidents (HSG245). Step 1: Gathering of Relevant Information Promptness The best time to start an accident investigation is as soon as possible after the event. The less time between the accident and the investigation, the better and more reliable the information available will be. Facts will be easier to determine and more details will be remembered by those involved, while the conditions are more likely to be closest to those immediately before the accident. Equipment Equipment required will depend on the circumstances: • Photographic equipment – digital cameras allow rapid and easy storage and transfer of photographic evidence. • Details of witnesses. • Portable lights may be necessary if electricity is switched off, or if the accident scene is in a poorly lit area in a confined space, such as a manhole. • Information about injury, ill health or loss sustained. • Sketchpad, pencils and measuring equipment. • Conclusions. • Record-keeping equipment including a notebook and possibly a portable Dictaphone. • Information obtained during any investigation. • Recommendations. • Costings. • Support materials (photographs, diagrams to clarify). • The signature of the person or persons carrying out the investigation. • The date. Standardised report forms should be kept at each workplace and used for each investigation. They should be returned to a central point for record-keeping and analysis. It is important that supervisory staff at the workplace carry out preliminary investigations and complete a report, as they should be accountable for the work conditions and need to have personal involvement in failure (accident, damage or conditions causing ill health). This demonstrates their commitment and removes any temptation to leave ‘safety’ to others, who may be seen as more qualified. 2-30 • Sample collection equipment, such as jars or other containers that can be sealed to prevent loss, evaporation, or contamination. Paper bags, plastic bags, envelopes and cartons may also be required. • Tools for cleaning debris or spillages. • Where explosive or flammable vapours and gases may be involved, portable gas/vapour detection equipment should be available. Similarly, where poisonous or radioactive materials may be involved, the appropriate detection equipment should be provided. | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Loss and Near -Miss Investigation Inspection of the Scene Interviewing Witnesses The first priority is to help injured people. You may also need to notify and report the incident to your local regulator. For serious incidents, the site may need to be made safe, but otherwise left undisturbed as a ‘crime scene’ pending an investigation by the police or a health and safety enforcement inspector. Any investigation will involve people, and it is easy to upset them when asking questions about what has been done or what has not been done. However, casual remarks made during the site inspection may be revealing, and the investigator should continue to talk to any personnel involved near the scene of the accident. This would be an ideal opportunity to explain that the object of the exercise is not to apportion blame or to criticise any individual, but to discover the causes so as to prevent a repetition. Depending on the severity of any injuries or damage, the investigator should be present during clearing-up operations and reinstatement, or clues may be missed. Failing this, the supervisor should take it upon him or herself to collect the necessary evidence. You cannot specify a routine because there are too many possible variations and circumstances. However, whatever situation the investigator has to deal with, there are certain things he or she will need, and there is a logical method of carrying out the investigation. In the case of fire investigation, although not essential, it is helpful if the investigator can be present during the fire, or at least as soon as possible after it has occurred. The exact area where the fire started may be more obvious, although it may be obscured by smoke, and heat may prevent access to the building. The investigator may get useful information by watching the activities of the fire-fighters. He or she will also be able to photograph the course of the fire, which may subsequently prove useful. An outline of a routine of investigation applicable in most cases, which can be modified to suit a particular situation, is as follows: • Take a careful, detailed look at the scene of the accident from a distance, preferably from all sides, evaluating and noting: –– The extent and severity of the damage. –– Damage to surrounding property. –– Environmental conditions, such as temperature, ventilation, humidity and illumination. • Survey the accident site(s) to see if there are any obvious dangerous physical conditions which may have been responsible for the accident. • In the case of spillages, splashes, or other escape of poisonous, explosive, flammable, or other dangerous material, it may be necessary to take samples for subsequent laboratory investigation. • Where machinery or other equipment has been involved, it may be necessary to issue instructions prohibiting its use or repair until the investigation has been completed. © RRC International Types of Witness There are three types of witness: • The primary witness is the victim: only he/she will know exactly the events which led to the accident, and should be able to give a full account of his/her actions. • The secondary witness, extremely rare in practice, is the eyewitness. The problem is that not many people really see the instant of an accident; their observations usually begin immediately after the accident has occurred. • Tertiary witnesses are those who can offer a variety of corroborative statements regarding people’s actions, or environmental information relevant to the circumstances surrounding the accident. Putting the Witness at Ease It is important to put the person being questioned at ease, and this can be done by explaining the purpose of the investigation (to discover the causes so as to prevent a repetition). The witness will also relax if you encourage his or her participation and involvement in the exercise, by listening to any ideas he/she might have about possible preventive measures. An understanding and friendly manner is essential to obtain co-operation. Remember that the witness must be reassured that the purpose of the interview is not to blame anyone, but to try to find out the cause and so reduce the possibility of a recurrence. Interview Location Where possible, interviews should be carried out at the scene of the accident, because it is generally easier for those involved to explain themselves clearly with the ‘props’ close at hand and be able to point out specific things and recall their actions related to specific locations. Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-31 Loss and Near-Miss Investigation Question Phrasing Step 2: Analysis of Information It is a good idea to start all questions with What, Where, When, How or Who. Questions starting with Why will only put the witness on the defensive and possibly antagonise them. This involves examining all the facts, piecing them together to establish what actually happened, and determining why it happened. This is often done to some extent while you are actually collecting data. As data comes in, you may start developing a theory of what you think may have happened. This theory may lead you to different areas of investigation (requiring more data). New data may result in a refinement of your theory until your theory is realistic enough to explain all the facts of the case. In general, you would achieve this by: Typical questions might be: • What happened? What did you see? What time was it? • Where were you at the time? Where was the victim? • When did you realise something was wrong? • How did it happen? How were you involved? How could it have been prevented? • Who else was involved? Who else saw it? Who reported it? Attitude The question ‘What happened?’ often generates the best response and the investigator must listen, without interruption, to the witness’s account of the accident. The investigator can always clarify any points at the end. The investigator should be looking for the witness’s version of the accident and should not disagree with any of the statements made or make any judgments on his/her evidence alone. After all, what a witness believes to have happened will depend to some extent on just how he/she perceived the situation, even though this might conflict with the actual facts of the matter. Conclusion When the witness has given their account of the accident, the investigator should repeat it to the witness to make sure that he understands it. This also allows the witness to add any details previously omitted, or expand some points to make them clearer. When the investigator and the witness are both satisfied that a true account has been given, the interview should end on a positive note by discussing any ideas the witness has regarding prevention of a similar occurrence. This will also help to reaffirm the purpose of the interview and ensure the witness’s further co-operation, should it be needed. 2-32 • Assembling all your data or evidence. • Extracting the information that is relevant. • Identifying any gaps – and following leads to fill those gaps. • Discovering the immediate, underlying and root causes by systematically working through the event (there are systematic tools for this, but simply asking ‘Why’ repeatedly is a good, simple method). For systematic consideration of all possible causes and consequences in complex systems, you can use formal methods (e.g. fault tree and event tree analysis, ‘cause and effect’ (or ‘fishbone’) diagrams combined with ‘brainstorming’ methods). You may need a team-based approach. Note on Cause and Effect Diagrams A cause and effect diagram is an analysis tool, sometimes called a ‘fishbone’ diagram because of its basic structure. It is also known as an Ishikawa diagram, after the professor who developed the first one in the 1950s. The purpose of a cause and effect diagram is to help people think through the causes of a problem thoroughly, considering all the possible causes, rather than just the most obvious ones. It is often used in conjunction with a brainstorming session. The following shows an example of a fishbone diagram applied to the problem of forklift trucks overturning. | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Loss and Near -Miss Investigation Fishbone diagram: FLT overturn Step 3: Identify Control Measures Identify all possible control measures and then select the ones that are most suitable (taking account of reasonable practicability and the effectiveness of different control types). This may involve justifying selected controls using formal cost-benefit analysis. We look at control selection in Element IA5. Consider also the wider implications of an event. Is this an isolated event, or is the same event waiting to happen on a similar piece of equipment in other parts of the plant or elsewhere? If so, do you need similar controls there too, to prevent another occurrence? Involvement of Managers, Supervisors, Employees’ Representatives and Others in the Investigation Process Who should carry out the investigation? Among those who may make an investigation are: • The safety practitioner, or one of his staff. • A member of management. • The supervisor, foreman, or charge-hand. Managers Plan what you have decided to do and do it. This will involve setting timescales (short-term versus long-term), allocating specific actions to individuals and checking that the proposed actions have actually been implemented. You will remember that many causes of accidents are due to management systems, or rather the lack of effective systems. The objective of any analysis or investigative report is to provide management with a means of deciding why their policies and procedures failed to prevent accidents, injuries and ill health. As it is management who ultimately make the decisions and allocate resources, it is vitally important that they are actively involved at every step of the procedures. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation Step 4: Plan and Implement v2.1 | 2-33 Loss and Near-Miss Investigation Supervisors Usually it is the immediate supervisor of the injured person, or the supervisor in whose department the damaged property belonged, who is better qualified to carry out the investigation than any other member of the management team, including the safety practitioner: • He is likely to know most about the situation, so is best suited to carry out the enquiries necessary for the investigation to reach a satisfactory conclusion. • He should know his own workers better than anyone else does. • He has a personal interest in establishing the causes of the accident because accidents affect the efficiency and morale of his department. He has to explain the consequences of work stoppage and personal injury to the members of his production team. Employees’ Representatives and Others • Employees’ Representatives Employees’ representatives have the right to investigate both accident and ill-health incidents, and this is usually carried out with approval of management. • Safety Practitioner In the case of serious accidents, the immediate supervisor may not have the necessary authority to conduct the investigation, so the company safety practitioner should be in charge of the investigation, although he will find it helpful to have the assistance of the supervisory staff. It is essential that the investigator has the authority to go as far as is necessary to get to the cause of the problem. Typical Investigation Procedure COMMUNICATIONS FOCUSING ON REMEDIAL ACTIONS AND LESSONS LEARNT Having investigated the loss event and identified the immediate and root causes, and remedial action, it is important that the organisation learns from the event. Those involved in the same task or similar work associated with the loss event are likely to benefit most from the lessons learned, and this might involve changes in the system of work, further training, etc. The method of communication will depend on the size of the organisation. Larger organisations may issue safety bulletins or newsletters, or even have dedicated briefings on the incident. USE OF FAILURE TRACING METHODS AS INVESTIGATIVE TOOLS Methods of identifying potential hazards and failures, such as fault tree and event tree analysis, can also be used to identify causes of accidents, particularly where there is an identifiable process. By applying the same techniques in retrospect, following an accident, rather than at the design and commissioning stages, they can be useful tools for the accident investigator. By going through each step of the process, it is possible to ask whether situations were normal, or whether a failure, malfunction or error occurred that could have contributed to the event. Failure tracing methods, the methodology behind them, and their applications are discussed in detail in Element IA4. MORE… Investigating Accidents and Incidents - a workbook for employers, unions, safety representatives and safety professionals (HSG245) can be downloaded Details about investigation procedure: from: • Typically performed by the supervisor for the section; if it is serious, then he/she calls in specialists, such as the safety adviser or engineers. www.hse.gov.uk/pubns/hsg245.pdf • The supervisor or specialist should: –– Discuss and write a report of events from the injured person. –– Interview witnesses; check out any discrepancies. –– Make sketches and drawings; take photographs. Joint investigation by management and union safety representatives can be extremely useful. Often an inspector will accept such a joint investigation as adequate, and attend later. REVISION QUESTIONS 9. What are the purposes of accident and ill-health investigation? 10. What equipment might be required in order to carry out an accident investigation? 11. What are the four principal stages of an accident investigation? (Suggested Answers are at the end.) 2-34 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Summary SUMMARY Theories of Loss Causation In this element we have considered the various theories of accident causation, including: • The single cause domino theory, in terms of which a number of factors need to be present in sequence for the injury to occur. If one factor is removed, the accident will not happen. • Multiple causation theory, in terms of which there may be additional factors that must be present simultaneously for the accident to occur. • Reason’s model of organisational accidents which shows how latent (ongoing) failures increase the likelihood of active failures. In accident ratio studies, the accident triangle shows that there appears to be a relationship between the numbers of different types of accident, e.g. fatal, major, near miss. The underlying causes of accidents are unsafe acts and conditions: • Unsafe acts are typically either deliberate violations or unintended errors. • Unsafe conditions include those of mechanical and physical origin. Quantitative Analysis of Accident and Ill-Health Data It is useful to consider the commonly used accident and disease ratios, in order to compare injury and ill-health rates from different industries, or between work areas in the same workplace. • Both statistics and epidemiology are useful in identifying patterns and trends. • Data gathered can be presented and interpreted in various ways, including: histograms, pie charts and line graphs. When working with statistical data, care must be taken to ensure that samples are representative of the relevant population of study. Reporting and Recording of Loss Events (Injuries, Ill Health, Dangerous Occurrences) and Near Misses Requirements for reporting and recording certain loss events are set out in the ILO Occupational Safety and Health Convention (C155) and the accompanying Protocol (P155). Employers should: • Record and notify occupational accidents, suspected cases of occupational disease, dangerous occurrences and commuting accidents. • Inform employees about the recording system and notifications. • Maintain records and use them to help prevent recurrence. Internal reporting and recording systems are also essential: • Accident investigation forms are used to provide management with information for measuring and evaluating safety performance. Guidelines are given as to what information should generally be included. • Accident records should be studied and analysed to gain information that can be used to help control accidents. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-35 Summary Loss and Near-Miss Investigations Currently there is no legal requirement for employers to investigate accidents, although it is actively encouraged. In this element we considered various aspects of accident and ill-health investigations, including the purposes of investigation: • Accident investigations are aimed at discovering the immediate, underlying and root causes of an accident. • Safety practitioners are more concerned with the ‘cause of accident’ than ‘cause of injury’. • Discovery of underlying causes can help the introduction of practices that may prevent recurrence. • Trends can be identified. After an incident, the priority is to help any injured persons. The incident must be classified and the site made safe, but left undisturbed as much as possible for investigators. There should be a defined procedure for investigating accidents. The incident report form is the basic document for storing information from the investigation exercise. The four-step investigation approach of HSG245 is: • Step 1: Gathering the Information –– Promptness. –– Equipment. –– Inspection of the scene. –– Interviewing witnesses. • Step 2: Analysing the Information –– Failure tracing methods can be used as investigative tools to identify causes of accidents. • Step 3: Identifying Risk Control Measures • Step 4: The Action Plan and Its Implementation 2-36 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Exam Skills I’m sure you coped really well with the practice question at the end of Element IA1. It’s important to complete as many past exam questions as possible so that you develop a really good exam technique. Your question for Element IA2 is as follows: QUESTION Witness interviews are an important part of the information-gathering process of an accident investigation. Describe the requirements of an interview process that would help to obtain the best quality of information from witnesses. (10) APPROACHING THE QUESTION SUGGESTED ANSWER OUTLINE As before, using good exam technique you should: The following are important factors that the Examiner might expect you to consider (note that these are examples only and there may well be other points you could cover): • Read the question. • Consider the marks available. Again there are 10 marks available so you should spend around 15 minutes answering the question and provide around 12 different points of information. • Next you need to highlight the key words; with this question the key words would include – describe, information-gathering, interview process, obtain, information, witnesses. • An outline plan might include - issues around timing; environment; atmosphere; listening, etc. • Planning the interview: –– Timing of the interview - as soon as possible after the incident in order to preserve the evidence, and ensure an accurate recollection of events. However, the witness must be in a fit state to be interviewed (e.g. they may be traumatised or injured). –– Location of the interview - calm and nonthreatening (e.g. not the director’s office, or in public view in the canteen), free from disruptions, distractions, e.g. noise, and with water available. –– Introduce all the persons involved in the interview. –– Interview witnesses one at a time to prevent accounts from becoming confused or influenced by the opinions of others. –– If appropriate, offer the interviewee a witness or person to accompany them in order to put them at their ease, such as a union representative or friend. • During the interview: –– Make clear the purpose of the interview at the outset, so that the witness appreciates that the intention is to prevent recurrence, not to apportion blame. –– Provide an overview of the process that will be followed so that the witness knows what to expect. –– Develop a rapport with the witness by adopting a calm approach. Use questions which will help you understand the incident and not apportion blame. –– Keep an open mind as to the causes of the incident and do not be hindered by hindsight. –– Set the scene for the interview in order to find out what the witness actually saw/knows, not what they think they know from later discussions. For that reason it is often useful to start the interview with questions around the build up to the incident. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-37 Exam Skills –– Take notes to record the interview and clarify/ summarise throughout to check understanding. It may be possible to use recording devices such as video cameras, but these may make the witness uneasy. –– Use open questions, such as “tell me about…” or “what happened…?” rather than leading or closed questions with yes/no answers. –– When listening to an answer don’t interrupt but allow the witness to talk. Use active listening techniques to demonstrate that attention is being paid, such as clarifying a point that has been made. –– It may be beneficial to have photographs, plans, etc. for the area to hand to aid the discussion, together with resources such as flip charts for sketching/ recording. –– Use language that is easy to understand and not reliant upon technical terms or jargon. • After the interview: –– Summarise and agree the interview. –– Tell the interviewee what will happen next, e.g. when the findings will be published. This is a great question because it is not difficult to expand the bullet points, but remember that there are only 10 marks available and you have 15 minutes in which to complete your answer. In a full answer you would need to ensure that you had described the meaning of the bullet points. Unfortunately many candidates lose marks by not taking account of the action verb and providing too brief a response. 2-38 | Unit IA – Element IA2: Loss Causation and Incident Investigation © RRC International v2.1 Exam Skills POSSIBLE ANSWER BY EXAM CANDIDATE Following an accident you would need to investigate witnesses of the events to establish the facts; to do this you need to undertake an interview of the witnesses. The process should take place in a non-confrontational manner, as soon as possible after the event, to keep the facts fresh and untainted by others’ accounts/recollections. The room itself should be somewhere that is non-threatening, i.e. not the manager’s office, and should start in a relaxed manner with an introduction of why the interview is taking place and the need to establish facts to prevent re-occurrence of similar type of incidents in the future, and learn from what went wrong and why. Questions should be open, to get responses which give information to the interviewer; the interviewer should allow witnesses time to answer questions and avoid interruptions and putting words into their mouth. The interviewer should have an open mind about the incident and make sure they listen sympathetically; sometimes they may need to highlight that they aren’t the best person to interview the witness as they may be part of the causal factors of the incident. Pen, paper, plans, documents, etc. should be available to talk about/discuss at interview, as well as for the interviewer to use to capture the facts. The interviewer should clarify what they think the witness has said or meant, because things often get mistaken in the process. The language used should be appropriate to the incident; summarise the interview and let the interviewee know that they can always come back later with anything else they may remember about the incident. © RRC International Unit IA – Element IA2: Loss Causation and Incident Investigation v2.1 | 2-39 v2.1 MEASURING AND REVIEWING HEALTH AND SAFETY PERFORMANCE ELEMENT 3 LEARNING OUTCOMES On completion of this element, you should be able to demonstrate understanding of the content through the application of knowledge to familiar and unfamiliar situations and the critical analysis and evaluation of information presented in both quantitative and qualitative forms. In particular you should be able to: Explain the purpose of performance measurement in relation to health and safety objectives and arrangements. the need for, and the objectives and Explain limitations of, health and safety monitoring systems. Describe the variety of monitoring and measurement techniques. the requirements for reviewing health and Explain safety performance. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-1 Contents PURPOSE OF PERFORMANCE MEASUREMENT Assessment of the Health and Safety Objectives and Arrangements Review of Current Management Systems Revision Question 3-3 3-3 3-6 3-7 MONITORING SYSTEMS Need for Active and Reactive Measures Objectives of Monitoring Limitations of Accident and Ill-Health Data as a Performance Measure Distinctions Between, and Applicability of, Performance Measures Revision Questions 3-8 3-8 3-8 3-9 3-9 3-10 MONITORING AND MEASUREMENT TECHNIQUES Range of Measures Available to Evaluate an Organisation’s Performance Key Elements and Features of Measurement Techniques In-House and Proprietary Audit Systems Use of Computer Technology to Assist with Data Storage and Analysis and Production of Reports Comparisons of Performance Data Use of Benchmarking Revision Questions 3-11 3-11 3-12 3-13 3-13 3-15 3-15 3-16 REVIEWING HEALTH AND SAFETY PERFORMANCE Formal and Informal Reviews of Performance Review Process Revision Question 3-17 3-17 3-17 3-18 SUMMARY 3-19 EXAM SKILLS 3-21 3-2 | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Purpose of Performance Measurement KEY INFORMATION Performance measurement serves several purposes: • It is essential in order to establish whether the policy and its arrangements have been effectively implemented, including the adequacy of control measures. • It provides information for the review process, which looks at the effectiveness of the entire health and safety management system and recommends changes that lead to improvements. • It measures and rewards success. • It maintains and improves health and safety performance. Here we examine the purpose of performance measurement in health and safety, and its role in assessing the effectiveness of health and safety objectives, and the management system generally. We looked at a number of management system models in Element IA1. The UK HSE guidance documents Managing for Health and Safety, HSG65 and Plan, Do, Check, Act - An introduction to managing for health and safety, INDG275 are excellent background reading for the subject of measuring health and safety performance. You can access both these publications at www.hse.gov.uk. The first question you might ask is: Why measure health and safety performance? One obvious answer is: How else will you know how well you are doing? If you don’t measure performance, you will have no idea of how far away you are from where you want to be and whether your plans are actually working. Purposes of performance measurement include to: • Assess the effectiveness and appropriateness of health and safety objectives and arrangements in terms of: ASSESSMENT OF THE HEALTH AND SAFETY OBJECTIVES AND ARRANGEMENTS Assessing effectiveness of health and safety performance implies that we must first have both something that can be measured, and some goal or standard against which to judge that measurement. As we mentioned in Element IA1, health and safety management system models all require a policy statement. This policy statement should be spelt out in clear objectives. At the very least it should commit the organisation to compliance with legislation (such as may be implemented in accordance with the ILO Safety and Health Convention). It should also commit to continual improvement. We need to set objectives in terms of things that can be measured. A common statement is, “If it cannot be measured, there is very little chance that it will be done”, so we need to state objectively what we mean. TOPIC FOCUS –– Hardware (plant, premises, substances). –– Software (people, procedures, systems). • Measure and reward success (not to penalise failure). A useful acronym to remember when setting objectives is SMART. Good objectives need to be: • Use the results as a basis for making recommendations for a review of current management systems. • Measurable - so you know if they have been met. • Maintain and improve health and safety performance. • Specific - as to what you want to achieve. • Achievable - attainable. • Realistic - realistically achievable with the resources you have. • Timely - set a reasonable timescale to achieve them. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-3 Purpose of Performance Measurement In many regions of the world there are legal standards for chemical contaminants and dust levels, and for noise. The exposure to some chemicals must be kept as low as possible, and must not exceed a certain level. The safety objective could be set lower than this standard. We then have an objective to aim for. If we achieve this consistently, an even lower standard can be set. In this way, we comply with the requirement to reduce the level to as low as possible. Similarly, equipment will need to be tested periodically. For each piece of equipment, the type of test, the frequency of testing, and the standard can be laid down. It is possible to create standards with regard to training. Good practice dictates that certain jobs should only be performed by qualified or experienced workers. Refresher training and perhaps even re-testing can be used to make sure that practical skills are maintained. For example, firstaid qualifications must typically be renewed at specified maximum intervals, e.g. every three years or so. Measuring Performance Against Objectives When setting objectives, we have to consider performance standards and indicators. It is easy to set and measure production standards and there are also standards that can be set for safety and health. Safety sampling and similar techniques can be used. The UK’s HSE document HSG65 (see earlier) suggests the use of two measuring systems with the main purpose of measuring and rewarding success, not penalising failure: • Active systems, which monitor the achievement of objectives and the extent of compliance with standards. Examples would be monitoring the safety of plant and equipment; compliance with safe systems of work; safe behaviour by employees. • Reactive systems, which monitor accidents, ill health, incidents and other evidence of deficient health and safety performance, such as hazard reports. Investigations into accidents should determine underlying causes; weaknesses; any need for training; and changes or replacement required in machinery, substances or working methods. Periodically, there will be a review procedure and those who are filling a post but not performing a role may need to be replaced. The safety committee (if you have one) should consist of active members. If something needs to be done, then it should be made the clear responsibility of an individual. There is then a standard against which to measure performance, so the committee is more than just a ‘talking shop’. The term “arrangements” can also mean everything that is stated in this section of the employer’s safety policy. The arrangements section usually includes such topics as: • Accident reporting. • Fire precautions. • Training. • Contractors and visitor arrangements. • Dealing with any hazards in the operation (i.e. control measures). Safe methods of work and permit-to-work schemes would also be detailed. All these arrangements need to be assessed to make sure that they are (and continue to be) effective and appropriate and working as intended. Control Measures An assessment of the effectiveness and the appropriateness of the control measures of a company is another important area of performance measurement, although this may not be so easy to measure accurately. Someone has to be in control of the organisation, but this control also has to be delegated. Since one person is usually not able to complete the whole task of achieving the safety objectives, it will have to be divided up and some degree of control exercised. • The formal control system can be either authoritarian or consultative. To be effective, each person needs to know those areas where he must conform to a predetermined plan and those areas where he can exercise some discretion. • There will also be an informal control system, where working groups establish and enforce the group norms. The ideal situation is where the individual and group targets coincide with the organisational targets. Arrangements for Actioning Objectives Performance measurement involves an assessment of the effectiveness and appropriateness of these organisational matters. If they do not work, they need to be made to work. If each person in the safety organisation has a job specification and a list of tasks and duties, and there are expectations of achievement, then it is possible to measure how effectively these people have performed. What is needed is some form of ‘measurement by objectives’. 3-4 | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Purpose of Performance Measurement Measurement of the degree of control is probably best achieved by systematic reviews. • A supervisor would carry out some form of daily assessment. • The sectional manager would need to hold a monthly review. • A quarterly review might be appropriate for a department. • An annual review would be appropriate for the total organisation. Control will involve a review of performance, and the setting of modified objectives for the next period of time. It is also the time to consider possible conflict situations and how these might be resolved, and any communication problems. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-5 Purpose of Performance Measurement REVIEW OF CURRENT MANAGEMENT SYSTEMS The HSE publication, Managing for Health and Safety, HSG65, is just one example of a safety management system. It details the methods of safety management which should be adopted, and contains a useful diagram which sets out the principles involved. The plan, do, check, act cycle based on the approach in HSG65 We are concerned here with the elements of measuring and reviewing performance, key elements in any system of management. To manage anything, including health and safety, we must have objectives or a policy which sets out what we hope to achieve. We then construct a suitable organisation and put the plan into effect. 3-6 After a suitable time interval we have to review performance; either we have achieved what we set out to do, or we have failed. If we have achieved our objectives, we can congratulate ourselves and set more difficult objectives for next year. If we have failed we must find out why. | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Purpose of Performance Measurement • Were the objectives impracticable? • Were resources not available? • Was the safety practitioner incompetent? • Should he or she be replaced? • Should we increase the safety budget? Every element of the management system can be audited or examined in detail. We require a system which is continually being improved. A management system for health and safety should be in existence. The one suggested in HSG65 is based on the Plan, Do, Check, Act cycle, so production managers should be used to operating along similar lines. The safety practitioner needs to be in a position to recommend that safety matters and risk management principles are incorporated into the company management systems. The idea that good management involves accident prevention and loss prevention is a very sound one. This might involve adding safety and health objectives to a list of production objectives for each manager. The integration of production and safety makes for a profitable and cost-effective organisation. You should be aware of the cost of accidents. If accident costs and other losses are deducted from any bonuses paid, or credited to production managers, then the safety message is established and the safety culture of the organisation is assured. REVISION QUESTION 1. List three purposes for performance measurement. (Suggested Answer is at the end.) © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-7 Monitoring Systems KEY INFORMATION • Monitoring requires a combination of both active and reactive measures to assess whether the health and safety objectives have been met. • Active measures check that health and safety plans have been implemented and monitor the extent of compliance with defined systems, procedures, legislation and standards, e.g. routine inspections. • Reactive measures analyse data relating to accidents, ill health and other loss causing events. • Accident and ill-health data may not be wholly reliable: –– Some incidents may not be reported. –– Infrequent events may not reflect the effectiveness of current arrangements. • Data may be qualitative (described by words), quantitative (described by objective numbers), subjective (based on personal opinion) or objective (unbiased and factual). NEED FOR ACTIVE AND REACTIVE MEASURES No single measure, by itself, will effectively measure the performance of the organisation. While we will be favouring the use of active monitoring, there is still a role for the reactive monitoring of accident and ill-health data; active means ‘before it happens’, while reactive means ‘after it has happened’. The essential element is to find some factor that can be measured and will relate directly to a specific objective in the safety policy, arrangements or control. OBJECTIVES OF MONITORING TOPIC FOCUS Objectives of Active Monitoring The objective of active monitoring is to check that the health and safety plans have been implemented and to monitor the extent of compliance with: • The organisation’s systems and procedures (check that practice reflects the written procedures). • Legislation and technical standards. By identifying non-compliances, steps can be taken to ensure that any weaknesses are dealt with, so maintaining the adequacy of the health and safety plans, and helping to avoid any incidents. Objectives of Reactive Monitoring The objective is to analyse data relating to: • Accidents. • Ill-health situations. • Other loss-causing events. • Any other factors which degrade the system. It is better to identify, and deal with, any potential problems by means of active monitoring, rather than waiting for an event to happen to highlight any shortcomings in the systems. 3-8 | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Monitoring Systems LIMITATIONS OF ACCIDENT AND ILL-HEALTH DATA AS A PERFORMANCE MEASURE Accidents in individual workplaces should be rare occurrences, and there should not be many cases of illness and disease caused by the work environment. This means that there are not many cases to count, and the numbers may not be regarded as statistically significant. Variations from year to year might be due to pure chance rather than any accident reduction measures that have been introduced. This is why we often resort to national statistics, or even international data, in order to find significant numbers to target safety programmes. If we keep data for many years, it is possible to iron out these fluctuations by finding the moving average. As we get another year’s, or month’s, figures we are able to enter this into the average and so identify a trend. Accident statistics tend to reflect the results of actions which were taken some time ago, so there is not a rapid cause and effect situation. It is also unfair to blame a manager for accident situations when the present situation is to some extent dependent on actions taken a while ago, and the present actions will take some time to show. Cases of occupational disease are, by their very nature, long-term effects. Accident data is relatively easy to collect. Serious injuries are quite difficult to hide. There are a number of standard calculations of accident rate which are fairly easy to understand. Management can easily link accidents with safety performance, so it should not be difficult to discuss accident reports, and get management to take action. Accident recording therefore has some value, but it is of limited use in relation to assessing future risk. There are problems with under-reporting of minor accidents. Time off work does not correlate well with the severity of an injury, because some people will work with a broken arm, while others take a week off with a cut finger. Also, if workers are made aware of safety matters, they tend to report more accidents. The picture may then look worse, when actually the safety culture is improving. DISTINCTIONS BETWEEN, AND APPLICABILITY OF, PERFORMANCE MEASURES Active/Reactive Active means ‘before it happens’, while reactive means ‘after it has happened’. Measuring safety performance by looking for things before they happen can never be easy, but this is what the law requires. We carry out risk assessments to decide what might happen and then take action. We can certainly measure whether we have taken action in those areas where the risk assessment suggests that we do. If an accident occurs then we can no longer suggest that this is improbable; it needs to be included in the risk assessments. Objective/Subjective • Objective means that it is detached from personal judgment. For example, an audit question such as: “How many enforcement notices have been issued to your company in the last 12-month period?” does not depend on the personal judgment of the auditor. However, a poorly phrased objective measure can distort your view by not taking account of the context and all the circumstances of the case. Objective measures are always desirable, but are not always possible; some things, or facets, resist objective measurement. • Subjective means that it depends on someone’s opinion, judgment, bias, or discretion. As a result, the person carrying out the measurement will influence the measurement result. Questions like: “Is housekeeping adequate?” with no defined standard of adequacy might get different results from different auditors. An example of a relatively, though not totally, objective audit system relating to contractors was described a few years ago - the principles are still relevant. The system involved a statement, the contractor’s response, the audit comment, and a score. The form used was something like the one in the next table. The scores are: 0. Totally unsatisfactory. 1. Very little action - unsatisfactory. 2. Some reasonable action - but could be better. 3. As required. Other scoring systems could be used. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-9 Monitoring Systems Example of Objective Safety Scores Item Statement or Question Contractor’s Response Audit Comment Mark 12 Workforce to be trained in use of fire-fighting equipment. Agreed Less than expected 2 13 Safety helmets to be worn at all times when on site. Agreed if provided by owner Satisfactory 3 14 Contractors to wear distinctive clothing. Agreed Not worn in hot weather 1 15 All waste to be cleared up daily. Agreed if skip provided Usually satisfactory 2 16 All electrical equipment to be subject to routine inspection as laid down in owner’s scheme. Agreed inspection schedule to be made Not satisfactory, no list available 0 17 All dump truck drivers to complete Agreed owner and a course of training. contractor to share cost Satisfactory 3 18 All lighting equipment to be subject to owner’s scheme of inspection and test. Unspecified equipment found 1 19 Who decides when weather Owner’s site foreman conditions are too bad for work to continue? Only one problem in 6 months 2 Agreed Scores on safety samples are also quite objective. Qualitative/Quantitative • Qualitative means that the data is not represented numerically, e.g. reports and commentaries, which although useful are difficult to treat as an accurate measure. • Quantitative means that the data describes numbers, e.g. the number of accidents reported. In such a case we can see whether there has been an improvement or a reduction in standard. Examples of quantitative measures of safety performance would be: • Audits. • Inspections. • Safety tours. • Safety sampling. • Behavioural measures. • Safety surveys. • Benchmarking. REVISION QUESTIONS 2. Give one example each of an active measure, reactive measure, objective measure and subjective measure of health and safety performance. 3. What are the limitations of accident and illhealth data as a performance measure? (Suggested Answers are at the end.) 3-10 | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Monitoring and Measurement Techniques KEY INFORMATION • Measurement techniques include inspections, audits, safety tours, safety sampling and surveys. • Audits are an independent assessment of the management system and may be undertaken internally or externally (often by consultants). • Benchmarking enables an organisation’s practice to be compared with other comparable organisations that display excellence. RANGE OF MEASURES AVAILABLE TO EVALUATE AN ORGANISATION’S PERFORMANCE ACTIVE MONITORING TECHNIQUES Selecting the appropriate outcome indicator depends on the chosen objectives, but the following is a range of active and reactive outcome indicators relevant to a range of objectives. Active Monitoring Data There is a wide range of data that can be collated to assess health and safety performance, some of which are active – such as the uptake rate for toolbox talks, or the completion of risk assessments against the target. TOPIC FOCUS Health and Safety Audits The health and safety audit should be an in-depth, systematic, critical investigation into all aspects of safety. It needs to include management systems, policy, attitudes, training and practice. Workplace Inspections These data cover the extent to which plans and objectives have been set and achieved, and include: A workplace inspection involves a competent person walking round a part of the premises, looking for hazards or non-compliance with legislation, rules or safe practice, and taking notes. The task is made easier and more methodical if a checklist is used. • Perceptions of management commitment. Safety Tours • Specialist staff. A safety tour follows a predetermined route through the area or workshop and can be conducted by a range of personnel from works managers to supervisors and safety representatives. Such tours typically last only 15 minutes or so and may be carried out at weekly intervals to ensure that standards of housekeeping are acceptable, gangways and fire exits are unobstructed, and hazards are dealt with quickly. • Risk assessments. • Safety policy. • Extent of compliance. • Training. • Health and safety committee meetings. Reactive Monitoring Data Safety Sampling Other data are reactive, and are typically based on accidents and incidents that have occurred. They include: • Near misses. This is an organised system of regular random sampling. Its purpose is to obtain a measure of safety attitudes and possible sources of accidents, by the systematic recording of hazard situations observed during inspections made along predetermined routes in a factory or on a site. • Damage-only accidents. Safety Surveys • Reportable dangerous occurrences. A safety survey is a detailed examination of a particular safety aspect. It could involve, for example, a detailed inspection of all aspects of fire-fighting equipment; examining all the safety devices on machines; or checking all the emergency exits. • Health surveillance reports. • Cases of occupational diseases. • Lost-time accidents. • Three-day, lost-time accidents. • Reportable major injuries. • Fatalities. • Sickness absences. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-11 Monitoring and Measurement Techniques KEY ELEMENTS AND FEATURES OF MEASUREMENT TECHNIQUES Workplace Inspections/Safety Tours/ Safety Sampling Health and Safety Audits The advantage of workplace inspections is that the inspection can be far more frequent than an audit. To be an effective measure, the workers as well as management need to be involved, as this gives them ‘ownership’ of the safety process. Management is able to demonstrate commitment to safety and it is possible to get a clear picture of problem areas and to take quick and effective action. A scoring system is required if comparisons over time, or with other sections, are to be made. Such an inspection usually goes under the name of safety sampling if it concentrates on a few specific points. A safety tour follows a set route. Health and safety audits are ideally done by an external organisation, or a special unit from head office in the case of multi-site operations. The purpose is to assess the extent to which the elements of the system are still effective, and whether any action is necessary to avoid accidents and other losses. To be used as a measure, standards need to be set in the key areas. A scoring system can be introduced if the intention is to hold managers responsible for standards in their area of influence. There are some points against the use of audits: • Audits are time-consuming and costly. • It is not feasible to carry out a full audit more than once a year. • There are likely to be a lot of things to correct, and some of these may take time to complete. • If there is a long time between the recommendation being made, and the solution being put into effect, the value of the audit is reduced. There are a number of proprietary audit systems which are available, sometimes referred to as the International Safety Rating System (ISRS). Often these are computerbased and require answers to set questions. If there are to be comparisons between departments then there will need to be some uniformity. The scoring system should give weighting to significant safety performance. Human factors and attitudes need to be a major element of the audit, but these are not so easy to measure or score. 3-12 Points to watch are that if the inspections or sampling are too frequent, it is possible that an action point required by the previous inspection will not have been corrected when the next inspection takes place. Any scoring system used to compare sections must be shown to be fair and impartial. You will be aware that some inspectors are lenient, and others are very strict; some inspectors just have to find something wrong. The training and experience of the inspectors is important. Often inspections find minor matters that are not really likely to cause accidents and fail to find larger potential hazards. Safety Surveys Safety surveys make sure that aspects of safety are not overlooked in the general run of inspections. A safety survey generally results in a formal report and an action plan to deal with any findings. | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Monitoring and Measurement Techniques IN-HOUSE AND PROPRIETARY AUDIT SYSTEMS The following is one of several methods that can be used: An important feature of the monitor and review process is that of the safety audit. The audit should suit the industry and the work situation involved, but be independent of the normal workforce. It must be cost-effective, help to avoid future problems and lead to real improvements. There are quite a number of proprietary audit systems available, either form-based or computer-based. Types of Safety Audit The term ‘safety audit’ is used in several different ways. It can be: • Nothing more than an inspection, safety sampling, or a safety survey - it is best not to use the term ‘audit’ for this situation. • A detailed internal investigation of the safety systems and practices of the organisation - such an audit would probably be carried out every year by a team consisting of the safety practitioner and production managers. They would use a specially prepared checklist covering areas such as: commitment, communications, safety training, access, machinery, electrics, lifting equipment, mobile equipment, materials handling and storage, fire prevention, housekeeping, PPE, etc. A report will be prepared for management and action will be required. • An external safety audit, carried out by an outside organisation. Its basic objective is to examine all aspects of the company which relate to safety and health to see if statutory requirements are being complied with. Since audit includes the competence of the safety specialist and the management, it cannot be carried out by people closely associated with the subject of the audit. It is similar to a financial audit, which checks on the ability and the integrity of finance personnel. The external safety audit is a critical examination of an industrial operation in its entirety to identify potential hazards and levels of risk. Its aims are to: • Ensure the company is complying with the relevant legislation. • A representative of the organisation carrying out the audit meets the client company’s management to define the exact terms of reference. • An audit team is formed under the leadership of a coordinator. • The audit is divided into a number of basic headings in accordance with the terms of reference. The headings are allocated among the team. Examples include: company information, personnel, premises, organisation, training, technical expertise, incident history, documentation, etc. • The team visits the company and acquires information under the headings by means of observation, discussion with management and analysis of records usually using prepared checklists and flowcharts. • The information is collated and a report is presented to the company’s management. Developments in technology, public attitude and legislation are likely to increase demand for audits; they could become as common as the financial audit is in accountancy. USE OF COMPUTER TECHNOLOGY TO ASSIST WITH DATA STORAGE AND ANALYSIS AND PRODUCTION OF REPORTS Availability and Types of Software Computer programs for data storage or analysis will be based on either a database or a spreadsheet format. There are likely to be quite a number of related programs which are called in to perform tasks. The spreadsheet can be likened to a very large sheet of graph paper or a very large table that can be filled with data. Words or numbers or a mathematical formula can be entered into each square. Columns and rows can be added, and quite complicated calculations performed between values in the various squares. This type of program can also produce graphs and other visual presentations of the data. • Make certain the methods of risk control are both effective and economically sound. Audits are generally undertaken by multidisciplinary teams. Individual members should have a good knowledge of legal requirements, an understanding of reasonable practice in the industry and the ability to communicate with all levels of personnel within the organisation. In many companies the expertise is not readily available and so audits tend to be undertaken by external specialists, such as consulting engineers acting independently or employed by insurance companies. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-13 Monitoring and Measurement Techniques In-House or Proprietary? Often a decision has to be made as to whether such a program is produced in-house, or purchased from a supplier. Many organisations can produce their own programs that do exactly the job required. Before purchasing a proprietary audit system, it is as well to decide a number of factors: • What do you want it to produce? • Where is the data? Is it to use data on name, address, etc. from another source, or do you duplicate this for safety purposes? • If organisational data is linked, will it be possible to access confidential information? • Is the hardware (computer items) compatible with the software (the programs)? The database program is similar and can store data in the form of numbers or phrases. It is rather like having lots of spreadsheets (or tables) which can be linked by common ‘fields’ or storage areas. A database program could store information about injuries with a separate, but linked, field for name, number, address, work area, injury, time of accident, reason for accident, time off work, etc. It is possible to search through the whole of the database looking for those records with a particular value or statement in a particular field. For example, if you wished to know how many accidents involved an injury to the hand, where protective gloves were not being worn, you would make a search in the field of “part of the body injured” and combine this with “gloves worn” in the PPE section. Many programs will help in an audit of the health and safety performance of the organisation, and will perform calculations and produce a report, with all the appropriate graphs and diagrams, ready to place on the managing director’s desk. • Is the program user-friendly? Can it be used by computer illiterates? Is it for use by one person, or on a network and available for many to use? Is the package flexible? Can we adapt it for our situation? Is it so general that we don’t need half of it, or is it lacking some things that are essential to us? Do we invalidate any guarantee if we make alterations? Can we have it on trial? Is it installed on site, serviced for initial problems and provided with a backup service arrangement? Is there some special concession if future program improvements are made? If you get satisfaction on all those points, you should get some good service from an audit software package. Production of Reports Once you have your computer program up and running you can use it to produce a number of reports, on a regular basis, to suit your company needs. The reports could look at the numbers of accidents or incidents, for example, or the results of an audit. The reports can be produced in a format to suit the reader. For example, it may be appropriate to send monthly accident statistics to local managers and some simple graphical representations of the numbers, particularly those which correspond to their area of responsibility. The Board of Directors, however, may require more in-depth information, especially if there are high-risk areas within the work situation. The audit program usually asks a series of questions and the answers are typed in, or a choice made from a list of answers. If the questions are answered honestly then the result will be a good assessment of your situation. It is important that any program is tailored to exactly fit your own situation. If your organisation has such a program then it would be useful for you to have some experience of using it. 3-14 | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Monitoring and Measurement Techniques COMPARISONS OF PERFORMANCE DATA Previous Performance It is always useful to compare present performance data with that obtained over the last few months or last year. The comparison of performance over time shows the overall trend and whether performance appears to be improving or deteriorating. However, you need to look at a reasonably long period of time as there may be seasonal fluctuations, for example, which could give a false view of performance. One way of overcoming fluctuations is to use the moving average, which shows the trend over time. Other factors could affect the data, e.g. a reduction in worker numbers may lead to a reduction in absolute accident numbers which could be misread as an improvement in safety performance. To avoid such issues it is possible to use accident rates which take into account the numbers of workers working and/or the number of man-hours worked, etc. Performance of Similar Organisations/ Industry Sectors Sometimes it is useful to compare company data against other organisations or industry sectors that carry out similar functions, or that deal with similar hazards. In this way, you can compare the performance of your company with others (benchmark) to determine the differences and similarities. Remember that you should check that the measurable parameters used are the same (it is easy to manipulate data by using different units of measurement or criteria). Once you have established that the data is comparable, it is worth trying to identify whether the trends are similar. Where there are marked differences, think about the reasons for these, e.g. geographical locations, different customer base, different shift patterns, etc. Some simple analysis may help you to understand your own data and may give you ideas as to how improvements can be made. It can be reassuring to compare data with other companies or, on the other hand, it can be alarming; whatever the outcome it is a worthwhile exercise. © RRC International National Performance Data Some performance data is produced by national enforcement agencies and also by international organisations (such as the World Health Organisation). This data can be useful in gauging where you are as a company, i.e. are you maintaining standards in line with national or international figures, or are there improvements to be made? It is easy to become complacent with respect to health and safety performance, particularly if your company appears to be continually improving. By comparing your company results to national figures, you may become motivated to further that improvement. In Element IA2 we considered how to calculate injury rates, and to analyse and interpret raw data. It is worth revising that information at this point. USE OF BENCHMARKING GLOSSARY BENCHMARKING The process of comparing your own practices and performance measures with organisations that display excellence and whom you might wish to emulate. One tool available for larger organisations (with 250+ employees) was the UK HSE Corporate Health and Safety Performance Index (CHaSPI) carried out online. HSE Research Report RR813 Review of CHaSPI concluded that many users felt that CHaSPI had limited impact due to levels of awareness and number of users. Greater future use was envisaged if the benefits of the tool were better promoted. However, CHaSPI does illustrate the principles of benchmarking. MORE… You can find more information on this benchmarking tool in RR813 Review of CHaSPI (HSE) at: www.hse.gov.uk/research/rrpdf/rr813.pdf Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-15 Monitoring and Measurement Techniques Potential Benefits of Benchmarking Benchmarking has a range of potential benefits which include: • Allowing employers to measure, compare and benchmark their health and safety performance. • Helping external stakeholders, such as insurers, investors, trade unions and regulators, to assess how well businesses are meeting their health and safety responsibilities and managing their risks. • Demonstrating the organisation’s commitment to health and safety. • Providing an indicator of performance. • Allowing better engagement with stakeholders. MORE… You can find more information on performance indicators at: Step Change in Safety: Leading performance indicators – Guidance for effective use (undated): www.stepchangeinsafety.net/knowledgecentre/ publications/publication.cfm/publicationid/26 Health and Safety Executive: Developing process safety indicators: A step-by-step guide for chemical and major hazard industries (HSG254) (Sudbury: HSE Books, 2006): www.hse.gov.uk/pubns/books/ hsg254.htm. Institution of Occupational Safety and Health (IOSH): Reporting performance - guidance on including health and safety performance in annual reports: www.iosh.co.uk/~/media/Documents/ Books%20and%20resources/Guidance%20and%20 tools/Reporting_performance.ashx REVISION QUESTIONS 4. List the main measurement techniques available for measuring health and safety performance in the workplace. 5. Explain the difference between an internal and an external audit. 6. Explain the term “benchmarking”. (Suggested Answers are at the end.) 3-16 | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Reviewing Health and Safety Performance KEY INFORMATION • The review process uses information from monitoring and audit data to make judgments regarding the effectiveness of the management system. • This can then lead to changes in the elements of the system and so continuous improvement. The review would probably cover: • Assessment of degree of compliance with set standards. • Identification of areas where improvements are required. • Assessment of specific set objectives. • Analysis of accident and incident trends. The safety committee and safety representatives, supervisors and management, would all be involved in the review process. FORMAL AND INFORMAL REVIEWS OF PERFORMANCE Review is the process of making judgments regarding the effectiveness of the occupational health and safety management system, and then making decisions to remedy any deficiencies that have been identified. It is a key element of any quality system. Review should be a continuous process and should be both formal and informal at different levels in the organisation. A formal review will be carried out periodically, e.g. annually, and may cover the whole site or organisation, whereas an informal review might be instigated by, for example, a supervisor who has identified a failure by workers to adhere to required control measures (e.g. not wearing PPE). REVIEW PROCESS Review is combined with audit procedures. The audit looks at all aspects of the system - policy, organisation, planning, implementation and systems for measuring and control. Reviewing is the process which reacts to the findings of the performance measuring process. There should be an instant review in the event of an accident which causes an injury or loss. We have to learn from mistakes and be prepared to make changes. For any system of health and safety which is vital and dynamic, there will have to be periodic reviews. In many systems it would probably involve: • Monthly review of each section. • Quarterly review of each department. • Annual review of the organisation. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-17 Reviewing Health and Safety Performance TOPIC FOCUS Inputs to a Review Process A range of information is used as the basis of the review, including: • Internal performance data, e.g. audit, accident, ill health and incident data, safety climate data. • Achievement of specific objectives. • Organisational arrangements, including any changes. • External standards and legislation. • Expectations of stakeholders. Outputs from a Review Process The review process leads to specific outputs which should lead to continuous improvement: • Specific actions and improvement plans which meet the SMART criteria. • New performance targets relating to both active and reactive measures (e.g. lost-time accidents). • Reports to stakeholders, e.g. shareholders, employee groups, regulators. REVISION QUESTION 7. Which two sources of information does the review process use? (Suggested Answer is at the end.) 3-18 | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Summary SUMMARY Purpose of Performance Measurement Performance measurement serves four purposes: • It establishes whether the policy and its arrangements have been effectively implemented, including the adequacy of control measures. • It provides information for the review process which looks at the effectiveness of the entire health and safety management system and leads to changes that lead to improvement. • It enables success to be measured and rewarded. • It maintains and improves health and safety performance. When setting objectives, we have to consider performance standards and indicators. Two measuring systems in use are: • Active systems, which monitor the achievement of objectives and the extent of compliance with standards (e.g. monitoring the safety of plant and equipment; compliance with safe systems of work; safe behaviour by employees). • Reactive systems, which monitor accidents, ill health, incidents and other evidence of deficient health and safety performance, such as hazard reports. Monitoring Systems Objectives of active monitoring are to check that the health and safety plans have been implemented and to monitor the extent of compliance with: • The organisation’s systems and procedures. • Legislation and technical standards. Objectives of reactive monitoring are to analyse data relating to: • Accidents. • Ill-health situations. • Other loss-causing events. • Any other factors which degrade the system. Accident recording has some value, but is of limited use in relation to assessing future risk. There are problems with under-reporting of minor accidents. Time off work does not correlate well with the severity of an injury. Also, if workers are made aware of safety matters, they tend to report more accidents. The picture may then look worse, when actually the safety culture is improving. Distinctions between, and applicability of, performance measures are: • Active means ‘before it happens’, while reactive means ‘after it has happened’. • Objective means that it can be accurately measured, while subjective means that it depends on someone’s opinion. • Qualitative measures are those like reports and commentaries, which although useful are difficult to treat as an accurate measure, while some kind of score is quantitative. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-19 Summary Monitoring and Measurement Techniques Measurement techniques include: • Health and safety audits. • Workplace inspections. • Safety tours. • Safety sampling. • Safety surveys. The term safety audit is used in several ways. It can be: • Nothing more than an inspection, safety sampling, or a safety survey - it is best not to use the term ‘audit’ for this situation. • A detailed internal investigation of the safety systems and practices of the organisation. • An external safety audit, carried out by an outside organisation. Reviewing Health and Safety Performance Review is combined with audit procedures. The audit looks at all aspects of the system - policy, organisation, planning, implementation and systems for measuring and control. Reviewing is the process which reacts to the findings of the performance measuring process. In many systems it would probably involve: • Monthly review of each section. • Quarterly review of each department. • Annual review of the organisation. The review would probably cover: • Assessment of degree of compliance with set standards. • Identification of areas where improvements are required. • Assessment of specific set objectives. • Analysis of accident and incident trends. The safety committee and safety representatives, supervisors and management, would all be involved in the review process. 3-20 | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Exam Skills This is another 10 mark question, but it is split into two sub-questions which have different mark allocations. This is a format which is quite common in Section A questions. QUESTION An advertising campaign was used to promote improvement in safety standards within a particular organisation. During the period of the campaign the rate of reported accidents significantly increased, and the campaign was deemed to be a failure. (a) Suggest, with reasons, why the rate of reported accidents may have been a poor measure of the campaign’s effectiveness. (b) Describe four active measures which might have been used to measure the organisation’s health and safety performance. (2) (8) APPROACHING THE QUESTION SUGGESTED ANSWER OUTLINE Remember to: In part (a) of your answer the Examiner would expect you to give the reasons why the number of reported accidents went up. • Read the question carefully. • Consider the marks available. Here there are two parts to the question so you should allocate your time carefully – 2 to 3 minutes for part (a) and 10 to 12 minutes for part (b). • Prepare an outline plan: –– For part (a) it might include: –– Why? Elaborate on these reasons. –– For part (b) it might include: –– List methods and choose four of them. –– Describe how they would be “active”. (Note that “active” is sometimes also known as “proactive”.) HINTS AND TIPS Remember to present your answer in two parts, (a) and (b), and answer the specific questions asked in the two different sub-questions. Possible reasons might be: • Pre-campaign under-reporting - the campaign made people aware of what they should be reporting; accidents/incidents may have been happening but were previously not reported. • Increased awareness – workers now expecting more follow-up of issues raised, so will now actually report them. • Previous under-reporting possibly due to worker reluctance because of: –– Disciplining of those who reported such incidents on previous occasions. –– Negative organisational health and safety culture which discouraged accident reporting. –– Lack of action by management when accidents were reported. In part (b) you need to give four examples of active techniques which are available to measure an organisation’s health and safety performance. These could include: • Consultation – how frequent; its effectiveness; adherence to procedures. • Procedures, safe systems of work, risk assessments, etc. – how many of them; whether they are up to date; awareness of them; adherence to them; whether or not in place. • Training – hours done/delivered/attended; %age compliance with mandatory courses; refresher courses completed on time/those overdue; number of “no shows” on courses. • Safety audits – number carried out compared to target number; findings completed compared to those overdue; issues raised by trends. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-21 Exam Skills • Inspections – numbers completed compared to target numbers; findings completed compared to those overdue; issues raised by trends. • Behavioural tours – numbers carried out compared to target numbers; findings completed compared to those overdue; issues raised by trends. • Benchmarking – which department/other organisation compared with; results. HINTS AND TIPS In your part (b) answer do not be tempted to give more than four examples – you won’t gain any extra marks by giving five! 3-22 | Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 © RRC International Exam Skills POSSIBLE ANSWER BY EXAM CANDIDATE (a) Following the campaign, the number of accidents may have significantly increased because of a number of factors; these could include that previously very few people were actually aware that they needed to report accidents, so accidents happened, but weren’t reported – resulting in under-reporting. It may also have been that the campaign was very successful because it now raised people’s awareness and expectations of what will be done now you have encouraged people to report accidents on site. (b)Four active methods of measuring H&S performance of the organisation could entail: –– Safety tours – these tours could take place on a regular basis and identify good and poor practice; these practices could then be logged to measure performance by scoring or tracking good and poor practice. –– Procedures, risk assessments, etc. – measuring the numbers that have been done against numbers required, checking whether they are in date and being reviewed in line with set frequencies, communicated to staff – by measuring awareness or understanding of them. –– Safety surveys – using a set survey and evaluating strengths and weakness and setting strategy for the future and implementing campaigns and then being able to measure through a survey the effectiveness of this campaign. –– Benchmarking – comparing your performance to previous years/months, other departments, sites or comparable companies (e.g. from national accident statistics published for your particular sector) to measure your performance in an active manner. REASONS FOR POOR MARKS ACHIEVED BY CANDIDATES IN EXAM An exam candidate answering this question would achieve poor marks for: • Lack of knowledge or understanding of reasons why accident reporting increased. • Lack of in-depth knowledge or understanding of four examples of active health and safety performance measures. © RRC International Unit IA – Element IA3: Measuring and Reviewing Health and Safety Performance v2.1 | 3-23 v2.1 IDENTIFYING HAZARDS, ASSESSING AND EVALUATING RISKS ELEMENT 4 LEARNING OUTCOMES On completion of this element, you should be able to demonstrate understanding of the content through the application of knowledge to familiar and unfamiliar situations and the critical analysis and evaluation of information presented in both quantitative and qualitative forms. In particular you should be able to: Describe how to use internal and external sources of information in the identification of hazards and the assessment of risk. Outline a range of hazard identification techniques. Explain how to assess and evaluate risk and to implement a risk assessment programme. the principles and techniques of failure Explain tracing methodologies with the use of calculations. © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-1 Contents SOURCES OF INFORMATION TO SUPPORT HAZARD IDENTIFICATION AND RISK ASSESSMENT Accident/Incident and Ill-Health Data and Rates External Information Sources Internal Information Sources Uses and Limitations of Information Sources Revision Questions 4-3 4-3 4-4 4-4 4-4 4-5 HAZARD IDENTIFICATION TECHNIQUES Hazard Detection Techniques Importance of Worker Input Revision Question 4-6 4-6 4-7 4-7 ASSESSMENT AND EVALUATION OF RISK Key Steps in a Risk Assessment Temporary Situations Types of Risk Assessment Organisational Arrangements for an Effective Risk Assessment Programme Acceptability/Tolerability of Risk Revision Questions 4-8 4-8 4-11 4-11 4-13 4-14 4-15 FAILURE TRACING METHODOLOGIES A Guide to Basic Probability Principles and Techniques of Failure Tracing Methods in the Assessment of Risk Revision Questions 4-16 4-16 4-17 4-29 SUMMARY 4-30 EXAM SKILLS 4-32 4-2 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Sources of Information to Support Hazard Identification and Risk Assessment KEY INFORMATION • Accident and ill-health data may be used to calculate incidence, frequency, severity and prevalence rates. • External information sources include: –– National governmental enforcement agencies such as the UK’s Health and Safety Executive (HSE), the USA’s Occupational Safety and Health Administration (OSHA) and Western Australia’s WorkSafe. –– International bodies such as the European Safety Agency, the International Labour Organisation (ILO) and the World Health Organisation (WHO). –– Professional bodies such as the Institution of Occupational Safety and Health (IOSH) and the International Institute of Risk and Safety Management (IIRSM). –– Trade unions. –– Insurance companies. –– Trade associations. • Internal information sources include: –– Injury data. –– Ill-health data. –– Property damage. –– Near-miss information. –– Maintenance records. –– Accident, ill-health and near-miss data are often under-reported. • Trends cannot be established unless large amounts of data are collected over relatively long periods of time. ACCIDENT/INCIDENT AND ILL-HEALTH DATA AND RATES Incidence Rate Incident data can be used to support hazard identification, risk assessment and risk factors. Some of the accident data collected is used to generate the statistics required by legislation but other uses are to: Incidence reflects the number of new cases in relation to the number at risk. This is calculated from: Number of work-related injuries × 1,000 Average number of persons employed • Classify industries according to risk. • Consider accident trends. It is a measure of the number of injuries per 1,000 employees and is usually calculated over a period of time, e.g. a year. It is often applied to discrete events, such as accidents. • Consider parts of the body injured - use of protective clothing. Frequency Rate • Classify workplaces. • Classify occupations. • Use ‘cause of injury’ to determine hazards in a workplace. This can be calculated from: Number of work-related injuries × 100,000 • Consider where the fault lies. • Measure the effect of preventative/control measures. It can sometimes be difficult to obtain and interpret such information. Total number of man-hours worked It is a measure of the number of accidents per 100,000 hours worked. Severity Rate This is: Accident and Disease Ratios In making comparisons between various industries, or between work areas in the same factory, it is useful to consider the commonly used accident and disease rates. You will remember these from Element IA2. © RRC International Total number of days lost × 1,000 Total number of man-hours worked It is a measure of the average number of days lost per 1,000 hours worked. Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-3 Sources of Information to Support Hazard Identification and Risk Assessment Prevalence Rate INTERNAL INFORMATION SOURCES Prevalence is a term often used to describe ill health in terms of the proportion of persons who have the prescribed ill-health condition at a particular time. TOPIC FOCUS Internal information is the most relevant data for an organisation, but other sources will be needed for comparisons, unless the organisation is large enough to give statistical significance. It can be calculated from: The total number of cases of ill health in the population × 100 Total number of persons at risk This calculation will give the percentage of the population with the disease. There should be a source of accident and ill-health data, as well as near-miss information, within the company. EXTERNAL INFORMATION SOURCES • Accident reports will be the most obvious source. It is important that the information recorded is adequate for risk assessments. We need to be able to investigate factors which contributed to the accident which means making a clear distinction between “cause of accident” and “cause of injury”. TOPIC FOCUS External information sources include: • National governmental enforcement agencies such as the UK’s HSE (www.hse.gov.uk/), the USA’s OSHA (www.osha.gov/), and Western Australia’s WorkSafe (www.docep.wa.gov.au/ WorkSafe/). These all produce legal and best practice guidance and statistics. Even if you are not under their regulatory control, their guidance can still be a valuable source of advice, especially where little or none exists in your region. • International bodies such as the European Safety Agency (osha.europa.eu/); the International Labour Organisation and their “safework” site (www.ilo.org/); and the World Health Organisation (www.who.int). • Professional bodies such as IOSH (www.iosh. co.uk/) and IIRSM (www.iirsm.org/). • Trade unions, a number of whom produce information on safety and health matters. The trade union interest here may be in making members aware of possible compensation areas. • Insurance companies, who set the levels of premiums and need data to calculate the probable risks of any venture. The average risks involved in most activities can be found in insurance tables. Since the risk manager is involved in managing risks, these tables will be extremely useful, although getting hold of them may not be so easy. • Absence records may be another indication of problems. Health problems may not always be reported, so conditions which are made worse by the work situation, rather than being caused by it, are not so easy to spot. • Maintenance records will usually show damage incidents. USES AND LIMITATIONS OF INFORMATION SOURCES Internal information is obviously very relevant to risk assessments. However, the absence of accidents is not a very good indication that all is well. Can you think why this is so? Accidents should be rare occurrences. Quite often there is a large element of chance involved in the severity of an accident. Near misses, which are usually a much larger figure, are a better indicator of risk. Care must be taken when using external sources of information. The numbers are larger, and any statistics are based on a larger sample, so are statistically more relevant. However, the type of industry covered may be much wider than your own situation. In the case of a very specialised situation this may be the only indication of risk available. Different sources use a different multiplier when working out accident frequency rates, etc. so care needs to be taken when making comparisons. • Trade associations. 4-4 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Sources of Information to Support Hazard Identification and Risk Assessment When comparing data between organisations it is important to make sure that they have the same terms of reference. For example, when comparing Lost-Time Accident (LTA) incidence rates between two organisations (based on numbers of employees), note the following: • The two organisations may use different definitions for a LTA (many companies use “more than 1 day lost” for internal reporting of LTA, whereas some enforcement agencies use “more than 3 days lost” as their standard). • There is no indication of injury severity. • The figures may be for workers only and so may be misleading for an organisation that makes wide use of contractors. • The figures may not take full account of overtime or part-time workers (they may not adjust the numbers of workers to ‘full-time equivalents’). • Culture differences - one organisation may have a culture where they take time off even after a very minor injury; another organisation might have a very strong ‘back to work’ culture where an injured worker might be brought back to work on restricted, or ‘light’ duties, in order to avoid recording a lost-time accident. • There may be different risk levels between organisations due, for example, to the nature of the work, premises, equipment, etc. • There may be different risk management arrangements in place relating, for example, to standards of risk assessment, training requirements and standards of control. REVISION QUESTIONS 1. What uses might we have for accident and illhealth data? 2. What internal information can organisations use to help in the assessment of risk? 3. Explain the difference between “incidence” and “prevalence” when referring to accident or illhealth statistics. (Suggested Answers are at the end.) © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-5 Hazard Identification Techniques KEY INFORMATION Hazards may be identified using: • Observation. • Task analysis. • Checklists. • Incidents and near misses. • Failure tracing techniques. Task Analysis Task analysis is used to analyse all aspects of a task (including safety), often with the intention of improving efficiency. A job can also be analysed with the emphasis on safety or hazards. The assessor divides the task into a number of steps, considering each step separately. The results of this analysis can be used to correct existing problems and to improve, among other things: • Safe working methods, working instructions, worker protection, safety rules, emergency procedures, serviceability of machinery and plant. Detection of hazards HAZARD DETECTION TECHNIQUES Before risk can effectively be managed, it is important to identify any hazards in the workplace; the following are some techniques that can be used. Observation Many hazard identification techniques rely on observation by the assessor(s) and are dependent on the experience and knowledge of the assessor. The analyst should observe the work being done, including work being carried out by groups of operators, looking for: • Actual and potential hazards - by observation and questioning. • Less obvious ‘invisible’ hazards - such as health dangers from fumes, gases, noise, lighting and dangerous substances, etc. • Behavioural aspects - rules and precautions for controlling any hazard or risk should be supplied by the operator, his/her supervisor or a specialist, but are they being followed? • Reporting of hazards, provision of information. • Layout of work areas. Checklists To ensure a consistent and comprehensive approach to checking all the safety elements to be covered during an inspection, a checklist or inspection form is usually developed that covers the key issues. Checklists should also be structured to provide a coherent approach to the inspection process. This helps in the monitoring of the inspection process and analysis of the results, as well as simplifying the task of carrying out the inspection itself. Checklists do have some limitations in that although they prompt the assessor when looking for hazards, any hazard not identified in the list, is less likely to be noticed. One helpful method of structuring a checklist is by using the “4 Ps”, as promoted by the UK Health and Safety Executive (HSE): • Premises, including: –– Access/escape. –– Housekeeping. –– Working environment. • Plant and substances, including: –– Machinery guarding. –– Local exhaust ventilation. –– Use/storage/separation of materials/chemicals. 4-6 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Hazard Identification Techniques • Procedures, including: –– Permits-to-work. –– Use of personal protective equipment. –– Procedures followed. • People, including: –– Health surveillance. –– People’s behaviour. –– Appropriate authorised person. (Note that the examples given are purely for illustration and are not intended to be a definitive list.) While checklists are often included in safety procedures and manuals, do not feel that they cannot be changed and adapted. In particular, in terms of maintenance and safety inspections, the list should not act as a constraint on the inspector(s) identifying other potential problems or hazards. Checklists should be reviewed regularly to take account of recent or proposed developments in health and safety issues in the particular workplace. Incident Reports These represent reactive, but nonetheless useful, data. Reports can arise from external notification requirements under national legislation (discussed in Element IA2), or from internal reporting of all loss and near-miss events. Certain accidents and occupational ill-health incidents may be reported to, and analysed by, government regulators or enforcement agencies. In such cases, annual reports are usually published giving detailed figures of reported accidents ‘analysed by cause’. These are useful when comparing differing sectors of industry. IMPORTANCE OF WORKER INPUT Rather than relying on one individual to undertake hazard identification, the team approach to risk assessment involves workers who have relevant experience and knowledge of the process or activity being considered, as they are likely to have the best understanding of the hazards. Can you think of any other reasons why workers should be involved? Involving workers also increases the “ownership” of the assessment as, having contributed to the exercise, an individual is more likely to appreciate the need for compliance with the control measures identified. Each company should maintain its own records, not just of ‘notifiable’ accidents and ill health, but of all accidents that have taken place. In this way, any trends, or particular areas that show significant changes, can be investigated at the earliest opportunity. The reports will also be a useful tool when carrying out risk assessments. Failure Tracing Techniques The techniques we have described are usually more than adequate for most risk assessments. In more complex systems it may be necessary to use more structured methods to identify hazards. One powerful technique is called a Hazard and Operability Study (or HAZOP). This breaks down a system, such as a chemical process, into different sections and then systematically asks what could go wrong in that section, what would be the consequences, and what measures could be introduced to reduce the likelihood of the failure occurring or, if it does fail, might mitigate the consequences. We will look at this and other techniques later in this element. REVISION QUESTION 4. Giving two examples for each, identify the “4Ps” promoted by the UK’s HSE when preparing a checklist for inspections. (Suggested Answer is at the end.) © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-7 Assessment and Evaluation of Risk KEY INFORMATION • The key steps in a risk assessment are: –– Hazard identification. –– Identification of who is at risk. –– Estimation, evaluation of risk and identification of precautions. –– Recording of significant findings and implementation. –– Reviewing the assessment. • Risk assessments may be qualitative, semi-quantitative or quantitative. • The risk assessment process should be reflected in a policy, organising, planning and implementing, monitoring and review. • Risks may be evaluated as being acceptable, unacceptable or tolerable. KEY STEPS IN A RISK ASSESSMENT Decide Who Might be Harmed and How According to the UK’s HSE publication Risk assessment It is important to identify the different categories of persons who are exposed to each hazard, because this will influence the choice of control measures that could be adopted to reduce the risk. For example, control measures such as training could be used to protect workers, but would not be practicable for protecting others, such as members of the public. – A brief guide to controlling risks in the workplace (INDG163): ‘a risk assessment is not about creating huge amounts of paperwork, but rather about identifying sensible measures to control the risks in your workplace.’ For the majority of work activities the five step approach is recommended: The categories might include: • Step 1: Identify the hazards. • Workers carrying out a task, e.g. operating a lathe. • Step 2: Decide who might be harmed and how. • Other workers working nearby who might be affected. • Step 3: Evaluate the risks and decide on precautions. • Visitors/members of the public. • Step 4: Record your findings and implement them. • Maintenance staff. • Step 5: Review your assessment and update if necessary. • New/young workers. Implicit within Step 3 of risk evaluation is the need to estimate the magnitude of the risk so here we will consider Step 3 as risk estimation, evaluation and deciding on precautions. • Persons who work for another employer in a shared workplace. Identify the Hazards This is a crucial step in any risk assessment; we have already discussed the techniques that can be used. • Persons with a disability. For each category you need to identify how they might be harmed. For example, for workers operating a lathe, loose clothing could become entangled in the rotating spindle, and other employees working nearby might be struck by swarf. Risk Estimation, Evaluation and Precautions Risk is the chance, high or low, that somebody could be harmed by these and other hazards, together with an indication of how serious the harm could be. It is important that you understand the difference between risk estimation and evaluation. 4-8 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Assessment and Evaluation of Risk Of course, merely encountering a hazard does not mean we will be harmed. Some people will see the hazard and avoid it deliberately and others will walk over it without being tripped up. In other words, a specific set of events must occur before a trip will occur, namely: GLOSSARY RISK ESTIMATION Risk estimation is determining the magnitude of the size of the risk. This may range from being a relatively crude estimation, e.g. high, medium or low, to a more accurate estimation based on data. “Estimation” is used because risk deals with uncertainty and even the most detailed risk assessments have to make a number of assumptions. • Not noticing the hazard and taking avoiding action. • Placing a foot into the tear such that the person can no longer maintain his or her balance. The consequence is the outcome from the adverse incident occurrence. From most such incidents there is not just one possible outcome, but a whole range of them. For example, with our torn carpet, one individual might trip on the tear, recover their balance and suffer no harm at all. At the other extreme, someone else may trip, hit their head and die. In practice we have to use our judgment to decide the most likely outcome, probably in this case just a bruise. However, if the same incident occurred in a care home where most of the residents were elderly and frail, then the most likely consequence may well be a fracture. EVALUATION Evaluation is the decision-making process whereby we decide, on the basis of the risk we have estimated, as to whether it is acceptable or otherwise. Factors Affecting Probability and Severity of Risk Risk Evaluation The magnitude of a risk associated with an incident is determined by two factors: Having estimated the magnitude of the risk, we then have to decide if the existing control measures are adequate, or whether additional/different ones are necessary. According to the HSE publication Risk assessment – A brief guide to controlling risks in the workplace (INDG163), the easiest way of evaluating the risk is to compare your practices with recognised guidance. This is more than adequate for most assessments. However, as safety practitioners who may encounter non-routine or more complex risks, having made an informed estimation of the magnitude of the risk, we can use the information to help us decide what action, if any, is necessary. • The likelihood or probability of the event occurring, and • The consequence or harm realised if the event takes place. This is usually expressed as: Risk = Likelihood (or Probability) × Consequence (or Harm) We now need to look at the factors that affect both the likelihood and the consequence. The likelihood of an adverse event occurring is affected by two factors: • Degree of exposure to the hazard and, once exposed to the hazard, We will consider the concept of risk acceptability and tolerability later in this element. Risk Control Standards Having evaluated the risk and established whether or not it is acceptable, you have to ensure that the controls meet minimum standards. Such standards may be defined in legislation, codes of practice and relevant guidance. • The likelihood that harm will occur. Let’s look at an example. Consider a torn carpet in an office and the risks it creates. Before somebody could possibly trip on the carpet, they have to walk in the vicinity of the carpet, so the degree of exposure to the hazard is a key factor. If the carpet is situated in the centre of a main walkway then the likelihood of it causing an accident is much greater than if it is in a corner of a little-used store room. Similarly, the hazard from crossing a road will create a greater probability of harm if we cross the road several times a day, rather than if we cross it only several times a year. © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-9 Assessment and Evaluation of Risk Formulation and Prioritisation of Actions When deciding on what action to take you should always follow the hierarchy of controls: • Elimination - can I remove the hazard altogether? If not, how can I control the risks so that harm is unlikely? • Substitute the hazard - try a less risky option (e.g. switch to using a less hazardous substance). • Contain the risk - prevent access to the hazard (e.g. by guarding). • Reduce exposure to the hazard - reduce the number of persons exposed to the hazard and/or reduce the duration of exposure. • Personal protective equipment - provide protection for each individual at risk. TOPIC FOCUS Suitable and sufficient This term is employed in UK legislation (Regulation 3, Management of Health and Safety at Work Regulations 1999), to ensure that the risk assessment process is comprehensive. Consequently the risk assessment should: • Identify the significant risks arising from, or in connection with, the work. The detail in an assessment should be proportionate to the risk, so if the hazards are simple, the assessment and record can be straightforward based on informed judgment and reference to relevant guidance. In many intermediate cases the risk assessment will need to be more detailed and may need access to specialist guidance and the use of analytical techniques, e.g. a noise meter to measure noise levels. • Skill/supervision - rely on the competence of the individual. • Welfare arrangements - provide washing facilities to remove contamination and first aid facilities. Invariably, combinations of control are applied, rather than relying on one alone. Just because a measure is near the bottom of the hierarchy does not mean it is not important (e.g. first aid) - it just means that an employer should not rely exclusively on it and must consider measures higher up the hierarchy. If we have made an evaluation of the risk we should then be able to prioritise the necessary actions in terms of risks that need immediate attention, e.g. because of serious non-compliance, and those that may be dealt with in the short or even long term when resources become available. These actions may reflect going beyond the minimum legal standard and be best practice. Recording Requirements Clearly, it is good practice to record the details of risk assessment. The significant findings should include: • A record of the preventive and protective measures in place to control the risks. • What further action, if any, needs to be taken to reduce risk sufficiently. In many cases, employers (and the self-employed) will also need to record sufficient detail of the assessment itself, so that they can demonstrate that they have carried out a suitable and sufficient assessment. This record of the significant findings will also form a basis for a future revision of the assessment. 4-10 The most hazardous sites will require the most sophisticated risk assessments, especially where there are complex or unusual processes. For example, if a site stores bulk amounts of hazardous substances then the risk assessment may require the use of techniques such as quantified risk assessment (see later in the element). Risk assessments must also consider all those who might be affected by the activities, whether they are workers or others, such as members of the public. For example, the assessment produced by a railway company will need to consider the hazards and risks which arise from the trains that not only affect workers but also contractors and the public. • Employers and the self-employed are required to take reasonable steps to help themselves identify risks by accessing appropriate legislation and guidance, manufacturers’ instructions, or seeking competent advice. • The risk assessment should indicate the period of time for which it is likely to be valid. This will allow management to know when shortterm control measures should be reviewed and modified. | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Assessment and Evaluation of Risk Qualitative Assessments TEMPORARY SITUATIONS For workplaces where the nature of the work may change frequently (such as contract maintenance work), or the workplace itself changes (such as a construction site), the risk assessment needs to be more dynamic in order to accommodate these changing situations. In these situations it may be necessary to concentrate more on a broad range of foreseeable risks and develop a range of appropriate control options for these rather than try to document rigid control measures for a temporary and changing workplace. For this approach to be effective in a temporary situation, detailed planning and worker training in dealing with the significant risks is essential. TYPES OF RISK ASSESSMENT Before we continue, let’s remind ourselves of the definitions of the following two terms: • Quantitative - a measurement of magnitude is involved, e.g. there were four fatalities due to falls from height over a 12-month period at Business X; the airborne concentration of formaldehyde in a workplace was measured as 13ppm. • Qualitative - no actual measurement is used. It involves describing the qualities, e.g. the airborne concentration was high or serious; the injury sustained was minor. There are conceptually two basic categories of risk assessment: qualitative and quantitative. In practice there is also a third category which uses numbers to indicate rank order, called semi-quantitative. Quantitative risk assessment uses more rigorous techniques in an attempt to quantify the magnitude of the risk. Even in the high hazard industries (such as nuclear and chemical) most of the assessments are not quantitative. However, they are often used to satisfy a regulator that very unlikely events which, if they occurred, would have serious consequences not only to the organisation but also to the public (such as loss of containment of radioactive material in a nuclear facility) have been assessed. All risk assessments involve at least some element of subjectivity or judgment. GLOSSARY QUALITATIVE RISK ASSESSMENT “A qualitative risk assessment is the comprehensive identification and description of hazards from a specified activity, to people or the environment. The range of possible events may be represented by broad categories, with classification of the likelihood and consequences, to facilitate their comparison and the identification of priorities.” Qualitative risk assessments are based entirely on judgment, opinion and experience including approved guidance, rather than on measurements. They use technology-based criteria to establish if you have done enough to control risks, i.e. “If I use this standard control measure I’m pretty sure the risk will be adequately controlled”. They allow you to easily prioritise risks for further action, but while they enable risks to be ranked against other risks, they do not objectively estimate risks and so do not allow direct comparisons with external estimates. A qualitative risk assessment is carried out by the risk assessor(s) making qualitative judgments with respect to the likelihood and consequence associated with a particular loss event. This judgment may be made through observation and discussion with workers, as well as looking at other information, e.g. accident records. There are various ways in which likelihood and consequence could be categorised; the following is a simple example. Example Consider our torn carpet example again. There are a number of possible outcomes should someone trip on it; the severity categories might be: • Minor - minor injury or illness with no significant lost time, such as a slight cut or bruise. • Lost time - more serious injury causing short-term incapacity from work or illness causing short-term ill health, e.g. broken limb. • Major - fatality or injury/illness causing long-term disability. We use our experience to qualitatively judge the most likely outcome. We need to be sensible here otherwise we will end up with the worst possible consequence always being death (or even multiple deaths) and the ability to prioritise remedial action is defeated as a result. In this example, the likely outcome could be that someone would be badly bruised with no significant lost time, and therefore “Minor” would be chosen. © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-11 Assessment and Evaluation of Risk The likelihood of someone tripping over the carpet could be categorised by one of the following terms: Here is simple 3 x 3 matrix: Matrix ranking risk in terms of likelihood and consequence • Very likely. • Likely. L i k e l i h o o d • Unlikely. In this example we might judge that the likelihood of exposure to the hazard (coming into contact with the torn carpet) and subsequently tripping might be “Likely”. Think of our earlier equation for risk magnitude: Risk = Likelihood (or Frequency) x Consequence (or Harm or Severity) It follows then, that, although no numbers are being used, it is easy to see that the risk of someone injuring themselves on the torn carpet is moderate. For this reason, remedial action must be carried out to minimise the risk which in the short term might involve using carpet tape to join the two ends. Where there are a number of hazards that have been assessed in a similar way, it is possible to prioritise the remedial action so that the ones which pose the greatest risk are resolved first. Clearly each organisation would need to come up with their own categories which reflect the types of injury that may occur along with their likelihood frequency. If the descriptors “Minor”, “Lost time”, “Major” are replaced arbitrarily with ‘1’, ‘2’ and ‘3’, respectively, this is still a qualitative risk assessment since there is still no quantitative basis for the choice - just a switch of numbers for words. So, don’t think that the mere presence of numbers somehow converts it into a more thorough quantitative assessment. 6 9 M=2 2 4 6 L=1 1 2 3 Medium = 2 High = 3 Consequence The likelihood and consequence are each characterised as low, medium or high and are assigned a number 1, 2 or 3 respectively. The risk is determined by calculating the product of the likelihood and the consequence, so risks range from 1 (low likelihood and low consequence) to 9 (high likelihood and high consequence). The key point about such matrices is that they are used to rank risks, i.e. put them in order. They have no meaning in terms of their relative sizes so it cannot be assumed that a risk value of 9 is nine times the size of a risk rating of 1. Quantitative Risk Assessment GLOSSARY QUANTITATIVE RISK ASSESSMENT “A quantitative risk assessment is the application of methodology to produce a numerical representation of the frequency and extent of a specified level of exposure or harm, to specified people or the environment, from a specified activity. This will facilitate comparison of the results with specified criteria.” In many risk assessments where the hazards are not few and simple, nor numerous and complex, it may be necessary to use some semi-quantitative assessments in addition to the simple qualitative assessments. Semi-quantitative risk assessments may also use a simple matrix to combine estimates of likelihood and consequence in order to place risks in rank order. 3 Low = 1 Semi-Quantitative This may involve measuring the exposure of a worker to a hazardous substance or noise which can then be used to assess whether the risks to the workers are acceptable or not. H=3 Quantitative risk assessments attempt to calculate probabilities or frequencies of specific event scenarios. This is sometimes mandated by legislation, so that the results can be compared with criteria on what is considered an acceptable, or a tolerable risk. They may use advanced simulation or modelling techniques to investigate possible accidents, and will utilise plant component reliability data. They are sometimes referred to as QRA or Probabilistic Risk Analysis (PRA). 4-12 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Assessment and Evaluation of Risk The degree of quantification used is variable. This type of risk assessment typically uses advanced tools such as fault tree analysis and event tree analysis (see later). It relies heavily on having suitable data to calculate the probability or frequency of a defined event. QRAs are evidence-based (i.e. use ‘hard’ data) to be as objective as possible. It may not be possible to fully quantify risks - especially for infrequent events. Despite the name, QRAs invariably involve some subjectivity; this is because some broad assumptions may have to be made, e.g. in the application of human reliability assessment. This approach is used for safety cases to establish that the risks have been fully identified, and to justify that enough has been done to reduce the risk to the lowest level reasonably practicable. QRA is used in high-hazard chemical and nuclear installations and in the offshore oil industry for specific risk scenarios. Such risk assessments are included as part of their safety report requirements. Quantitative methods are also used in setting Occupational Exposure Limits (OELs) for airborne contaminants. For major hazard sites, such as large chemical installations, numerical estimates of the probability or frequency of plant failure may be calculated. This is at its most valid when it involves use of component reliability data, simply because the data is available (or can be measured) and is often based on a large sample size and so is statistically valid. The results of particular failure scenarios would then be considered, in terms of the different possible consequences, perhaps using fault trees and event trees (which may use component, structural, system and/ or human reliability data). Consequence itself is not usually quantified as such. Rather, many failure scenarios (perhaps several hundred), all with different consequences are modelled, and the probability or frequency of each scenario actually developing is calculated. An example would be the failure of a chlorine storage vessel in a particular way with dispersion modelling of several different release patterns for a toxic gas cloud. In such cases, the likelihood of harm resulting from all the different potential causes of failure, has to be rolled up into a single estimate of the risk from that installation. We will consider some of these points in more detail when we look at failure- tracing methods later in this element. © RRC International ORGANISATIONAL ARRANGEMENTS FOR AN EFFECTIVE RISK ASSESSMENT PROGRAMME As risk assessment is a fundamental component of a health and safety management system, it is important that the process of risk assessment is effectively managed. Earlier in the course we looked at what constitutes an effective health and safety management system; it is sensible to use the elements of a health and safety management system to manage risk assessment. Plan • Where you are now and where you need to be. • What you want to achieve, who will be responsible for what, how you will achieve your aims, and how you will measure your success. • Write down this policy and your plan to deliver it. • Decide how you will measure performance, looking for leading as well as lagging indicators (active and reactive). • Remember to plan for changes and identify any specific legal requirements that apply. Do • Identify your risk profile. –– Assess the risks, identify what could cause harm in the workplace, who it could harm and how, and what you will do to manage the risk. –– Decide what the priorities are and identify the biggest risks. • Organise your activities to deliver your plan. In particular, aim to: –– Involve workers and communicate, so that everyone is clear on what is needed and can discuss issues – develop positive attitudes and behaviours. –– Provide adequate resources, including competent advice where needed. • Implement your plan. –– Decide on the preventive and protective measures needed and put them in place. –– Provide the right tools and equipment to do the job and keep them maintained. –– Train and instruct, to ensure everyone is competent to carry out their work. –– Supervise to make sure that arrangements are followed. Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-13 Assessment and Evaluation of Risk –– Make sure that your plan has been implemented. –– Assess how well the risks are being controlled and if you are achieving your aims. • Investigate the causes of accidents, incidents or near misses. Act • Review your performance. –– Learn from accidents and incidents, ill-health data, errors and relevant experience, including from other organisations. –– Revisit plans, policy documents and risk assessments to see if they need updating. • Take action on lessons learned, including from audit and inspection reports. (Based on original source HSG65 Managing for Health and Safety, HSE, 2013 (www.hse.gov.uk/pubns/priced/hsg65. pdf)) ACCEPTABILITY/TOLERABILITY OF RISK There are criteria by which a society decides which risks it is prepared to expect workers and members of the public to live with, and those it is not. In the UK the criteria are set out in the HSE document Reducing Risks, Protecting People (R2P2) in which, broadly speaking, the risks are classified into three categories: • Acceptable - no further action required. These risks would be considered by most to be insignificant or trivial and adequately controlled. They are of inherently low risk, or can be readily controlled to a low level. • Unacceptable - certain risks that cannot be justified (except in extraordinary circumstances), despite any benefits they might bring. Here it is possible to distinguish between those activities that those at work are expected to endure, and those that individuals are permitted to engage in through their own free choice, e.g. certain dangerous sports/pastimes. • Tolerable - risks that fall between the acceptable and unacceptable. Tolerability does not mean acceptable, but means that society is prepared to endure such risks because of the benefits they give, and because further risk reduction is grossly out of proportion in terms of time, cost, etc. In other words, to make any significant risk reduction would require such great cost that it would be out of all proportion to the benefit achieved. When we discuss benefits we mean: –– Employment. –– Lower costs of production. –– Convenience to the public. –– Maintenance of a social infrastructure, e.g. supply of food or production of electricity. 4-14 Increasing individual risk and societal concerns • Measure your performance. The terms acceptable, unacceptable and tolerable are best illustrated by the following figure: Unacceptable Tolerable ALARP region Acceptable Tolerability of risk You can see that the risks that fall into the tolerable region are described as being “As Low As is Reasonably Practicable”, often referred to as ALARP. These are risks that society is prepared to endure on the following assumptions: • They are properly assessed to determine adequate control measures. • The residual risk (after the implementation of control measures) is not unduly high. • The risks are periodically reviewed to ensure they remain ALARP. How, then, are tolerability limits defined? Increasing individual risk and societal concerns Check Unacceptable Tolerable 1 in 1,000 per person/yr (employee) 1 in 10,000 per person/yr (public) ALARP region 1 in 1m per person/yr Acceptable Unacceptable/tolerable/acceptable boundary limits | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Assessment and Evaluation of Risk • Boundary Between Acceptable and Tolerable The UK’s HSE believes an individual risk of death of one in 1 million per year, or less for both workers and members of the public, is broadly acceptable. This risk is very low; indeed using gas or electricity, or travelling by air poses a much greater risk. • Boundary Between Tolerable and Unacceptable Here there is a distinction between workers and the public. –– For workers, an individual risk of death of one in 1000 per year represents the dividing line between what is tolerable for an individual for any large part of their working life and what is unacceptable (apart from exceptional groups). –– For members of the public who have risks imposed on them who live, for example, next to a major accident hazard, the figure is an individual risk of death of one in 10,000 per year, i.e. ten times less risk. This figure equates approximately to the individual risk of death per year as a result of a road traffic accident. MORE… You can access the HSE publication Reducing risks, protecting people (R2P2) at: www.hse.gov.uk/ REVISION QUESTIONS 5. What are the characteristics of a “suitable and sufficient” risk assessment? 6. What is a tolerable risk? (Suggested Answers are at the end.) © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-15 Failure Tracing Methodologies KEY INFORMATION Failure tracing methods are structured techniques to assist in hazard identification and risk assessment. They include: • Hazard and operability studies - identify hazards in a system and their effect on the system. • Fault tree analysis - identifies the necessary events and how they combine to lead to a loss event called the Top Event. • Event tree analysis - used to identify the possible consequences from an event and the influence of controls. A GUIDE TO BASIC PROBABILITY To understand the advanced risk assessment techniques that involve quantified risk assessment you need to understand the basic principles of probability. Probability of a Single Event Occurring Probability relates to the chance of an event occurring and in numerical terms can only have a value between 0 and 1: • 0 means there is no chance of it happening, i.e. it is impossible. • 1 means it is certain to happen. Suppose we toss a coin. There are only two possible outcomes, namely Heads or Tails. • So, the probability of getting Heads, i.e. ½, or, 0.5. • The probability of getting Tails is also ½, or, 0.5. You will notice that given that there are only two possible outcomes, the sum of the two probabilities equals one, i.e. Probability of Heads + Probability of Tails = 0.5 +0.5 = 1. There are four outcomes but only one matches “Heads and then Heads”; the probability is therefore ¼ = 0.25. The probability is simply the product of each of the two events, i.e. ½ × ½ = ¼ =0.25. So if we wanted to know what the probability is of obtaining three sixes if we threw three separate dice, it would be: 1/6 × 1/6 × 1/6 = 1/216 = 0.0047, which is not very likely! So to calculate the probability of two or more independent events occurring, we multiply the probabilities. Incidentally, the probability of winning the Lotto, i.e. selecting all six numbers, is 1 in 14,000,000, which is an extremely remote event! Yet, of course, as millions of people play every week there is often a winner. Suppose we now wanted to know what the probability is of getting a 1 OR a 6 if we threw a dice. Well the possible outcomes are, of course, 1, 2, 3, 4, 5 and 6. Of these six possibilities two meet our requirement of 1 or 6, i.e. 2 out of 6 = 2/6 (or 0.33). Similarly, if we threw a six-sided dice, the probability it would land showing a six would be 1/6 = 0.167. • The probability of getting a 1 is 1/6. Probability of Multiple Events Occurring So the probability of getting a 1 OR a 6 is 1/6 + 1/6 = 1/3. Suppose we now toss a coin twice. What is the probability that on both occasions it will show Heads? Here are all the possible outcomes: • Heads and then Heads. • Heads and then Tails. • The probability of getting a 6 is also 1/6. In other words, when we want to know the probability of one event or another, we ADD the probabilities of the two separate events. Understanding these principles will be very useful to you when we look at Fault Tree Analysis. • Tails and then Heads. • Tails and then Tails. 4-16 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Failure Tracing Methodologies Probability and Frequency The studies are carried out by a multidisciplinary team, usually made up of four to seven people. Members typically include: In risk assessment we sometimes refer to the probability of an event and sometimes to the frequency of an event. What is the difference? • Probability is the chance something will happen. So if the probability of tripping over a torn carpet happened to be 1 in a 1000, then this means that if 1000 people walked over the tear, on average, one would trip. How long this would take would depend how long it takes 1000 people to encounter the tear. If the tear was in a busy walkway, it might be only a matter of a few hours or less; if it was in a room that was hardly used, it might take many years. So exposure to the hazard is very important. • Frequency takes account of the exposure. So if we say the event will happen on average once every 10 years, we say its frequency is 1/10 or 0.1y-1. We cannot combine frequencies, i.e. add or multiply them in the same way that we can probabilities, but we can multiply a frequency with a probability. Consider an event which has a probability of harm of 1 in 100, i.e. 0.01, and we know the event occurs 300 times a year; the frequency of the harm will be: • Study Leader - should not be closely involved with the project but should have good experience of HAZOP and can keep the team focused. • Recorder - documents the proceedings. • Designer - explains how the system should work. • A user of the system, such as a production manager. Others who may contribute include: • Maintenance engineer. • Software specialist. • Safety expert. • Instrument engineer. The team have a diagram that represents the system, showing each of the components of the system and how they are related. In the case of a chemical process plant this would be a pipeline and instrumentation diagram. The steps involved in a HAZOP are: • Divide the system into parts (sometimes called nodes). In the case of a chemical process plant this might be a pipeline between a storage vessel and a reactor. 0.01 (probability of harm) x 300 (frequency of occurrence per year) = 3 harmful events a year. • For each part define the design intention, i.e. what is meant to occur when it is operating normally. PRINCIPLES AND TECHNIQUES OF FAILURE TRACING METHODS IN THE ASSESSMENT OF RISK Failure tracing methods may be used in more detailed risk assessments. They are unnecessary in most cases, but provide a systematic methodology for identification of hazards and, in some cases, calculation of failure probabilities, for more complex cases; they are used extensively in, for example, quantified risk assessment. They can be used qualitatively and some quantitatively as well. Some can be used to model incidents and so can be used in accident investigation. Hazard and Operability Studies (HAZOPs) The HAZOP method is designed for dealing with relatively complex systems, such as large chemical plants or a nuclear power station, where a deviation from what is expected in one component of the system may have serious consequences for other parts of the system The principles can be used in simpler situations, but a full HAZOP will not usually be cost-effective, except in a high risk situation. We will cover the principles and outline the technique. • Apply a number of ‘guide words’ to the statement of intention, so that every possible deviation from the required intention is considered. The main guide words are: NO or NOT Negation of intention, e.g. no flow. MORE Quantitative increase, e.g. high pressure. LESS Quantitative decrease, e.g. low temperature. AS WELL AS Qualitative increase, e.g. impurity present. PART OF Qualitative decrease, e.g. only one of two components present REVERSE Logical opposite of intention, e.g. backflow. OTHER THAN Complete substitution, e.g. flow of wrong material. HAZOPs are a form of structured “brainstorming”. © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-17 Failure Tracing Methodologies Let us consider a simple example. In a batch process, two substances, A and B, are pumped from their respective storage vessels into a reaction vessel: Parameter Guide word Deviation Cause Consequence Actions Flow of ‘A’ No No flow Pump failure Incorrect product/ reaction doesn’t occur Indicate pump working at control panel. Pump off Line blockage Maintain lines Level control on tank, etc. Tank empty Reactor full More More flow Pump at wrong rate Incorrect product/ reaction doesn’t occur The design intention is for equal amounts of A and B to be pumped into the reactor vessel. We can identify two parts to this system: • Storage vessel A and the pipeline and pump to the reactor vessel. • Storage vessel B and the pipeline and pump to the reactor vessel. Let us apply the first guide word “NO” to the first part. In this case it would mean “no flow”. Think of some reasons why there might be no flow in the pipeline. Here are some suggestions: • Pump A has failed. • Pump A not switched on. • Storage vessel A is empty. • Reactor vessel is full. • Pipeline blocked. Having established the possible causes of this deviation we then need to make an estimate of the risk for each cause. In other words: Automatic control of pump rate Having assessed the risk, we need to determine whether the existing control measures are adequate, or whether we need to add additional ones. In our example we might introduce a level gauge in the storage tank and reactor vessel, each linked to an alarm so that the operator of the plant would know when the levels were too high or too low. We might introduce a more reliable pump or even a second (redundant) pump that could take over should the first one fail. Having considered this deviation we would then move on to the next guide word, which in this case would mean “more flow”. Having examined flow we would move on to other parameters such as temperature and pressure, and apply the guide words again. Clearly even a relatively simple system can result in a significant and lengthy analysis. For a major plant it can take considerable time and involve significant expenditure. Fault Tree Analysis (FTA) and Event Tree Analysis (ETA) Be careful not to get confused between these two techniques; they are, in fact, complementary (and are often used together) but focus on opposite sides of an undesired event. The following figure shows how they fit together: • How likely is this deviation? • How soon would we know that the deviation had occurred? • What are the consequences? • How serious are the consequences? 4-18 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Failure Tracing Methodologies Looking at Undesired Events - Using Failure Tracing Methods Multiple Consequences after event Multiple Causes leading to event initial undesired event Preventive measures Mitigation measures The focus of ETA The focus of FTA Relationship between FTA and ETA (‘Bow-Tie’ model) The figure only shows a single ‘undesired event’; in reality, multiple causes can lead to many different events initially, each then escalating with multiple consequences. You can analyse each event with FTA and ETA. In summary, FTA is concerned with analysing faults which might lead to an event, whereas ETA considers the possible consequences once an undesired event has taken place. Both can be applied qualitatively or, if you have the data, quantitatively. Fault Tree Analysis (FTA) In many cases there are multiple causes for an accident or other loss-making event. Fault tree analysis is one analytical technique for tracing the events which could contribute. It can be used in accident investigation and in a detailed risk assessment. The fault tree is a logic diagram based on the principle of multi-causality, which traces all branches of events that could contribute to an accident or failure. It uses sets of symbols, labels and identifiers. For our purposes, you will only need a handful of these: © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-19 Failure Tracing Methodologies EVENT AND gate OR gate Basic fault A fault tree diagram is drawn from the top down (like an upside down tree). The starting point is the undesired event of interest (called the Top Event because it gets placed at the top of the diagram). You then have to logically work out (and draw) the immediate and necessary contributory fault conditions leading to that event. These may each in turn be caused by other faults and so on. Each branch of the tree is further developed until a primary failure (such as a root cause) is identified. It could be endless (though, in fact, you will naturally have to stop when you get as far as primary failures). The most difficult part is actually getting the sequence of failure dependencies worked out in the first place. Let’s look at a simple example of a fire to illustrate the point. 4-20 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Failure Tracing Methodologies Fire Fuel Paper Petrol Ignition source Oxygen Discarded cigarette Plastic Electrical fault Deliberate Fault tree analysis of a fire The above figure shows a simple fault tree for a fire. HINTS AND TIPS Don’t worry about getting the symbols precisely right when you draw fault trees by hand; you can make your intentions quite clear by writing AND or OR in the appropriate logic gate as well. Also, as long as you describe the fault/failure in a box, don’t worry too much about the (sometimes subtle) distinction between what should go in rectangles and circles. For the fire to occur there needs to be: Notice we use an AND gate to connect them here because all three need to be present at the same time to allow the Top Event. The example shows that, in this scenario, there happen to be three possible sources of fuel and three possible sources of ignition. An OR situation applies in each case, because it would only need one of these to be present. The example also shows a single source of oxygen (e.g. the atmosphere). To prevent the loss taking place, we would first examine the diagram for AND gates. This is because the loss can be prevented if just one of the conditions is prevented. Fault trees can also be quantified, but need relevant data on the respective probabilities of each of the sub events. Let’s try this on the same example. • Fuel. • Oxygen. • An ignition source. © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-21 Failure Tracing Methodologies From previous experience, or as an estimate, a probability for each of the primary failures being present or occurring can be established, shown in the following figure (these are purely illustrative): Fire Fuel Ignition source Oxygen 1 Paper Petrol Plastic Discarded cigarette Electrical fault Deliberate 0.1 0.02 0.09 0.2 0.05 0.1 (We’ve assigned a probability of 1 for oxygen being present, as it is always in the surrounding atmosphere.) We can then use two well-established rules of combination of these probabilities and progress up the diagram to get at the probability of the Top Event (fire) occurring. Essentially we: • Add the probabilities which sit below an OR gate (this isn’t strictly correct, but is a ‘rare event’ approximation). • Multiply the probabilities which sit below an AND gate So, in this example, combining probabilities upwards to the next level gives: Probability of FUEL being present = 0.1 + 0.02 + 0.09 = 0.21. Probability of OXYGEN being present = 1. Probability of IGNITION being present = 0.2 + 0.05 + 0.1 = 0.35. 4-22 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Failure Tracing Methodologies Updating the figure: Fire 0.1 + 0.02 + 0.09 = 0.21 Fuel Ignition source Oxygen 0.2 + 0.05 + 0.1 = 0.35 1 Paper Petrol Plastic Discarded cigarette Electrical fault Deliberate 0.1 0.02 0.09 0.2 0.05 0.1 Moving up again, we can now calculate the probability of the Top Event. These faults are below an AND gate, so we multiply the probabilities, giving 0.21 × 1 × 0.35 = 0.0735. The fully quantified fault tree then looks like this: © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-23 Failure Tracing Methodologies 0.21 × 1 × 0.35 = 0.0735 Fire 0.1 + 0.02 + 0.09 = 0.21 Fuel Ignition source Oxygen 0.2 + 0.05 + 0.1 = 0.35 1 Paper Petrol Plastic Discarded cigarette Electrical fault Deliberate 0.1 0.02 0.09 0.2 0.05 0.1 So the probability of the Top Event is 0.0735. You are probably wondering what this number means. Well, if the probability was 0.1, this would mean there was a 1 in 10 chance of it occurring (i.e. 1/0.1 = 10). If it was, say, 0.25 then this represents 1/0.25 = 4, i.e. a 1 in 4 chance, so 0.0735 means 1/0.0735 = 13.6, i.e. nearly a 1 in 14 chance of the fire occurring. HINTS AND TIPS To get maximum marks in the exam, make sure that you show all your workings when quantifying a fault tree. 4-24 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Failure Tracing Methodologies Event Tree Analysis (ETA) Unlike identifying the root causes of an event under consideration, ETA is concerned with identifying and evaluating the consequences following the event. In FTA the main event is called the Top Event, whereas in ETA it is called the Initiating Event. Event trees are used to investigate the consequences of loss-making events in order to find ways of mitigating, rather than preventing, losses. The stages involved in carrying out an event tree analysis are: • Identify the Initiating Event of concern. • Identify the controls that are assigned to deal with the Initiating Event, such as automatic safety systems, and other factors that may influence the outcome, such as wind direction or presence of an ignition source that would be important if there was an escape of a large amount of liquefied petroleum gas. • Construct the event tree beginning with the Initiating Event and proceeding through the presence of conditions that may exacerbate or mitigate the outcome. • Establish the resulting loss event sequences. • Identify the critical failures that need to be dealt with. • Quantify the tree if data is available to identify the likelihood or frequency of each possible outcome. There are a number of ways to construct an event tree. They typically use binary logic gates, i.e. a gate that has only two options, such as success/failure, yes/no, on/ off. They tend to start on the left with the Initiating Event and progress to the right, branching progressively. Each branching point is called a node. Simple event trees tend to be presented at a system level, glossing over the detail. Let us illustrate the process with a simple example where the Initiating Event is a fire: Fire detected? Initiating event Fire Yes No © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-25 Failure Tracing Methodologies The ETA diagram shows the Initiating Event on the left, leading to a mitigation measure: “Is the fire detected?” The answer to this question is a simple YES or NO, so the tree now branches to represent whether the answer to the question is YES or NO. Detection of the fire is, of course, the first step in minimising the consequence of the fire so now we need to consider those other factors that are necessary that will either minimise the outcome, or make the situation worse. Fire detected? Fire alarm works? Sprinkler works? Limited damage Yes Yes No No Fire Yes Yes Extensive damage Limited damage Wet people No No Possible fatalities Extensive damage In this example, apart from detecting the fire we need to have an effective alarm system to alert persons in the building and an effective sprinkler system. The detection system switches on the alarm and then the sprinkler. Each factor is considered as to whether it occurs or does not occur, each leading to a further branch in the tree. You will also note that in this example, should the fire not be detected, the alarm will not sound nor will the sprinkler operate, so if the fire is not detected there will be the worst outcome. At the end of the branches on the right of the tree you can see the different outcomes identified, depending on the success or otherwise of the intervening factors. In binary logic, an event either happens, or does not. Let us suppose that the probability the fire is detected is 0.95; this means 95 out of every 100 times a fire takes place it will be detected. It follows that the probability it is not detected is 0.05, i.e. 5 out of every 100 times. So the: Probability of success + Probability of failure = 0.95+0.05=1. In all binary events the sum of the two probabilities must always equal 1. To quantify an event tree we need to know the probability for each of the outcomes that follow from the Initiating Event - the probability that: • The fire is detected; • The alarm works; and • The sprinkler works. 4-26 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Failure Tracing Methodologies Here is the tree with the probabilities for the three events after the Initiating Event. Fire detected? Sprinkler works? Fire alarm works? P = 0.9 Limited damage Yes P = 0.99 Yes No P = 0.1 P = 0.9 P = 0.95 No f = 0.01/y Yes Yes Extensive damage Limited damage Wet people P = 0.01 Fire No No P = 0.1 P = 0.05 Possible fatalities Extensive damage As we noted above, the sum of the probabilities for each event is always 1. You will also notice that we have included the frequency of the Initiating Event, i.e. the fire, which is 0.01/y which means a fire will occur on average once every 1/0.01 years, i.e. once every 100 years. We can now calculate the frequency of each of the possible sequences identified in the tree by multiplying the probabilities for each sequence and then multiplying this by the frequency of the Initiating Event. So for the sequence leading to “Limited damage” we have: Frequency of fire (0.01/y) x Fire detected (0.95) x Fire alarm works (0.99) x Sprinkler works (0.9) = 0.0085. This means this outcome will occur (on average) once every 1/0.0085 years = 118 years. In contrast, the sequence in which the fire is not detected will occur with a frequency of 0.01 × 0.05 = 0.0005/y which is once every 1/0.0005 years = 2000 years. © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-27 Failure Tracing Methodologies Here is the tree with the expected frequencies for each of the outcomes: Fire detected? Fire alarm works? Sprinkler works? P = 0.9 Yes P = 0.99 Limited damage f = 1:117.65y P = 0.0085/y Yes No P = 0.95 No P = 0.01/y Yes P = 0.1 P = 0.9 Yes P = 0.01 Extensive damage P = 0.00094/y f = 1:1063.83y Limited damage Wet people P = 0.000086/y f = 1:11,627.91/y Fire No No P = 0.0000095/y P = 0.1 f = 1:105,263.16/y P = 0.0005/y P = 0.05 f = 1:2000/y Possible fatalities Extensive damage What can we conclude from this? Well, the most probable outcome, should a fire break out, is that all the controls will work and damage will be limited (probability = 0.0085). However the second most probable outcome is the fire not being detected and this leads to extensive damage and possible fatalities (probability = 0.0005). What would we recommend? One solution would be to increase the reliability of the fire detection system. However, this is a crucial link in the sequence, since if it fails then the reliability of the alarm and sprinkler become irrelevant. A much better improvement would be to include a second detector, independent of the first. This would mean that BOTH detectors would have to fail, which is a much less likely event. The following is a similar example. The figure shows a quantified event tree for the action following a fire on a conveyor system. Here the fire detector, i.e. the heat sensor, opens the valve leading to operation of the water sprays. As in the previous example, should the sensor fail, the success of the valve or water spray is not relevant to the outcome; but here, should the valve fail, the success of the water spray becomes irrelevant. 4-28 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Failure Tracing Methodologies Heat sensor detects Valve operates Water sprays operate 0.7 0.8 0.3 0.9 0.2 Outcome frequencies 2 × 0.9 × 0.8 × 0.7 = 1.008/yr 2 × 0.9 × 0.8 × 0.3 = 0.432/yr 2 × 0.9 × 0.2 = 0.36/yr Conveyer belt fire (of frequency 2/year) 0.1 2 × 0.1 = 0.2/yr Success state Failure state The only outcome resulting in control of the event is where the sensor, valve and water spray operate (the example is a little contrived but serves to demonstrate the principles). Notice how the frequencies of the outcomes are calculated. Notice also that the sum of all the outcome frequencies adds up to 2 in this case, i.e. the frequency of the Initiating Event (the conveyer belt fire). The event tree could be used to check that there were adequate fire detection, warning and extinguishing systems. REVISION QUESTIONS 7. The frequency of pipework failure in a large LPG storage facility is estimated at once every 100 years (f=0.01/year). Immediate ignition of the released gas (probability, p=0.05) will result in a jet flame. Otherwise, prevailing winds will normally carry any vapour cloud off site across open countryside where it will disperse safely. However, under certain conditions (p=0.1), the cloud may drift to a nearby industrial estate where ignition (p=0.5) will cause a vapour cloud explosion or flash fire. Using the data provided, construct an event tree to calculate the expected frequency of fire or explosion due to pipework failure BOTH on site AND on the industrial estate. 8. Outline the basic principles of a hazard and operability study. 9. Briefly explain the difference between an “event tree” and a “fault tree”. (Suggested Answers are at the end.) © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-29 Summary SUMMARY Sources of Information to Support Hazard Identification and Risk Assessment We considered commonly used accident and disease ratios - incidence rate, frequency rate, severity rate and prevalence rate. Information can be sourced both externally and internally: • External sources include: national governmental enforcement agencies, international bodies, professional and trade bodies, and insurance companies. • Internal sources include: accident reports, absence records and maintenance records. Hazard Identification Techniques Various techniques can be used to detect hazards including: task analysis, checklists, observations and incident reports. A checklist which covers the key issues to be monitored is developed to ensure a consistent and comprehensive approach to checking all the safety elements to be covered during an inspection. The analyst should make an observation of the work being done, including work undertaken by groups of operators. Assessment and Evaluation of Risk We looked at the key steps that characterise all risk assessments: • Hazard identification. • Identify who is at risk. • Estimation, evaluation of risk and identifying precautions. • Record significant findings and implement. • Review the assessment. Assessments should ensure suitable and sufficient coverage of risk. This means that: • They should identify the significant hazards. • The detail should be proportionate to the risk, with the most hazardous operations requiring the most sophisticated assessments. • In some cases more analytical techniques may be necessary (e.g. high noise levels). • The period for which it is likely to remain valid should be identified. Types of risk assessment include: • Qualitative - risks are represented by simple word descriptors. –– Risk = Probability (or Frequency) x Consequence (or Harm or Severity). –– Probability is the chance that a given event will take place. –– Severity of risk is the outcome. • Semi-quantitative - results represented by qualitative and quantitative descriptions. In some the risk is expressed as a number which indicates rank and not an absolute value. • Quantitative - risks are represented by the frequency or probability of a specified level of harm, from a specified activity. 4-30 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Summary Organisational arrangements for risk assessment include: • Plan - what you want to achieve, who will be responsible for what, how you will achieve your aims, and how you will measure your success. • Do - identify your risk profile, organise your activities to deliver your plan. • Check - measure your performance, assess how well the risks are being controlled and investigate the causes of accidents, incidents or near misses. • Act - review your performance and take action on lessons learned, including from audit and inspection reports. Once hazards have been identified, the risk they pose needs to be assessed and prioritised. Failure Tracing Methodologies Principles and techniques of failure tracing methods: • HAZOPS is: –– A method designed for dealing with complicated systems where failures can affect other parts of the system. –– Used, for example, at large chemical plants. • Fault tree analysis starts with a Top Event and identifies the necessary preceding events and their combination that are necessary for the Top Event. It identifies causes. • Event trees start with an Initiating Event and look at the consequences through the failure of control measures and the effect of other events. © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-31 Exam Skills QUESTION This is the first example of a 20 mark, Section B question for you to work on. It is split into three sub-questions and is based on a scenario. You should allow 30 minutes to answer a Section B question in the exam. Question An employer wishes to build a new gas compression installation to provide energy for its manufacturing processes. An explosion in the installation could affect the public and a nearby railway line. In view of this the employer has been told that a qualitative risk assessment for the new installation may not be adequate and that some aspects of the risk require a quantitative risk assessment. (a) Explain the terms ‘qualitative risk assessment’ AND ‘quantitative risk assessment’. (b) Identify the external sources of information and advice that the employer could refer to when deciding whether the risk from the new installation is acceptable. (c) A preliminary part of the risk assessment process is to be a hazard and operability study. Describe the principles and methodology of a hazard and operability (HAZOP) study. (5) (5) (10) APPROACHING THE QUESTION At first sight this might seem like a complicated question, but don’t be put off by it as it isn’t as bad as it looks. HINTS AND TIPS I suggest that you re-read the appropriate sections of the element and think about the terms asked about in the question. This will help to get things clear in your mind. This question isn’t about chemical process safety (which is examined in Unit IC of the International Diploma), but about risk assessment techniques. As you write your answer make sure that you refer back to the scenario described in the question to ensure that your answer has the correct emphasis. Think about the marks available for the three parts of the question, and your timing. Put together an answer plan for part (a) of the question around the terms “qualitative” and “quantitative” risk assessment. Remember that there are only 5 marks available for this part so the Examiner is not looking for lots of information - just that you can show that you understand the terms and the differences between them. Part (b) requires a list of sources of guidance, so reference to national governmental enforcement agencies and international bodies would be appropriate here. Remember that part (c) refers to a HAZOP so the Examiner is looking for sources relating to how you conduct a HAZOP and decide on an acceptable level of risk. Part (c) is worth 10 marks so you need an answer plan that covers 10/12 points that you know about how a HAZOP is conducted in order to get full marks. Use bullet points and expand each point to show that you understand what you are saying. 4-32 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 Exam Skills SUGGESTED ANSWER OUTLINE This looks like a hard question, but remember that you can’t expect to find every question easy to answer. You need to accumulate marks from your stronger questions and then work on getting 50% in the other questions to spread your mark risk. HINTS AND TIPS You might get good marks for any or all of parts (a), (b) and (c) and they all count to your overall total so have a go. In part (a) the Examiner would have wanted you to explain the differences between the two terms, so make sure you get them the right way round or you lose all the marks here! The Examiner can set any questions based on the syllabus and related to the Learning Outcomes. Just because you don’t use a certain type of process does not mean that there won’t be a question on it. Remember that you are expected to show that you can apply your knowledge and understanding to both familiar and unfamiliar situations. • Qualitative: informed subjective judgments; needs good hazard identification process and looks at likelihood of hazards occurring and severity of their consequences. Can be number or ranked (High, Med, Low, etc.). • Quantitative: numerical, based on frequency/ probability of events happening and their consequence; an objective approach which relies on specific data or comparison with specific criteria. In part (b) the Examiner was concerned with the issue of tolerability, so the UK HSE’s publication “Reducing Risks, Protecting People” would be a great source to mention, as would be similar guidance which talks about tolerability. Other sources could be experts, consultants, other organisations with similar installations or design companies, as well as insurance companies. In part (c) you would need an understanding of how HAZOP studies operate, so you should mention identification of deviations from intended normal operation and that HAZOPs are best carried out at design stage of installation but can be used for modifications to processes/installations. HAZOP studies have a team leader; there has to be awareness of the scope of the study which is to be conducted by the team. The installation/process is broken down into key parts/elements (known as “nodes”); you need objective data and information to support the study. The study involves brainstorming and the use of guide words which are then applied methodically to each process parameter to form “deviations” from normal operating conditions. Examples of process parameters include flow, pressure, temperature and concentration, whereas guidewords include no, more, less and reverse. An example deviation would therefore be “less flow” or “more concentration”. You would need to mention that the study looks at possible causes and consequences of each deviation and will identify possible corrective actions. The study also needs to be documented and you can use a set format, which is then recorded and kept in the project file or H&S file. © RRC International Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks v2.1 | 4-33 Exam Skills POSSIBLE ANSWER BY EXAM CANDIDATE (a) The terms qualitative and quantitative refer to the way the risk assessments are conducted. Qualitative – as the word suggests this is a subjective approach to deciding on the level of risk; it looks at likelihood of incidents occurring and the severity of injury or damage to people or the environment from those incidents. It will be ranked and a typical approach is to rank them HIGH, MEDIUM or LOW risk. Quantitative – this is a numbers-based approach using data/frequencies of events happening and their consequence and is used more formally for higher risk applications, as it is an objective approach to assessing the risk. (b) An employer could consult, externally, consultants who are experts in the installation/topic, industry guidance, manufacturers of the equipment to find out failure rates and types of incidents; insurance providers will also be able to put employers into contact with advice and guidance and support the employer with information. The HSE, the OSHA, the European Safety Agency, the ILO and the World Health Organisation are all good sources of information and their websites may have good guidance on reducing risks. (c) A hazard and operability study (HAZOP) is a formal type of risk assessment which follows a set format, with a study leader gathering a team of people, who would consist of supervisors, operators, maintenance staff, designers, H&S professionals, etc. The team will follow a checklist which looks at the plant operating parameters, such as flow, temperature and pressure, together with agreed guide words, e.g. no, more, less, part of and reverse. Each parameter is combined with each guide word to identify possible deviations from the designed operating conditions. The possible causes of the deviations are then discussed, together with possible controls to prevent such deviations. The process should take place at the design stage of new facility/plant or before modifications to existing take place. This study should have an action plan which should be managed to ensure the plant is designed safely; anything that needs operational controls should be identified and this information acted upon by the operational department. The study should be kept as part of the H&S file for the installation. HINTS AND TIPS In your part (b) answer do not be tempted to give more than four examples – you won’t gain any extra marks by giving five! REASONS FOR POOR MARKS ACHIEVED BY CANDIDATES IN EXAM This was not a popular question when it appeared on a Diploma paper (possibly people were scared off by the term HAZOP), but an exam candidate who did answer this question would achieve poor marks for: • Getting terms muddled up. • Not linking the parts of the question back to the scenario (a complex high-risk installation which needed a good understanding of risk and tolerability). • Not identifying relevant external sources of information for this complex installation. • Showing no real understanding of the HAZOP process. 4-34 | Unit IA – Element IA4: Identifying Hazards, Assessing and Evaluating Risks © RRC International v2.1 ELEMENT RISK CONTROL 5 LEARNING OUTCOMES On completion of this element, you should be able to demonstrate understanding of the content through the application of knowledge to familiar and unfamiliar situations and the critical analysis and evaluation of information presented in both quantitative and qualitative forms. In particular you should be able to: Outline common risk management strategies. factors to be taken into account when Outline selecting risk controls. © RRC International Explain the development, main features and operation of safe systems of work and permit-towork systems. Unit IA – Element IA5: Risk Control v2.1 | 5-1 Contents COMMON RISK MANAGEMENT STRATEGIES Concepts Within a Health and Safety Management Programme Selection of Optimum Solution Based on Relevant Risk Data Revision Question 5-3 5-3 5-6 5-7 FACTORS TO BE TAKEN INTO ACCOUNT WHEN SELECTING RISK CONTROLS General Principles of Prevention Categories of Control Measures General Hierarchy of Control Measures Factors Affecting Choice of Control Measures Cost-Benefit Analysis Revision Questions 5-8 5-8 5-10 5-10 5-11 5-11 5-13 SAFE SYSTEMS OF WORK AND PERMIT-TO-WORK SYSTEMS Safe Systems of Work Use of Risk Assessment in Developing and Implementing a Safe System of Work Permit-to-Work Systems Revision Questions 5-14 5-14 5-16 5-17 5-22 SUMMARY 5-23 EXAM SKILLS 5-24 5-2 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Common Risk Management Strategies KEY INFORMATION The key risk management strategies are: • Avoidance or elimination. • Reduction. • Transfer. • Retention with/without knowledge. CONCEPTS WITHIN A HEALTH AND SAFETY MANAGEMENT PROGRAMME Risk management may be defined as: The identification, measurement and economic control of the risks which threaten the assets or earnings of a company or enterprise. Risk control can be split into loss control and risk financing. • Loss control: –– Risk avoidance. –– Risk reduction. • Risk financing: –– Risk retention. –– Risk transfer. A strategy may consist of one, or a combination of these methods. Avoidance or Elimination • Risk avoidance is avoiding completely the activities giving rise to risk. For example, never travel by air to avoid the risk of being involved in a mid-air collision. • Risk elimination usually has a wider meaning; it implies removal of a risk without necessarily ceasing an activity completely, e.g. redesign of a process to remove a particular risk without stopping the activity. Risk avoidance or risk elimination is the best solution to the problem of risk. In some cases we will have estimated the risk of some particular operation to involve the possibility of a fatality or serious personal injury. This suggests that avoidance or elimination is an essential requirement. In eliminating one risk you could inadvertently introduce other risks. For example, in automating a process by introducing robots to eliminate, say, the risk of manual handling, you will introduce some of the risks associated with robots. Some hazards can be avoided by completing a task in a slightly different way. For example, providing a chair for a supermarket checkout person (rather than expecting them to stand) can remove hazards associated with physical fatigue. © RRC International Reduction Often avoidance or elimination may not be possible,or reasonably practicable, or even desirable (if, for example, it would involve closing a factory with the loss of all jobs and the high associated cost of redundancy). Risk reduction, while not as effective, might be a more economically viable solution. Unit IA – Element IA5: Risk Control v2.1 | 5-3 Common Risk Management Strategies Advantages of Risk Retention GLOSSARY RISK REDUCTION This is where risk is not avoided or eliminated entirely, but attempts are made to reduce the frequency and/or severity of a potential loss by use of typical safety control techniques such as engineering solutions to control risk at source, procedures and behavioural measures (training, etc.). Risk Retention Here the loss is to be financed from funds within the organisation, so we have to consider where the funds are to come from. Sources of Funds Possible sources are: • The full sum of insurance premiums is never paid out, so risk retention can be cheaper than insurance. The insurance company has to make a profit, both for future finance, and for its shareholders. A millionaire does not take out maximum insurance for his car; if it is damaged, he just buys another one. The good car driver or employer pays, through his premiums, for the poor driver or employer. Insurance is profitable for poor risk managers, but not for a good risk manager. • Retention reduces the cost both of processing claims and the detailed accounting required. The loss occurs and you just pay out. • If costs are allocated to departments, management becomes more risk conscious. This is a vital feature in risk management; it is pointless for a departmental manager to go all out for production profit and then have to use his or her profits to pay for accidents and losses. • Losses are dealt with quickly. • Pay losses from current operating funds. Payments should be restricted to a maximum of about 5% of the operating costs. Losses must be predictable. You should think about each advantage and see whether it applies to your organisation. • Use an unfunded reserve, such as depreciation. This is where some large item of capital expenditure is written off over a number of years. The problem is that the fund does not actually exist except as an accounting convenience. There is no tax advantage and no actual ready cash. With knowledge means you have made a conscious decision to bear the burden of losses; without knowledge means it is done without any consideration whether or not to insure. • Use a funded reserve, e.g. a fund of cash or easily obtained cash. It could be a group fund. There is no tax advantage. It takes time to build up such a reserve, so care is required in the early years. There is low interest on capital. If you wish to obtain a good rate of interest, you will have to give notice before you can withdraw funds. The fund needs to gain interest, but should be readily available when required. Risk Retention - With or Without Knowledge Every risk that is not transferred (to insurance) is a retained risk. Examples are: • Insuring through a captive insurer (see later). • Events which are insurable. You cannot get insurance for everything. The insurance company has to be able to assess risk, since they are in the business of risk management. They may quote a premium that is above the value you wish to insure. If you can buy a new item for the price of the premium, it is pointless to insure. Take the risk instead. • Borrowing to restore losses, which is not easy after a loss occurs. For example, if you had just had a large fire at the factory, the bank would be reluctant to lend and would make a lot of expensive conditions. • Losses not considered when setting up insurance - if you do not take into account a particular possibility, you are retaining the loss. It is a case of accidental risk retention, or risk retention by default. • Divert funds from planned capital investment; the company then uses funds set aside to buy an important capital item because there is a loss which has to be paid for. • Hazards deliberately not insured - risk management is all about taking a risk, where you have been able to reduce either the probability or the severity of a lossmaking event. If you consider each of these options, you will realise that there is no readily available, inexpensive source of finance to pay for any loss. On the other hand, there are some good reasons for considering risk retention. • Losses outside the scope of the insurance - there are always exclusion clauses, and you do not realise their significance until you need to make a claim. The good risk manager does not find himself or herself in such a situation. 5-4 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Common Risk Management Strategies • The part of the loss paid by the company (the excess) - you can get cheaper insurance if you agree to pay the first £x of any claim. • The part of the loss which is above the limits of the contract - there is often an upper limit to an insurance claim. The claimant pays if the loss exceeds that figure. • The person or company is unable to pay full compensation - obtaining the cheapest insurance cover may not be sound economy if your losses put them into bankruptcy. Risk Sharing Risk management is really a type of risk sharing and involves financing risks which are manageable and transferring those which are not. Methods include: • A deductible portion of excess - you pay the first part of each claim. • Re-insurance. Transfer involves transferring the risk to another party such as by insurance - the loss is financed from funds which originate outside the organisation. The second main way is to engage a contractor who will take on the risks. • Co-insurance - the insurer pays a percentage of the claim. This is another way of reducing a premium. You share the risk with the insurer by paying not only an excess but a percentage of the losses which fall within a certain price range; paying another percentage of those in another range; and the insurer paying all losses above a set figure. Insurance An Important Point How can you reduce insurance premiums? One way is to retain losses; another way is to accept a voluntary excess on insurance premiums and control losses. A good risk manager will make his greatest savings in the area of insurance by: Advantages of insurance are that: • Considering very carefully those areas where the risk has significantly been reduced. Risk Transfer • The loss will be dealt with smoothly. There will be a few forms to fill in and enquiries, but the procedures are well known. • Not insuring where the risk has been eliminated. • Paying for the retained risks where it is cheaper than insuring. • The cash is available. The insurer can get hold of the funds quickly, though will perhaps not release them as quickly as you would like. • The insurer can provide advice. He is dealing with this type of problem all the time and can help you to decide what is best. Use of Specialist Contractors Sometimes the best way of avoiding a hazard is to make use of specialist contractors, e.g. for the removal of asbestos. In this way the hazard is avoided by workers and the task is carried out professionally and in compliance with current legislation. A reputable company with suitably trained personnel and a good safety record should be used. © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-5 Common Risk Management Strategies SELECTION OF OPTIMUM SOLUTION BASED ON RELEVANT RISK DATA The selection of the optimum solution must take into account the type of organisation and the relevant risk data. The risk assessment will be a vital part of the exercise. If the probability is high and the severity is also high, then it will be important to do a great deal and spend a lot of finance to achieve a valid solution. If the probability or the severity is low, then it will not warrant too great an expenditure. Study the following table carefully: Probability Severity Action Definite High Eliminate Medium Fund (cheaper than insurance) Low No action - operating expense High Eliminate or reduce probability or severity Medium Reduce severity Low Retain as an operating expense High Reduce severity Medium Reduce severity or transfer High Medium Low Remote Low Retain as an operating expense High Fund or insure Medium Fund Low Retain as an operating expense Catastrophic Insure, or fold company High Fund, insure, or fold company Medium Fund or retain as an expense Low No action Other important factors include: • Present State of Technology With technology improving all the time new solutions become available; as computers have improved, the price of this technology has reduced. The safety practitioner must keep up to date with technology and consider how it could help the safety solutions. • Public Expectancy After a disaster a journalist often asks: “Can you guarantee that nothing like this will ever happen again?” Remember that human beings make mistakes, and no machine is infallible. Earthquakes occur without warning, and we can do little to control the effects of freak weather. 5-6 A major problem is that the general public is never realistic in assessing relative risk. Car accidents cause more deaths than public transport, but seldom hit the national headlines. Atomic energy is probably one of the safest power sources. Most deaths are from cancer, heart disease and stroke, and very few are from industrial causes. Most people would make a poor job of rating industries by their accident potential. • Legal Requirements ‘Learning by accident’ is a way of describing how safety legislation has developed over the years. Industrial accidents and disasters were the basic reason for the introduction of much of the existing safety legislation. Mines and factories were the cause of many fatalities while industry was developing, so legislation was enacted to control them. Now legislation tends to be more proactive, setting broad standards that have to be adhered to in order to control risk, rather than reactively responding to specific incidents. | Unit IA – Element IA5: Risk Control © RRC International v2.1 Common Risk Management Strategies • Economic State of the Company The economic state of the company is no excuse for not meeting legal standards - it can be used as a reason for not going for a higher standard. It is not good economic sense to skimp on safety, since all accidents produce a loss. However, a company with vast profits can afford to spend more than one with financial restraints. Companies’ economic goals will influence the approach to risk control. These may range from simple cost covering to survive, to profit maximisation. Risk management must balance the cost of controls against the estimated reduction in potential loss from risks. • Levels of Insurance Premiums Premiums are set by the level of claims. The insurance company is in business to make a profit. Good companies pay their premiums and do not make claims; it is the bad companies who benefit from insurance. If the premiums are reasonable, it is better to take the precaution of insurance. However, if premiums become excessive, then it will be better to retain the risk. • Confidence of the Company in the Benefits of Risk Management and in the Competence of the Risk Manager A good company, with good control of risk, will opt to retain risk rather than insure or transfer the risk. As the situation and the confidence improve, there will be increased movement towards this method of solution. If the company is able to use a captive insurance company, there will be less reliance on outside risk transfer. • Human Factors Accidents and incidents have an associated direct cost but can also influence the culture of the organisation. Frequent loss-making events can have a bad effect on morale, which can lead to a reduction in efficiency and higher overall costs. Consequently, a wish to improve industrial relationships can influence the approach to risk control measures. REVISION QUESTION 1. What are the main risk management strategies? (Suggested Answer is at the end.) © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-7 Factors to be Taken Into Account When Selecting Risk Controls KEY INFORMATION • The following are well recognised general principles of risk prevention: –– Avoid risks. –– Evaluate. –– Combat at source. –– Adapt work to the individual - ergonomics. –– Adapt to technical progress. • Control measures may be classified as being technical, procedural or behavioural. • The choice of control measures adopted should take account of: –– Use in the long or short term. –– Applicability. –– Practicability. –– Cost. –– Effectiveness. –– Legal requirements. –– Competence/training needs. • Cost-benefit analysis is a useful tool to aid the decision-making process. GENERAL PRINCIPLES OF PREVENTION Having identified the risks, measured their effect upon the company, and developed some kind of priority, we then have to do something about them. In practice, we are probably doing each of these stages at the same time: • Recognise. • Measure. • Evaluate. • Control. • Monitor. • Review. 5-8 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Factors to be Taken Into Account When Selecting Risk Controls TOPIC FOCUS Preventive and Protective Measures There are some well recognised general principles of prevention: • Avoiding risks. Not using the material (e.g. toxic chemicals) or carrying out the activity (e.g. excavations) eliminates the need for control. • Evaluating the risks which cannot be avoided. Risk evaluation is an essential part of the risk assessment process. It is where the level of risk is compared against agreed risk criteria. This helps you decide on the most appropriate risk control options. • Combating the risks at source. Control the risk as close to the point of generation as possible to prevent its escape into the workplace (e.g. extract dust directly from a circular saw blade using LEV). • Adapting the work to the individual, especially as regards the design of workplaces, the choice of work equipment and the choice of working and production methods, with a view to alleviating monotonous work and work at a predetermined work-rate and to reducing their effect on health. The traditional approach has always been for the person to adapt to the machine or process. This measure requires the employer to carefully consider ergonomic principles and design the work to suit the person. • Adapting to technical progress. Many risks disappear from the workplace as better processes and methods are introduced. For example, the replacement of traditional machine tools by CNC (Computer Numerical Control) machines, primarily for production efficiency, also removes the need for manually adjusted guards on lathes and milling machines. • Replacing the dangerous with the non-dangerous or the less dangerous. This is always a key aim, and an example of this is the replacement of the metal-cased, hand-held mains electric drill by rechargeable, battery-operated, plastic-cased drills. • Developing a coherent overall prevention policy which covers technology, organisation of work, working conditions, social relationships and the influence of factors relating to the working environment. This embodies the principles of risk management and requires the employer to look at all aspects of the health and safety management system rather than simply concentrating on basic workplace precautions. • Giving collective protective measures priority over individual protective measures. A safe place of work should be the main priority rather than a safe person, so control of noise at source should be the aim rather than the issue of hearing protection. • Giving appropriate instructions to workers. © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-9 Factors to be Taken Into Account When Selecting Risk Controls CATEGORIES OF CONTROL MEASURES Control measures are often categorised into one of three different types. TOPIC FOCUS • Technical - the hazard is controlled or eliminated by designing a new machine or process, or by producing some guarding measure. Hierarchy of Control Measures • Procedural - such as a safe method of work, e.g. introducing permit-to-work systems as part of a safe system of work. • Behavioural - will involve education and training of operatives, putting up notices and signs, using protective equipment and generally making workers aware of the risks - changing the ‘safety culture’ of the organisation. GENERAL HIERARCHY OF CONTROL MEASURES In dealing with risks, we must establish an order of treatment. A quick Internet search will make you realise that there are a number of different hierarchies, many of which are very similar; some are specific to control of chemicals or machinery guarding. One such order of treatment is: One hierarchy of control measures (modified from that in Management of Occupational Health Risks in the Offshore Oil and Gas Industry) is: • Elimination Stop using the process, substance, or equipment, or use it in a different form. • Substitution Replace a toxic chemical with one that is not dangerous or less dangerous. Use less noisy pumps. • Engineered Controls Redesign of the process or equipment to eliminate the release of the hazard so that everyone is protected; enclosure or isolation of the process or use of equipment to capture the hazard at source and release it to a safe place, or dilution to minimise concentration of the hazard, e.g. acoustic enclosures, use of LEV. • Administrative Controls Design work procedures and work systems to limit exposure, e.g. limit work periods in hot environments, develop good housekeeping procedures. Controls may also include: use of signs, training in specific work methods, and supervision. • PPE (as a last resort) Respiratory protective equipment, gloves, etc. only protects the individual. 5-10 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Factors to be Taken Into Account When Selecting Risk Controls The items at the beginning of the list are often long-term objectives and are the responsibility of management. They are the most effective, but more costly to implement. The items towards the bottom of the list can be short term and quickly put into place, but are the least effective. It may be impossible or prohibitively expensive to eliminate a hazard in a practical situation. On the other hand, you will get very few marks in the examination if your solution to a practical situation is to issue a pair of gloves, or just suggest that a worker takes more care. Another example of a hierarchy that is sometimes quoted is: • Total elimination or avoidance of the risk at its source. • Reduction of the risk at its source. • Contain the risk by enclosure of some kind. Effectiveness of Controls No one control measure can be 100% effective, so when evaluating which measure to adopt you have to take into account its effectiveness. PPE is of limited benefit because it only protects the person wearing it and not necessarily all those at risk. It may be uncomfortable or inconvenient to wear. The more effective the control, the greater consideration should be given to its use. Legal Requirements and Standards In some circumstances, legislation specifies the controls needed for a particular hazard. In these situations any selected control measure will have to meet these standards as a minimum. Competence of Personnel and Training Needs • Remove the worker from the risk. • Reduce the worker’s exposure to the risk. Clearly the control measures adopted for a specific situation must be such that the user is competent to use them without them creating a risk to the worker concerned or others. This may mean additional training and supervision which are an added cost. • Use personal protective equipment. • Train the worker in safe techniques. • Make safety rules, or issue instructions. • Tell the worker to be careful. FACTORS AFFECTING CHOICE OF CONTROL MEASURES Long Term/Short Term, Applicability and Costs Those points which appear earlier in the list of control measures will be the most effective in reducing the risk, but are usually the more expensive and take much longer to put in place, so can be viewed as long-term objectives. Although, in practice, it might be technically possible to achieve total elimination of a hazard, the costs involved and the benefits achieved may mean that it does not pass the test of “reasonably practicable”. Many of the improvements in safety standards have been due to the reduction in manpower and increasing mechanisation. Computers can be used to control many operations and eliminate the use of people in risky situations. However, they cannot think, and sometimes the choice is not between right and wrong (1 and 0 to a computer) but between the lesser of two wrongs. COST-BENEFIT ANALYSIS There are costs involved with all accidents and losses. There will also be costs involved with accident prevention and risk reduction, in addition to the obvious benefits of such measures. It is possible to spend more on risk treatment than we save by the reduction of the losses. This is why part of risk management is the idea of risk retention. The methods shown lower in the list of control measures are usually the cheaper options. They can be put into operation quickly, and give some measure of risk reduction, but their effect is of short duration. PPE, although near the bottom of the hierarchy, may be acceptable for nonfrequent exposure, such as in maintenance tasks. © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-11 Factors to be Taken Into Account When Selecting Risk Controls The cost-benefit graph is illustrated below. Cost-benefit graph This graph shows the position where there is maximum benefit. Cost-benefit analysis is a conceptually simple tool for helping you make a decision as to whether a particular course of action or project is in fact viable or cost effective. So, if you are thinking about upgrading risk control measures, you will probably need to justify the request for funding with the aid of a cost-benefit analysis. In its simplest form, it is an entirely economic argument (rather than a moral or legal one). It is an essential, persuasive tool for the safety practitioner because not only is it systematic and simple, but it is also commonly used and understood by business people. For this reason, using the UK as an example, any proposed new regulations are almost always accompanied by a regulatory impact assessment, which contains a cost-benefit analysis to assess the financial impact of the proposals on UK businesses. In the case of regulatory impact assessments, costs may outweigh the benefits for certain industries but, if the proposals become law, the requirements will still have to be implemented. In principle, you simply add up all the benefits associated with a programme and then subtract all the costs. In practice, there are a number of complications: • Not all costs and benefits can be assigned a reasonably accurate financial value. Though we know that intangible concepts such as ‘reputation’, ‘public/shareholder perception’, ‘worker morale’, and ‘worker co-operation and involvement’ may have an impact on efficiency, productivity, shareholder investment and sales, their value cannot be fully quantified financially - though it may be possible to suggest an estimate. 5-12 • Benefits may not be seen immediately. It may take several years to achieve sufficient benefits to ‘break even’. This is known as a payback period. This includes the benefits of reduction in civil liability claims and reductions (or no trend of further rises) in employers’ liability insurance premiums. • Some costs and benefits are one-off, others are recurring. For example, if your project required the purchase of a new piece of machinery, there is the initial one-off cost of the machine itself, installation, commissioning and any specific training. There are also the annual on-going running costs, such as energy, maintenance, testing, etc. For ‘software’ projects, such as implementing a safety management system or a behavioural safety programme, you may need to hire extra staff to manage and administer the system, as well as incur costs associated with annual external audits/ recertifications. We have already looked at some typical sources of costs in relation to health and safety accidents. Benefits can be along similar lines (removing a current source of cost is, of course, a future saving, i.e. a benefit of implementing a risk control measure). | Unit IA – Element IA5: Risk Control © RRC International v2.1 Factors to be Taken Into Account When Selecting Risk Controls Benefits may arise from issues such as: • Projected reduction in accidents, with associated savings from less time off and fewer investigations, etc. • Projected reduction in civil claims. • Projected reduction in insurance premiums (or bucking the trend of increases due to repeated claims). • Increased productivity (i.e. reduced cost per unit). This may seem difficult to quantify. However, think about how much time might be saved and translate this to man-hours. This will give an indication of how much time, and therefore money, may be saved. There is obviously a cost implication from controlling any kind of risk. Costs from implementing safety improvement measures (some of which may have ongoing as well as one-off costs) can arise from the following areas: You must be prepared to provide and justify estimates of the benefits that you perceive. You will need to analyse your annual accident statistics and consult with your human resources, legal and finance departments to arrive at estimates for some of these benefits. • Organisational These are the costs of any new personnel (salary and training) or perhaps making greater use of an existing resource required to implement and maintain risk control measures. There will also be costs associated with disruption to normal working (temporary staff to cover workers being trained or overtime). Initially, you should try to stick to costs and benefits for which you can provide plausible estimates. The more intangible elements for which no financial estimate can be agreed are of more persuasive value. Once you have estimated costs and benefits, you can calculate a projected payback or break-even point. The shorter this is the better, of course, but some projects are more long term. Even so, do not expect to be greeted with enthusiasm if your projected payback period is much over three years; short payback periods are much more attractive to senior management. • Design Reduction of accidents will involve engineering aspects, such as the purchase, fabrication and installation of safety devices, other equipment and any associated software. Safety systems need to be designed, and programmes for recording and costing losses will have to be tried out. Costs may also arise from lost production and sales, perhaps due to plant shut-down while equipment is being installed. • Planning New safe methods of work, permit-to-work schemes and factory layouts could be considered here. • Operational Consideration must be given to the costs of running and maintaining safety systems, maintaining guards, interlocks and software (support, licence renewals), providing PPE as well as carrying out sampling and testing. REVISION QUESTIONS 2. List the factors that should be considered when choosing control measures. 3. Give three reasons why cost-benefit analysis is not as simple as adding up all the benefits of a health and safety programme and subtracting the costs. (Suggested Answers are at the end.) © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-13 Safe Systems of Work and Permit-to-Work Systems KEY INFORMATION • A safe system of work is devised from a risk assessment of the task. • The following need to be considered when devising a safe system of work: –– People. –– Equipment. –– Materials. –– Environment. • A permit to work is a formal written document of authority to undertake a specific procedure and is designed to protect personnel working in especially hazardous areas or activities. It details the: –– –– –– –– –– Task. Significant hazards. Control measures to be used before work starts and during work. Checks to establish normal work can resume. Persons authorised to undertake the task and those responsible for monitoring it. SAFE SYSTEMS OF WORK GLOSSARY SAFE SYSTEM OF WORK A safe system of work is one where the work is organised in a logical and methodical manner so as to remove the hazards or minimise the risks and can be defined as follows: A good working definition is that from the UK HSE leaflet, INDG76L, Safe Systems of Work: “A safe system of work is a formal procedure which results from systematic examination of a task in order to identify all the hazards. It defines safe methods to ensure that hazards are eliminated or risks minimised.” Legal and Practical Requirements For example, Article 10 of the ILO Occupational Safety and Health Recommendation (R164) states the following obligation on employers: “to provide and maintain workplaces, machinery and equipment, and use work methods, which are as safe and without risk to health as is reasonably practicable”. Copyright © International Labour Organisation 1981 The term “reasonably practicable” occurs quite often in ILO documents. It is used in a number of legislative systems throughout the world to qualify legal duties. You may already be familiar with its meaning. It generally implies that you can take account of the cost (in terms of time, money or trouble) in proportion to the magnitude of the risk in deciding whether you have done enough, or should do more to control the risk. So if the risk is insignificant in proportion to the effort required to reduce it, then you wouldn’t normally be expected to take further action. It is important to realise that we are not talking about absolute cost here; it is the cost in relation to the risk. So, big risks would necessarily entail considerably more effort. In some countries (like the UK) there is an explicit legal requirement to maintain systems of work that are safe. Article 7 of the ILO Safety and Health in Mines Convention (C176) explicitly mentions the use of safe systems of work. Even if it is not an explicit legal requirement in your country, it is almost certainly strongly implied. 5-14 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Safe Systems of Work and Permit-to-Work Systems Practical Requirements In developing a practical safe working system, adequate provision must be made for: • Safe design of plant and equipment. • Safe installation of plant and machinery. • Safe maintenance of plant, equipment and premises. • Safe use of plant, equipment and tools, through proper training and supervision. • Documented, planned maintenance procedures. • Safe working environment (ventilation, heat and light). • Adequate and competent supervision. Job safety training is also an integral part of the safe working system; there must be a basic commitment to provide high standards of safety training for all operatives, new entrants, line managers and the safety practitioner and safety representatives. When is a Safe System Required? • Trained and competent workers. • Proper enforcement of the safety policy and associated rules. • Adequate personal protection for vulnerable workers. • Documented procedures for the issue of protective clothing. • Dissemination of health and safety information to all the workers. • Regular reviews (not less than once a year) of all job safety instructions and methods of work to ensure that: –– –– –– –– –– –– –– Safe systems of work should fully identify and document all the hazards, safety precautions and safe working practices associated with all activities performed by workers. The analysis should be capable of identifying any unsafe work methods. There must also be a system of monitoring safety performance and for publishing information about such performance. There is continued compliance with legislation. Plant modifications are taken into account. Substituted materials are taken into account. New work methods are incorporated. Systems still work safely in practice. Advances in new technology are exploited. Safety precautions are adjusted to take into account accident experience. Many hazards are clearly recognisable and can be overcome by physically separating people from them, e.g. by using guarding on machinery. A safe system of work is needed when hazards cannot be physically eliminated and some element of risk remains. You should apply these principles to routine work as well as to more special cases such as: • Cleaning and maintenance operations. • Making changes to work layouts, materials used or working methods. • Employees working away from base or working alone. • Breakdowns or emergencies. • Controlling activities of contractors on your premises. • Loading, unloading and movement of vehicles. Components of a Safe System of Work A safe system of work constitutes the bringing together of: • People. • Equipment. • Materials. • Environment. Systems of work must have a logical, well thought-out approach when compared with methods of working, which often merely evolve over time. In a system of work, there is a logical progression, from hazard identification and prediction, so that such hazards are eliminated or controlled. There should be a safe system of working for a lone worker © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-15 Safe Systems of Work and Permit-to-Work Systems USE OF RISK ASSESSMENT IN DEVELOPING AND IMPLEMENTING A SAFE SYSTEM OF WORK Systematic methodologies such as task (or hazard) analysis can be used to develop a safe system of work. One method is to use the following four-step approach. Analysing the Task - Identifying the Hazards and Assessing the Risks Assess all aspects of the task and the risks which it presents, considering hazards to health as well as to safety. Take account of: • What is used, e.g. the plant and substances, potential failures of machinery, toxic hazards, electrical hazards, design limits, risk of inadvertently operating automatic controls. • Who does what, e.g. delegation, training, foreseeable human errors, short cuts, ability to cope in an emergency. • Where the task is carried out, e.g. hazards in the workplace, problems caused by weather conditions or lighting, hazards from adjacent areas or contractors, etc. • How the task is done, e.g. the procedures, potential failures in work methods, lack of foresight of infrequent events. Involve the people who will be doing the work. Their practical knowledge of problems can help avoid unusual risks and prevent false assumptions being made at this stage. In those special cases where a permit-to-work system is necessary, there should be a properly documented procedure. We shall look at permits to work in detail later in this element. Instructing and Training People in the Operation of the System Your safe system of work must be communicated properly, understood by employees and applied correctly. They should be aware of your commitment to reduce accidents by using safe systems of work. Ensure that supervisors know they should implement and maintain those systems of work and that employees, supervisors and managers are all trained in the necessary skills and are fully aware of potential risks and the precautions they must adopt. Stress the need to avoid short cuts. It should be part of a system of work to stop work when faced with an unexpected problem until a safe solution can be found. Monitoring and Reviewing the System Monitoring and reviewing involves periodically checking that: Where possible, you should eliminate the hazards and reduce the risks before you rely upon a safe system of work. • Workers continue to find the system workable. Introducing Controls and Formulating Procedures • Any changes in circumstances which require alterations to the system of work are taken into account and implemented. • The procedures laid down in your system of work are being carried out and are effective. Control selection may be from the range we identified earlier (technical, procedural, behavioural), taking account of the application hierarchy and the general principles of prevention. Your safe system of work may include verbal instructions, a simple written procedure or, in exceptional cases, a formal permit-to-work scheme. Other matters include: • Consider the preparation and authorisation needed at the start of the job. • Ensure clear planning of job sequences. • Specify safe work methods. • Include means of access and escape if relevant. • Consider the tasks of dismantling, disposal, etc. at the end of the job. 5-16 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Safe Systems of Work and Permit-to-Work Systems PERMIT-TO-WORK SYSTEMS TOPIC FOCUS GLOSSARY A permit to work has four main sections: PERMIT TO WORK A formal written document of authority to undertake a specific procedure, designed to protect personnel working in hazardous areas or activities. Permits are used for high-risk activities that require complex precautions and clear communication of additional controls. They are also frequently used where operations are non-routine, or if new hazards are introduced and require communication. MORE… The UK HSE’s booklet HSG250 Guidance on permit-to-work systems – A guide for the petroleum, chemical and allied industries contains useful guidance in this area and is recommended reading. You can access it at: www.hse.gov.uk/pubns/priced/hsg250.pdf Need for Permit-to-Work Systems In many cases, it is impossible, or extremely unrealistic, to eliminate a risk totally. Even when the risk has been reduced, we are left with no alternative but to train someone in the skill to recognise the risks involved, and the knowledge of how to minimise them; and then, in effect, say: “Be careful”. A procedural way of taking every precaution possible is to have a permit-to-work system. Permit-to-work systems are only as good as those who design, implement and monitor them and so may be relatively easy to defeat. • Issue – the controls that must be implemented for the work to take place are defined. The permit is issued by an authorised person. • Receipt – the workers sign onto the permit to signal that they accept the conditions of the permit and understand the hazards and control measures detailed in it. • Clearance/Return to service – once the work is complete, the workers sign to say they have finished and are leaving the jobsite to allow normal work to resume, usually also indicating whether the work is complete or not. • Cancellation – control of the work area is accepted back by the issuer and the permit is cancelled. Extensions may be granted if additional time is required to complete the work. Permit-to-work systems are only as good as those who design, implement and monitor them and so may be relatively easy to defeat. When designing a permit-to-work system it is essential that the company culture is established to support the system. For a permit system to be worthwhile, there needs to be an appropriate level of detail within the system, as well as a commitment to train permit-issuers and ensure that only authorised persons issue the permit. It must also be accepted that a good permit will take a little time to issue. Let us look at a permit-to-work system as an example of a systematic means of controlling risk. Whenever maintenance or other temporary work of a potentially hazardous nature is to be carried out within the plant, some sort of permit-to-work system is essential. Jobs likely to require a permit-to-work system include: • Working in confined spaces. HINTS AND TIPS Do not mistake a “permit-to-work system” for a “safe system of work”. Rather, a safe system of work may require a permit-to-work system to be adopted as part of its overall systematic control of risk. The safe system of work should in itself be considered as part of the quality control procedures of an organisation. © RRC International • Hot work on plant containing flammable dusts, liquids, gases or their residues. • Cutting into pipework containing hazardous substances. • Work on electrical equipment. Most accidents can be attributed in one way or another to human error. To achieve a high degree of safety we have to eliminate human error as much as possible by using a system which requires formal action. Permit-towork systems try to ensure that formal action is taken by providing a written and signed statement to the effect that all the necessary actions have been taken. The permit must be in the possession of the person in charge of the operation before work begins. Unit IA – Element IA5: Risk Control v2.1 | 5-17 Safe Systems of Work and Permit-to-Work Systems Ideally, the control of permit-to-work systems throughout the company should be the overall responsibility of one person. That person should appreciate the existence of hazards and know how to eliminate them. He/she must have the necessary authority to instruct responsible people in the organisation to make safety recommendations on matters requiring their specialist knowledge. The person responsible must also have authority to co-ordinate the efforts of everyone concerned with the provision of safe working conditions. If a permit is issued, he or she must make sure that everyone involved understands the terms of the permit and follows its instructions down to the smallest detail. Initial Steps Before work begins, the following general safety precautions should be observed where applicable: • Electrical or mechanical isolation of the plant. • Isolation of the machine or equipment area. • Locking or blanking off of water, steam, acid, gas, solvent, and compressed air supplies. • Erection of scaffolding. • Provision of temporary guards (or other like equipment) to make the job safe. These provisions should be extended to any outside contractors taking part and it must be made clear that their workers must not in any circumstances begin work until the safety precautions and procedures have been fully explained to them. Cutting with an oxyacetylene torch requires a permit to work Essential Features of a Permit-to-Work System Permits should: • Define the work to be done. • Say how to make the work area safe. • Identify any remaining hazards and the precautions to be taken. • Describe checks to be carried out before normal work can be resumed. • Name the person responsible for controlling the job. 5-18 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Safe Systems of Work and Permit-to-Work Systems Details of Permit Form Design The permit to work should include the following basic elements: 1. Permit title 2. Permit number Reference to other relevant permits or isolation certificates. 3 Job location. 4. Plant identification. 5. Description of work to be done and its limitations. 6. Hazard identification - including residual hazards and hazards introduced by the work. 7. Precautions necessary. Person(s) who carries out precautions, e.g. isolations, should sign that precautions have been taken. 8. Protective equipment. 9. Authorisation. Signature confirming that isolations have been made, and precautions taken, except those which can only be taken during the work. Date and time duration of the permit. 10. Acceptance. Signature confirming understanding of work to be done, hazards involved and precautions required. Also confirming permit information has been explained to all workers involved. 11. Extension/shift hand-over procedures. Signatures confirming checks made that plant remains safe to be worked upon, and new acceptor/workers made fully aware of hazards and precautions. New time expiry given. 12. Hand-back. Signed by acceptor certifying work completed. Signed by issuer certifying work completed and plant ready for testing and recommissioning. 13. Cancellation. Certifying work tested and plant satisfactorily recommissioned. A Formal Document The permit to work is always based on a formal document, the format and details of which will vary according to circumstances (see following example). In addition to the safeguards outlined above, the specific safety precautions to be taken should be itemised. The document should be valid only for a limited period depending on the nature of the work and associated hazards. © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-19 Safe Systems of Work and Permit-to-Work Systems HEPWORTH BUILDING PRODUCTS LIMITED PERMIT TO WORK 1. ISSUE To In the employ of For the following work to be carried out: I hereby declare that it is safe to work on the following apparatus and that the safety measures detailed below have been carried out. Here state apparatus on which it is safe to work ALL OTHER PARTS ARE DANGEROUS Here state exactly at what points isolating steam, water, air, gas valves, or radioactive shutters have been shut and locked off and what motors have been locked off and isolated. Signed Being the Senior Authorised Person Date Time Note: After being signed for the work to proceed, the receipt must be signed by, and The Permit retained by the person in charge of the work until the work is suspended or completed. RECEIPT 2. I hereby declare that I understand that the plant specified on this permit is safe to work upon and that this Permit applies to this plant only. Signed being the person in charge of the work on the apparatus upon which it is safe to work Date Time Note: The apparatus mentioned must not be recommissioned until this clearance has been signed and The Permit returned by the person in charge of the work and cancelled. 3. CLEARANCE I hereby declare that all men under my charge have been withdrawn and warned that it is no longer safe to work on the apparatus specified in this permit and that all gear and tools are clear and that all guards have been replaced. Signed Being the person in charge of the work Time Date 4. CANCELLATION I hereby declare that this Permit and all copies of it are cancelled. Signed Being the Senior Authorised Person Time Date 5-20 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Safe Systems of Work and Permit-to-Work Systems All the methods to be used and precautions to be taken should be: • Carefully discussed and agreed beforehand. • Clearly stated on the permit. The number of permits issued should be kept to the minimum required for conducive to the efficient manning of the plant. Basic Principles of Operation TOPIC FOCUS Certain principles need to be observed for the operation of an effective permit-to-work system. • Hazard Evaluation This involves recognising every type of hazard which may be encountered, and then working out the means of eliminating or overcoming them. The best way of doing this in the long term is by introducing a hazard appraisal programme, which can be used to formulate a long-lasting system of precautions. A major problem may be that work is often performed under emergency conditions and there is little time available for a detailed appraisal to be made. • Precaution Planning All planning associated with the permit must be carried out by a competent person who should have sufficient detailed knowledge of the hazards of the process or plant so that he can formulate the plan properly. The person must have the necessary position of authority for his or her instructions to be recognised and complied with. He/ she should also have an adequate knowledge of the legal requirements, and of technical terms such as ‘isolate’, ‘lock off’, and ‘blank off’, as they apply to the permit-to-work system. • Instructing the Supervisors Those people responsible for the work should be carefully briefed by the person issuing the permit. The instructions in the permit must be fully understood, and this is best achieved by direct questions and answers to supplement the written word. • Issuing the Permit The permit, which should be completed and signed by the issuer, must be given to the person in charge of the work (who signs for it). Sufficient copies must also be given to plant or site management and supervisory staff who may be involved, especially where they need to be kept informed of work progress. An additional copy of the permit should be exhibited nearby during the time it remains in force. • Monitoring the Permit A permit-to-work system is only as good as the people who design, implement and monitor its application and so can be easy to defeat. Monitoring is therefore a crucial element. The initial explosion and resulting fire in the Piper Alpha disaster of 1988 in the North Sea was caused by poor adherence to a permit-to-work system. Regular monitoring is essential to ensure: –– Full and accurate completion of the documentation, including signing off. –– That the safe work practices specified in the permit are complied with. © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-21 Safe Systems of Work and Permit-to-Work Systems General Application Radiation Hazards Here are some examples of the types of hazardous situations in which permit-to-work systems should be used. Work with radiation may require that a permit-to-work system is operated to prevent the ingestion, inhalation, or other absorption of radioactive material into the body. There is a general duty on employers to restrict the exposure of workers and other people who could be affected by contamination. Restriction of exposure is achieved by engineering controls, design and safety features. Electrical Equipment and Supplies There is considerable evidence that the hazards associated with electricity are either not understood, or are treated in too casual a manner. Because of the high level of risk involved and the serious consequence of switching errors and other careless mistakes, it is essential that a comprehensive safety system is put into operation whenever work is to be started on high voltage equipment. Any work on substation equipment must be covered by a permit-to-work system if safe working conditions are to be ensured and any electrical work should only be carried out by a qualified electrician. Confined Spaces Work in confined spaces introduces risks such as asphyxiation from gas, fume, or vapour and the necessary precautions should be included in the permit to work. Machinery The biggest risk to maintenance workers is that they may be injured if machinery is started up while work is in progress. This is often because the men carrying out the maintenance work are hidden from the sight of persons at the plant controls. The machines may be started as a result of some misunderstanding, negligence, or lack of knowledge and, unless the motive power is isolated and cannot be reconnected without specific authority, an accident might easily occur. Sewer entry would be considered confined space entry Overhead Travelling Cranes If a person is working on or near the crane track, he is likely to be struck by the crane if effective measures are not taken to ensure that the crane cannot approach too close to the working place. In such circumstances a permit-towork system is the only real safeguard. Chemical Plant Under normal operating conditions, chemical plant is designed to work safely. During maintenance, repair or sometimes commissioning conditions, however, hazards may be introduced, or work may have to be carried out which could expose the workers to danger unless carefully planned safety procedures are adopted. Each job would have to be considered individually, because the hazards likely to be encountered (involving flammable, toxic and corrosive liquids or gases, and explosive atmospheres) vary considerably. Formulating a permit-to-work system in a chemical plant demands a wide technical knowledge and a high degree of authority on the part of the person issuing the permit. It is likely, therefore, that only a few specialist managers will possess the necessary competence. REVISION QUESTIONS 4. Explain how risk assessment should be used to develop a safe system of work. 5. What is a permit to work? (Suggested Answers are at the end.) 5-22 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Summary SUMMARY Common Risk Management Strategies We identified and discussed: • Avoidance or elimination. • Reduction. • Transfer. • Retention with/without knowledge. Factors to be Taken Into Account When Selecting Risk Controls Control measures can be considered using the following principles: • Avoid risks. • Evaluate. • Combat at source. • Adapt work to the individual - ergonomics. • Adapt to technical progress. Control measures may be classified as being technical, procedural or behavioural. The choice of control measures adopted should take account of: • Use in the long or short term. • Applicability. • Practicability. • Cost. • Effectiveness. • Legal requirements. • Competence/training needs. Cost-benefit analysis involves ensuring that the cost of risk management is not disproportionate to the savings by reduction of losses. Costs of controlling risks include: organisational, design, planning, and operational costs. Safe Systems of Work and Permit-to-Work Systems We considered the following in terms of safe systems of work: • A safe system of work is one where the work is organised to remove hazards and minimise risks. • It should proceed logically from identification to elimination of risks. • A safe system of work is needed where hazards cannot be physically eliminated. • Four steps to identifying a safe system of work: –– Analyse the task - identifying hazards and assessing risks. –– Introduce controls and formulate procedures. –– Instruct and train people in the operation of the system. –– Monitor and review. A permit to work is a formal written document of authority to undertake a specific procedure and is designed to protect personnel working in hazardous areas or activities. Permit-to-work systems do not replace safe systems of work; they try to ensure that formal action is taken to eliminate human error. © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-23 Exam Skills QUESTION The last question you attempted looked daunting but hopefully you will feel more confident at tackling this one. Here we will have a look at another of the short answer, compulsory 10 mark questions. Remember that with these Section A questions you have no choice. You need to average 50% across the six compulsory questions to give yourself a great chance of passing the exam. Most students find that there are questions they find easy to answer and others where their knowledge is weaker. You need to develop your skills and knowledge to raise your marks in your weaker questions, so make sure you have a go at all of them. Question A maintenance worker was asphyxiated when working in an empty fuel tank. A subsequent investigation found that the worker had been operating without a permit to work. (a) Outline why a permit to work would be considered necessary in these circumstances. (b) Outline the possible reasons why the permit-to-work procedure was not followed on this occasion. (3) (7) APPROACHING THE QUESTION SUGGESTED ANSWER OUTLINE Note that your answer to this question will need to show a logical progression of ideas and both sections require an outline; think about the marks on offer for both parts of the question. (a) A permit to work would be considered necessary in these circumstances because: –– Risk assessment of the work identified its need. –– It is a high risk task in a confined space. –– Additional hazards might develop as the work progresses therefore the job needs a structured approach. –– A permit to work for this type of work could be a legal or national requirement. (b) Possible reasons why the permit-to-work procedure was not followed on this occasion include: –– There was no permit-to-work system available. –– The initial risk assessment was inadequate and therefore the potential hazards were not fully understood or identified. –– The organisation had a poor health and safety culture and therefore violations of work systems and permits to work were routine. –– The permit system was thought to be too bureaucratic and complicated. –– There was pressure to complete the work quickly and following the permit prevented this. –– There was difficulty organising controls before starting work due to lack of a competent person to authorise the permit. –– The controls to be followed were not clear or specific. –– Management failed to stress the importance of using a permit in such circumstances and did not communicate this to workers. 5-24 | Unit IA – Element IA5: Risk Control © RRC International v2.1 Exam Skills POSSIBLE ANSWER BY EXAM CANDIDATE (a) A risk assessment of the job could have identified the need for a permit to work. The work is in a confined space therefore a permit would be needed. (b) The permit system was too complicated and prevented the job being finished quickly. The control measures needed were not described clearly or specifically and were difficult to organise. There was no competent person to authorise the permit. Management did not stress the importance of using a permit for this type of work or had not even introduced a permit-to-work system. REASONS FOR POOR MARKS ACHIEVED BY CANDIDATES IN EXAM An exam candidate answering this question would achieve poor marks for: • Outlining what should be included in a permit to work rather than why it was necessary for the circumstances given. • Simply listing the operations where a permit would be required rather than outlining its need. • Listing possibilities for the permit not to be followed instead of giving a fuller outline with reasons. © RRC International Unit IA – Element IA5: Risk Control v2.1 | 5-25 v2.1 ELEMENT ORGANISATIONAL FACTORS 6 LEARNING OUTCOMES On completion of this element, you should be able to demonstrate understanding of the content through the application of knowledge to familiar and unfamiliar situations and the critical analysis and evaluation of information presented in both quantitative and qualitative forms. In particular you should be able to: Explain the internal and external influences on health and safety in an organisation. the different types of organisation, Outline their structure, function and the concept of the organisation as a system. Identify the various categories of third parties in a workplace, the relevant duties, responsibilities and controls. the role, influences on and procedures for Explain formal and informal consultation with employees in the workplace. the development of a health and safety Outline management information system, the relevant duties and the data it should contain. Explain health and safety culture and climate. the factors which can both positively and Outline negatively affect health and safety culture and climate. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-1 Contents INTERNAL AND EXTERNAL INFLUENCES Internal Influences on Health and Safety Within an Organisation External Influences on Health and Safety Within an Organisation Revision Questions 6-3 6-3 6-5 6-6 TYPES OF ORGANISATIONS Concept of the Organisation as a System Organisational Structures and Functions Organisational Goals and Those of the Individual: Potential Conflict Revision Question 6-7 6-7 6-7 6-11 6-12 THIRD PARTY CONTROL Integration of Goals of the Organisation with the Needs of the Individual Identification of Third Parties Reasons for Ensuring Third Parties are Covered by Health and Safety Management Systems Basic Duties Owed To and By Third Parties Selection, Appointment and Control of Contractors Responsibilities for Control of Risk Associated with Contractors on Site Revision Questions 6-12 6-12 6-13 6-13 6-14 6-15 6-16 6-16 CONSULTATION WITH WORKERS Provision of Information Relating to Hazards/Risks to Third Parties Role of Consultation Within the Workplace Formal Consultation Informal Consultation Role of the Health and Safety Practitioner in the Consultative Process Behavioural Aspects Associated with Consultation Development of Positive Consultative Processes Revision Questions 6-16 6-16 6-17 6-18 6-19 6-20 6-20 6-21 6-22 HEALTH AND SAFETY MANAGEMENT INFORMATION SYSTEM Health and Safety Management Information Systems Within the Workplace Types of Data Within a Health and Safety Management Information System Requirements and Practical Arrangements for Providing Health and Safety Information Revision Questions 6-23 6-23 6-24 6-25 6-25 HEALTH AND SAFETY CULTURE AND CLIMATE Culture and Climate Impact of Organisational Cultural Factors on Individual Behaviour Indicators of Culture Correlation Between Health and Safety Culture/Climate and Health and Safety Performance Measurement of the Culture and Climate Revision Questions 6-26 6-26 6-27 6-28 6-28 6-28 6-30 FACTORS AFFECTING HEALTH AND SAFETY CULTURE AND CLIMATE Promoting a Positive Health and Safety Culture Factors that May Promote a Negative Health and Safety Culture or Climate Effecting Cultural or Climate Change Problems and Pitfalls Relating to Change Revision Questions 6-31 6-31 6-32 6-33 6-35 6-35 SUMMARY 6-36 EXAM SKILLS 6-38 6-2 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Internal and External Influences KEY INFORMATION • The key internal influences on health and safety are: –– Finance. –– Production targets. –– Trade unions. –– Organisational goals and culture. • The key external influences are: –– –– –– –– –– –– –– –– Legislation. Enforcement agencies. Courts and tribunals. Contracts. Clients and contractors. Trade unions. Insurance companies. Public opinion. INTERNAL INFLUENCES ON HEALTH AND SAFETY WITHIN AN ORGANISATION • Pay incentive bonuses to increase the daily rate of production. Finance • Reduce the quality of the goods by using inferior materials. Health and safety costs money to administer, but it costs considerably more if you don’t invest in health and safety (remember Elements IA1 – costs of accidents, and IA5 – cost-benefit analysis). Annual budgets are set which allow you to plan. Be careful that the safety budget is not diverted to more ‘urgent’ projects. In difficult years, money available for hiring resources, maintaining safety equipment/systems and safety improvements is more limited (especially if the benefits are not immediate). Some things will just not get done which will inevitably lead to accidents/ill health which will lead to yet more costs. Small companies may fail as a result of a compensation claim arising from just one accident. Production Targets Achieving production goals can put intense pressures on workers leading to stress and an increase in incidents and accidents in the workplace. It is recognised that increased competition, longer hours, increased workloads, new technology and new work patterns are significant occupational stressors. Industrial psychology also requires that in a ‘conveyor-type’ operation, the speed of the belt should be geared to the capacity of the slowest operator. The pressures on management to achieve production targets/increase production can be translated into action on the shop-floor in a number of ways: Apart from increasing the size of the workforce, these measures encourage workers to ‘cut corners’. For example: • Longer hours can lead to tiredness and less attention to safety factors. • Bonuses for increased production can lead to disregard for any safe systems of work which slow down the speed at which the worker can operate. • Increased production targets may create anxiety in the slower worker, especially if part of a team, and can lead to short-cuts being taken in an effort to keep up with colleagues. • Reducing quality may require new systems of work, leading to stress. All of these can lead to unsafe acts which may have considerable effect on the company’s health, safety and accident record. • Make the workforce work longer hours. • Increase the size of the existing workforce. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-3 Internal and External Influences Trade Unions Trade union safety representatives may be involved as members of safety committees, and as such are actively involved in improving health and safety in the workplace. They have a dual role in that they can be involved in the formulation of policy in certain companies, but they also have a policing role in that they can monitor management’s performance. They carry out the following functions: • Investigating potential hazards and dangerous occurrences. • Examining the cause of accidents. • Investigating health and safety complaints from workers they represent. • Making representations to the employer on complaints, hazards and accidents. • Carrying out inspections of the workplace. • Consulting with enforcement agency inspectors on behalf of the workers they represent. • Receiving certain information from the enforcement agency inspector. In many workplaces, this type of representation is not restricted to trade union representatives, but has been widened to include elected workers who are not members of a trade union. Organisational Goals and Culture The goals and culture of the organisation strongly characterise the company. Some organisations rate safety highly and treat it seriously, not only in what they claim to do (their safety policy), but also in what actually happens in practice. Safety culture can be simply described as “the way we do things”. If you have worked for several different organisations you will probably recognise different cultures in terms of what they accept and tolerate. We will look at this topic in more detail later in this element. 6-4 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Internal and External Influences EXTERNAL INFLUENCES ON HEALTH AND SAFETY WITHIN AN ORGANISATION Enforcement Agencies Courts/Tribunals Insurance Companies Contracts/Contractors/Clients The Organisation Legislation Trade Unions Public Opinion External influences on the organisation Legislation Contracts/Contractors/Clients Any company or officers of a company ignore legislation at their peril. Changes in legislation are well-publicised in relevant journals and any health and safety adviser should ensure that he/she is aware of any pending changes and their effect on the company. The nature of contracts and relationships with contractors may have profound effects on the health and safety of a particular contract. Contracts must, of course, be honoured and be fair (they are usually enforceable through the courts). Contractors may expose the company to many additional hazards and liabilities (and vice versa). In those circumstances where a contractor feels that he is making a loss on a particular job, there may be a strong temptation to cut corners and perhaps compromise health and safety. Where a client takes a direct interest in the progress of a contract and in achieving good standards of health and safety, the standards on site are positively improved. There is a need for effective vetting of contractors’ own company health and safety competence before awarding the contract to them. Tribunals/Courts Court decisions clearly have a direct effect on the company concerned, but may also create precedents that are legally binding on all companies in similar circumstances. Enforcement Agencies In some countries there may be enforcement agencies for local legislation who can influence health and safety within companies by: • Providing advice on general legal requirements. • Serving enforcement notices in cases of specific legal contraventions. • Prosecuting employers for serious breaches of the law. Trade Unions Trade unions are active in many countries promoting standards of health and safety in a variety of ways: • Supporting their members’ legal actions and setting precedents and standards. • Acting through lobby and pressure groups to influence legislation. • Carrying out and sponsoring research. • Publicising health and safety matters and court decisions. • Providing courses on health and safety subjects. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-5 Internal and External Influences Insurance Companies In many countries, employers are legally required to carry insurance to cover claims for workplace injury/ill health from their workers. Should a company suffer an unusually high accident rate, the insurance company can either increase their insurance premiums, or insist that the company adopt risk reduction measures. It is now more common for insurance companies to carry out their own inspections of workplace risks and set certain minimum standards. Public Opinion Public opinion can have a powerful effect on legislators, which may result in legislation being passed, or prosecution taking place. Other actions may involve a particular company’s products being deliberately boycotted by consumers because of the company’s behaviour, or other more direct forms of action by protesting consumer groups. REVISION QUESTIONS 1. List some of the internal influences on an organisation in respect of health and safety at work. 2. List some external bodies which can influence health and safety standards of organisations, identifying the means by which each body exerts its influence. (Suggested Answers are at the end.) 6-6 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Types of Organisations KEY INFORMATION • An organisation may be considered to be a system that has interacting components forming a whole. • Within an organisation there are both formal and informal structures. • Conflict may arise as a result of individual goals not being consistent with those of the organisation. CONCEPT OF THE ORGANISATION AS A SYSTEM ORGANISATIONAL STRUCTURES AND FUNCTIONS GLOSSARY GLOSSARY SYSTEM ORGANISATION A regularly interacting or interdependent group of items forming a united whole. A group of persons who interact with each other in an effort to achieve certain predetermined goals or objectives. (Note: This is one of several definitions which can be applied to “systems”.) The systems approach to management is a way of thinking in which the organisation is viewed as an integrated complex of interdependent parts that are capable of sensitive and accurate interaction among themselves and within their environment. Common characteristics of systems are that: • Every system is part of a still larger system and, itself, encompasses many subsystems (‘circles within circles’). • Every system has a specific purpose to which all its parts are designed to contribute. • A system is complex - any change in one variable will effect change in others. • Equilibrium: a system strives to maintain balance between the various pressures affecting it, internal and external. Some systems experience more pressures to change than others, giving rise to stable and unstable systems. Initial reaction to pressure is often what is called dynamic conservatism - the organisation fights like mad to stay just as it is! However, sooner or later homeostasis takes place (activities which serve to stabilise and vitalise the organisation as a whole in an evolving state of dynamic equilibrium). © RRC International At a very basic level, the worker goes to work to earn money. The earning of money is a specific goal common to everyone in that particular organisation. There will be many other shared goals and objectives. There will also be many goals which are not shared, which lead to conflict, and which, ultimately, may have a bearing on the success or failure of the organisation. A work organisation is an organisation which has been established for a specific purpose and within which work is carried out on a regular basis by paid workers. Examples of such are: businesses, hospitals, educational institutions, government departments, etc. Formal and Informal Structures All organisations have a formal and informal structure. Within each organisation there is a formal allocation of work roles and the administrative procedures necessary to control and integrate work activities. However, organisations also have an informal arrangement or power structure based on the behaviour of workers how they behave towards each other and how they react to management instructions. The foreman or supervisor will have specific instructions from management aimed at achieving certain goals or production targets. In many cases, he ‘adjusts’ those instructions in accordance with his personal relationships with individual, or groups of, workers. This takes us some way towards being able to make a distinction between formal and informal organisations. There is a blurring at the edges between the two - a cross-over point where the distinction between the formal and informal at the actual point of action becomes obscured and is the subject of a great deal of sociological argument and discussion. For our purposes, we can describe or explain them in the following way. Unit IA – Element IA6: Organisational Factors v2.1 | 6-7 Types of Organisations • Formal Organisational Structure Most organisations describe their structure in the form of an organogram. This shows the reporting relationships from the chief executive of the company down to the workers carrying out the most basic tasks. The following figure illustrates a typical formal structure for a small company. DIRECTOR SALES MANAGER PRODUCTION DIRECTOR SALES STAFF PRODUCTION EMPLOYEES QUALITY MANAGER FINANCE DIRECTOR ACCOUNTS STAFF Formal structure In theory, every person within the structure has a well-defined role with clear lines of reporting and clear instructions as to standards of performance. These roles are clearly understood by others in the organisation so that everyone acts together to achieve the organisational objectives. • Informal Organisational Structure An organisational chart cannot identify all the interactions which occur between staff. Invariably, it will be the quality of personal relationships which determines how communications flow within a company and ‘how things get done’. In most organisations, the formal structure represents the model for interaction, but in reality the informal relationship is significant in understanding how organisations work. The informal structure cannot replace the formal structure, but works within it. It can influence relationships and effectiveness in both positive and negative ways. An understanding of it is an invaluable aid to good management. Take another look at the Formal Structure figure and then compare it with the Informal Structure figure that follows. Look at the superimposed informal structure shown by the dotted lines. 6-8 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Types of Organisations ER H ET OG FT DIRECTOR BR OT OL YG LA P SALES MANAGER HE WENT TO SAME SCHOOL PRODUCTION DIRECTOR QUALITY MANAGER RS -IN -LA W FINANCE DIRECTOR AT UNIVERSITY TOGETHER SALES STAFF PRODUCTION ACCOUNTS STAFF EMPLOYEES MEMBERS OF COMPANY SOCCER TEAM Informal structure An awareness of these informal relationships would obviously influence how communications are made. The effective manager will use such knowledge to break down resistance to new measures (including health and safety). A simple way of making a distinction between formal and informal organisation structure is: • Formal - represented by the company organisation chart, the distribution of legitimate authority, written management rules and procedures, job descriptions, etc. • Informal - represented by individual and group behaviour. Organisation Charts The structure of an organisation is determined by its general activities - its size, location, business interests, customer base, etc. and by the way in which its workers are organised. The organisational pyramid (Formal Structure) illustrated earlier is probably the principal model for most organisations with management at its apex and the workforce at its base. Within this model each separate department has its own pyramid with its own power structure and departmental goals. If the organisation is very large then considerable problems involving communication, efficiency, effectiveness, etc. may occur. The following figures show two typical pyramids. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-9 Types of Organisations Board of Directors Head Office Departments Accounts Company Secretary Administration Marketing Sales Production Human Resources Typical company pyramid HEALTH AND SAFETY DIRECTOR Security Manager Health and Safety Manager Assistant Security Manager Occupational Health Nurse Security Officers Typical departmental pyramid By looking at these structures you can see the formal levels of authority and responsibility within the organisation or department. Basically, authority or control runs from top to bottom. However, there are other important management/worker relationships, such as line management, staff, and functional relationships. 6-10 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Types of Organisations Role of Management Functional Relationship GLOSSARY MANAGE AND MANAGEMENT To manage is “to organise, regulate and be in charge of a business…”, and management is “those engaged in these functions”. Management will lead through issued instructions, policies and procedures, and supervision to ensure that these are being adhered to. There is normally a line of responsibility with different functions at each level. Line Management Look at the following figure: In many larger organisations, certain members of staff have a company-wide remit to carry out activities ‘across the board’. Human resources departments often implement company appraisal plans which affect every department; internal auditors visit all departments to carry out their work; and quality control inspectors and health and safety managers have a company-wide role in order to inspect and check procedures. In such circumstances, any defects discovered would normally be dealt with by reporting them to the departmental head rather than dealing directly with any individual within the department. The various hierarchies and line, staff and functional relationships can create huge problems for any organisation. Office ‘politics’ and protocols often obstruct communication, which is one of the key factors in efficient management. Small Businesses Works Director These are organisations with up to 50 workers. A feature of such organisations is the necessity (certainly in those with few workers) for those employed to adopt several roles. Small businesses are far less likely to have a dedicated health and safety professional than a large organisation; the role is often taken on by an individual who combines the responsibility with other tasks. Works Manager Foreman Chargehand ORGANISATIONAL GOALS AND THOSE OF THE INDIVIDUAL: POTENTIAL CONFLICT Shop-Floor Operative A typical line management function Here you can see a direct line of authority from the Works Director to the Shop-Floor Operative. GLOSSARY GOAL In this context, a goal can be defined as “an object of effort or ambition”. Staff Relationship The managing director’s secretary reports to the Managing Director (MD) and carries out instructions by passing the MD’s wishes to other directors and senior heads of department, but there is no ‘line’ relationship between the secretary and those departments. There is no instruction from the secretary, as her/his authority stems from the MD. A health and safety consultant reporting directly to an MD is not in a position to ‘instruct’ heads of departments to carry out health and safety policies or instructions. Again, his/her authority stems from the MD and, in practice, he/she would advise heads of department of any changes in policy agreed with and authorised by the MD. © RRC International To be successful and progress, both an organisation and individuals have to have goals. For the organisation, the goal may be an objective to be the “best in their field”, or to be the “largest”, or to be renowned for “outstanding quality”. For the organisation to achieve these goals the workers need to have their own goals and objectives to work towards the organisational goal. However, the individual may have other goals which may or may not impact on the organisation. For example, an individual may hope to be promoted, which would probably mean that they will work very hard to achieve their goals/objectives within the organisation, as this should help them to achieve their own personal goal of promotion. Another individual, however, may want to work less hours, or have more time with their family, and this may impact negatively on their willingness to put in extra hours which may be required for the organisation to achieve its goal. Unit IA – Element IA6: Organisational Factors v2.1 | 6-11 Types of Organisations INTEGRATION OF GOALS OF THE ORGANISATION WITH THE NEEDS OF THE INDIVIDUAL In setting and achieving health and safety targets, the organisation should consider the needs of the individual. Where health and safety tasks are delegated, at all levels from senior managers to shop-floor workers, the responsible individual(s) should be clearly identified and stated. This gives ownership to the individual concerned, and is an important factor in getting the individual to ‘buy in’ to the organisation’s goals. Many organisations give responsibility without the relevant authority - this can be a mistake as, without authority, the individual can feel frustrated at being unable to carry out the tasks. This leads to a feeling of futility and results in tasks being done poorly or not at all. Where authority is given to enable the individual to carry out tasks, this can result in an increase in self-esteem and every chance that the tasks will be performed well. The limits of responsibility and authority should be clearly defined so that individuals know the extent of what they can and cannot do. With responsibility comes accountability, and this must be made clear to all individuals given health and safety responsibilities. One important issue when giving responsibility is to ensure that the individual is capable of accepting it. REVISION QUESTION 3. What is the difference between a formal and informal organisational structure? (Suggested Answer is at the end.) 6-12 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Third Party Control KEY INFORMATION • Third parties include contractors, visitors, trespassers and members of the public. • There are legal, moral and economic reasons for ensuring that third parties are covered by health and safety management systems. • Basic duties owed to and by third parties include those of: –– Designers, manufacturers and suppliers to customers/users. –– Occupiers of premises/land to visitors. –– Contractors to clients and vice versa. • To ensure that the contractor chosen is capable of doing the work required safely, it is necessary to introduce procedures for the selection, appointment and control of contractors. • The responsibility for control of risk associated with contractors on site is shared, the client being responsible for the workplace, environment and their workers and the contractor being responsible for the job and their workers. • It is important to provide information relating to hazards/risks to third parties such as contractors, visitors and the general public. IDENTIFICATION OF THIRD PARTIES A third party is defined as: “someone other than the principals who are involved in a transaction”. In this case, it means anyone other than the employer, worker or owner who may be affected by the safety of a workplace. GLOSSARY CONTRACTOR “One who is engaged to perform a certain task without direction from the person employing him.” VISITORS AND TRESPASSERS Visitors are literally third parties who visit premises or land. Many visitors will either be explicitly invited or have an implicit right to be there. However, a trespasser is someone who has no invitation or consent of any kind (explicit or implicit); in fact their presence is strongly objected to. MEMBERS OF THE PUBLIC Members of the public are not workers or contractors, but may become visitors or trespassers if they enter the premises. Notice how a person can move from one category to another quite easily depending on the circumstances. © RRC International REASONS FOR ENSURING THIRD PARTIES ARE COVERED BY HEALTH AND SAFETY MANAGEMENT SYSTEMS In terms of potential legal requirements, the ILO Occupational Safety and Health Convention C155 (Article 17) states: “Whenever two or more undertakings engage in activities simultaneously at one workplace, they shall collaborate in applying the requirements of this Convention.” Copyright © International Labour Organisation 1981 The accompanying Recommendation R164 (Article 11) states: “Whenever two or more undertakings engage in activities simultaneously at one workplace, they should collaborate in applying the provisions regarding occupational safety and health and the working environment, without prejudice to the responsibility of each undertaking for the health and safety of its employees. In appropriate cases, the competent authority or authorities should prescribe general procedures for this collaboration. “ Copyright © International Labour Organisation 1981 So, both of these imply that account is taken of third parties who happen to be working on the same premises. This invariably will involve the exchange of information (on hazards, etc.), as well as the co-ordination of emergency arrangements and sharing of procedures. Unit IA – Element IA6: Organisational Factors v2.1 | 6-13 Third Party Control This collaboration requirement is repeated in some of the sector-specific conventions, such as the Safety and Health in Construction Convention C167 (Article 8), together with its Recommendation R175 (Article 5). Even if your country has not ratified the above ILO convention, you may have equivalent requirements. It is quite clear that there is a moral imperative which ‘obliges’ us to look after other people, but because of the complexities of modern society, we often now have legislation which provides standards by which we look after the physical well-being of our neighbours - the young, the elderly, the disadvantaged - physically and mentally, and the visitor who may enter our premises and workplaces completely oblivious to the hazards which may lurk there. Apart from moral and legal obligations to third parties, there is another consideration, and that is the economic factor. What are the economic implications of neglect of health and safety in the workplace? We have already looked briefly at the hidden costs of accidents. Economic considerations are twofold. Accidents resulting from poor health and safety management result in huge financial losses to everyone concerned. Poor health and safety management is often itself caused by the serious lack of economic resources available for health and safety purposes both at national and workplace levels. It is not a difficult management exercise to compare the costs of preventing accidents with the costs arising from them (compensation, lost production, increased insurance premiums, overtime, legal fees, fines, etc.) but the simple logic appears to escape many boardrooms. Prevention of accidents and ill health is a worthwhile investment which attracts enormous dividends both for the individual employer and the national economy as a whole. BASIC DUTIES OWED TO AND BY THIRD PARTIES You may be familiar with the concept of “duty of care to your neighbour”. This is quite a common principle in civil law, even without a specific contract between parties. It arises from the moral/ethical duty not to cause injury/ damage through negligent (i.e. careless) acts/omissions. The type of civil action that might arise is called “the tort of negligence” (a “tort” is a civil wrong). Designers, Manufacturers, Suppliers to Customers/Users This duty is usually in relation to machinery and dangerous substances for use at work. The duty in relation to machinery usually encompasses design and construction (as safe as possible), testing to ensure that they are in fact reasonably safe, and provision of information to users on safe use. For example, Article 12 of the ILO Safety and Health Convention (C155), places a duty on national governments to create laws which ensure that designers/ manufacturers of machinery, equipment and substances do just that. Occupiers of Premises/Land to Visitors Many countries have established a common duty of care of an occupier to all lawful visitors (remember the earlier definition of “visitor”). The duty is essentially to take reasonable care to see that the visitor will be reasonably safe in using the premises for the purposes for which they are invited or permitted by the occupier to be there. The duty is usually in respect of dangers due to both the state of the premises, as well as any acts or omissions. It is also common for this duty (albeit in a qualified, lesser form) to be extended to trespassers (i.e. those who have no invitation or permission to be there). Generally, the occupier must be prepared for children to be less careful than adults. If the occupier allows a child to enter premises then the premises must be reasonably safe for a child of that age. The occupier must be aware of any lure or attraction to children, such as a pond, that could constitute a trap. It is generally accepted that there may be special risks associated with certain types of work undertaken by the visitor. In such cases, an occupier may expect that a person, in doing their job, will appreciate and guard against any special risks related to it, e.g. if the occupier invites a competent electrician to do some work, and due to the carelessness of the contractor he or she is electrocuted, then the occupier would not generally be liable. It is common that an occupier can try to discharge at least some of his duty of care by displaying a warning notice, but it is not usually enough on its own. Indeed, signs may be of little use to protect children or the visually impaired. Earlier, we also looked at Article 17 of C155, the ILO Occupational Safety and Health Convention, and also Article 11 of the associated Recommendation R164. These contained a general duty to collaborate where two or more employers engage simultaneously in activities at the same workplace. If your country has ratified the convention, these requirements will be enshrined in law. We will now consider some specific examples of relationships which illustrate typical duties owed to and by third parties. 6-14 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Third Party Control Contractors to Clients (and Vice Versa) Choosing a Contractor It has long been held that professional people owe a duty of care to their clients, but under the “neighbour” concept, the reverse is also true. This implies co-ordination/ collaboration of activities and exchange of essential information that might affect the health and safety of respective workers (which we have already mentioned in relation to Article 17 of the ILO Safety and Health Convention). This is especially true for the client to provide information on any special site hazards. The ILO code of practice on Construction Safety and Health also identifies the responsibility of the client to ensure that contractors consider the cost of adequate health and safety provision for the construction project when tendering for the job, i.e. there is a responsibility not to just choose contractors based on “lowest bid”, and there is again an implication that information on specific site hazards is communicated to the contractor so that he is able to take account of them when counting the cost of safety at the tender stage. The client should also ensure that the contractor is allowed sufficient time for the job, in consideration of health and safety (i.e. don’t set unrealistic deadlines which would compromise safety). There is also an implied duty (frequently enshrined in law) for clients to make reasonable “due diligence” efforts to ensure that the contractor that they engage is actually competent to do the job, and a reciprocal duty on the contractor (as on any employer/self-employed person) to ensure that his workers are competent to do the job. • Determine what technical and safety competence is required by the contractor. • Ask the contractor to supply evidence of that competence. • Supply information regarding the job and the site, including site rules and emergency procedures. • Ask the contractor to provide a safety method statement outlining how they will carry out the job safely. Contractors Working on Site • Introduce a signing in and out procedure. • Ensure the contractor provides a named site contact. • Carry out site induction training for all contractor workers. • Where necessary, control activities by using a permitto-work system. Checking on Performance • Are contractors working to agreed safety standards? • Have there been any incidents and were they reported? • Have there been any changes of circumstance, e.g. change of personnel? SELECTION, APPOINTMENT AND CONTROL OF CONTRACTORS To ensure that a chosen contractor is capable of doing the work required safely, you need to introduce procedures that will identify and cover key points. The following lists suggest an approach that covers all aspects of contractor hire (adapted from UK HSE Guidance HSG159, Managing Contractors). The Planning Stage • Define the task(s) that the contractor is required to carry out. • Identify foreseeable hazards and assess the risks from those hazards. • Introduce suitable control measures to eliminate or reduce those risks. • Lay down health and safety conditions specific to the tasks. • Involve the potential contractors in discussions concerning the health and safety requirements. • Agree realistic timescales for the work. A client’s project manager monitors the work of a contractor Review • Regularly review the procedures to ensure currency and effectiveness. Always remember that contractor work can impact on workers and vice versa. The passing on of information regarding work that may affect others is a vital part of safe working with contractors. • Ensure accident and first-aid procedures and arrangements are in place. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-15 Third Party Control RESPONSIBILITIES FOR CONTROL OF RISK ASSOCIATED WITH CONTRACTORS ON SITE It is clear that there is a general duty to ensure that all reasonably practicable measures are taken by clients (i.e. those who engage contractors) and people in charge of premises to reduce the risk to contractors and vice versa. It is probably fair to say that the responsibility for risk control is shared - the client being responsible for the workplace, environment and their workers; the contractor being responsible for the job and their workers, BUT there will be many areas of overlap (indeed the terms of the engagement contract should help clarify major responsibilities). Tight procedures are required to ensure all possibilities are addressed. This type of shared responsibility is exemplified by the provision of site welfare facilities. The client is often responsible for ensuring that adequate management arrangements are in place for the provision of site welfare facilities. The contractor is responsible for ensuring that welfare facilities are provided and that adequate site induction is given. • General Public Information to the general public will include such things as notices and warnings on perimeter fences, gates, etc. Road works and other activities that impact on the general public, as well as requiring prominent signage, may be publicised in local newspapers and prework notices erected at the site. MORE… You can find further information on contractor management in the UK HSE publication Using contractors - A brief guide (INDG368) that you can download from: www.hse.gov.uk/ PROVISION OF INFORMATION RELATING TO HAZARDS/RISKS TO THIRD PARTIES The provision of information to third parties relating to hazards and risks is important. • Contractors We have already looked at the duty to collaborate on health and safety matters contained within the Occupational Safety and Health Convention. This will necessarily involve exchange of relevant information (on hazards, risk assessments, method statements, procedures, etc.). Many items may be specifically identified in the contract between the two parties. • Visitors It is usual to give visitors to the workplace written information on emergency procedures, often in the form of a small card or on a visitors’ slip. Think about where the visitor is going and what the purpose of their visit is. It may be necessary to supplement the general information with other, more specific, information relating to their particular situation. 6-16 REVISION QUESTIONS 4. Outline the legal reasons for ensuring that third parties are covered by health and safety management systems. 5. What are the economic implications of neglect of health and safety in the workplace? (Suggested Answers are at the end.) | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Consultation with Workers KEY INFORMATION • Successful health and safety management depends on a workforce that is committed to health and safety and which co-operates with the employer. ILO Occupational Safety and Health Convention (C155), Article 20, and ILO Occupational Safety and Health Recommendation (R164) lay down useful principles regarding consultation in the workplace. • Formal consultation will involve worker representatives on health and safety and the safety committee. • Informal consultation relies on discussion groups, safety circles and departmental meetings. • The health and safety practitioner has a substantial role to play in the consultative process. • Behavioural aspects associated with consultation include peer group pressures and identification of potential areas of conflict. • Positive consultation is based on a willingness of employer and worker to consider problems together, to make use of each other’s knowledge. ROLE OF CONSULTATION WITHIN THE WORKPLACE Successful health and safety management depends on a workforce that is committed to health and safety and which co-operates with the employer. The following is from the ILO Encyclopaedia article Consultation and Information on Health and Safety (Part III, Chapter 21). “The idea of employers and employees working jointly to improve health and safety at work is based on several principles: 1. Workers can contribute to prevention of industrial accidents by spotting and warning about potential hazards and giving notice of imminent dangers. 2. Involving employees educates and motivates them to co-operate in the promotion of safety. 3. Ideas and experiences of workers are regarded as a useful contribution to safety improvement. 4. People have a right to be involved in decisions that affect their working life, particularly their health and well-being. 5. Co-operation between the two sides of industry, essential to improve working conditions, should be based on an equal partnership.” In terms of international standards offered for adoption as national laws, the ILO Occupational Safety and Health Convention 1981 (C155), Article 20, states the basic approach: “Co-operation between management and workers and/or their representatives within the undertaking shall be an essential element of organisational and other measures taken in pursuance of Articles 16 to 19 of this Convention.” Copyright © International Labour Organisation 1981 This is supported directly by the associated R164 Occupational Safety and Health Recommendation (see especially Article 12). Also relevant are the ILO Co-operation at the Level of the Undertaking Recommendation (R94) and the ILO Communications within the Undertaking Recommendation (R129), which recommend consultation within the workplace. Copyright © International Labour Organisation 2011 There is general agreement that consultative and participatory arrangements have a direct effect on safety performance. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-17 Consultation with Employees FORMAL CONSULTATION You probably have formal consultation arrangements in your own workplace. These may even be mandated by local laws, e.g. implementing Article 19(a)-(e) of the ILO Safety and Health Convention: “There shall be arrangements at the level of the undertaking under which-(a) workers, in the course of performing their work, co-operate in the fulfilment by their employer of the obligations placed upon him; (b) representatives of workers in the undertaking cooperate with the employer in the field of occupational safety and health; (c) representatives of workers in an undertaking are given adequate information on measures taken by the employer to secure occupational safety and health and may consult their representative organisations about such information provided they do not disclose commercial secrets; (d) workers and their representatives in the undertaking are given appropriate training in occupational safety and health; (e) workers or their representatives and, as the case may be, their representative organisations in an undertaking, in accordance with national law and practice, are enabled to enquire into, and are consulted by the employer on, all aspects of occupational safety and health associated with their work; for this purpose technical advisers may, by mutual agreement, be brought in from outside the undertaking;” • Access to all parts of the workplace, workers, labour inspectors and health and safety specialists (as required). • Allowed reasonable time (paid) and given training to perform their functions. For some useful discussions on the role of safety representatives and safety committees, see the ILO training materials Introduction to Occupational Health and Safety, available from the ILO at: http://actrav.itcilo.org/actrav-english/telearn/osh/intro/ inmain.htm. The main role of representatives is to work actively to prevent worker exposure to occupational hazards. Typical activities include: • Workplace observations and inspections. • Examination of records. • Listening to complaints. • Reading information. • Asking members represented what they think. To support the role, representatives need to keep informed about their workplace hazards and possible control measures, and work in partnership with the union (if applicable, or otherwise the represented group) and the employer for hazard identification and control. Health and Safety Committees Copyright © International Labour Organisation 1981 Worker Representatives An approach to fulfilling the obligations under Article 20 of the Convention (see earlier) is suggested within the associated Recommendation R164 (Article 12). This involves the appointment of: • Workers’ safety delegates (often called “safety representatives”). • Workers’ safety and health committees and/or joint safety and health committees. Representatives should have the following functions, rights and entitlements: • Be given adequate information on health and safety matters. Consultation with workers Union Committees There are several types of health and safety committee, one being a local union committee. This has no employer involvement. According to the ILO training guide, the role of the local union committee is to: • Consulted (when major health and safety measures or changes to work with health and safety implications are planned). • Respond to worker concerns. • Protection from dismissal/prejudicial treatment. • Educate union members in health and safety. • Be able to contribute to the health and safety decisionmaking process/negotiations. • Help represent workers’ health and safety grievances to management. 6-18 • Initiate action on the hazards it recognises. | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Consultation with Employees In the absence of a joint worker-management safety committee, the local union committee would have to deal directly with management. Membership should have representation from all work areas and shifts (different unions should attempt to work together as a single committee). Members should be concerned about health and safety and want to learn more, and meetings should be held monthly. Typical activities of such committees would include: • Holding regular meetings to discuss issues brought to its attention by members, suggesting possible solutions and progress reports on issues being tackled. • Developing health and safety training programmes. • Researching specific health and safety issues to aid negotiations with management. • Accompanying government inspectors on workplace inspections. Joint Labour-Management Committees These involve management as well as workers. In terms of membership, generally there should be at least two worker representatives, selected with the agreement of the unions (where applicable), or possibly from the local union committee. Members should have an interest in health and safety and a desire to co-operate. It is suggested that equal numbers of workers and management should be on the committee. The management members should, as far as possible, have the authority to make the necessary decisions and to allocate resources. Typical activities of these committees would include: • Promoting health and safety in the workplace (including providing training). • Monitoring the workplace for hazards and legal compliance (including inspections). • Agreeing the health and safety policy and its implementation. INFORMAL CONSULTATION Informal consultation can be more effective than formal. There are numerous opportunities for discussion during workplace inspections, toolbox talks, induction training, safety audits and staff appraisals. Individuals may often express genuine personal feelings in a one-to-one situation, in a more open manner when free from peer group pressure. Discussion Groups and Safety Circles • Discussion groups consist of a group of individuals coming together to discuss issues of mutual interest. In the workplace, groups may be formed, often from volunteers, to deal with a number of issues both work and non-work related. They may be given certain remits, such as safety and quality. • Safety circles are small groups of workers - not safety representatives or members of safety committees who meet informally to discuss safety problems in their immediate working environment. The idea is based on the ‘quality circles’ concept and allows the sharing of ideas and the suggestion of solutions. Any insurmountable problem would be referred to the safety representative or safety committee. Departmental Meetings These meetings are normally attended by shop-floor representatives, supervisory and management staff who will meet frequently, often once a week, to discuss general matters affecting their department. Matters for discussion might include: shift patterns, maintenance and breakdown procedures, and production targets. It is difficult to discuss any of these without impinging on health and safety requirements and, although perhaps not a major objective of such meetings, health and safety policies and arrangements would come under examination. Again, any health and safety problems identified would probably be referred to senior management through the safety representative or safety committee. • Working with management to resolve health and safety problems/complaints. • Involvement in planning proposed changes that may impact on health and safety. • Keeping union members informed about planned actions. Informal consultation can take the form of departmental meetings © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-19 Consultation with Employees ROLE OF THE HEALTH AND SAFETY PRACTITIONER IN THE CONSULTATIVE PROCESS The term ‘safety professional’ covers such diverse staff as: safety advisers, occupational hygienists, doctors, nurses, safety managers, human resources managers, training officers, facilities managers, ergonomists, engineers and radiation protection advisers. The qualifications range from the highly qualified doctor to the human resources manager who has completed perhaps a non-examination, three-day, basic health and safety awareness course. The health and safety practitioner needs to be a person with a wide range of abilities and a recognised safety qualification at diploma or degree level with IOSH membership. In relation to the health and safety consultative process, health and safety practitioners have a substantial role to play. They are often the first contact for the employer or worker on health and safety matters. The safety practitioner maintains a number of relationships: • Within the Organisation –– The position of health and safety practitioners in the organisation is such that they support the provision of authoritative and independent advice. –– The post-holder has a direct reporting line to directors on matters of policy and authority to stop work which is being carried out in contravention of agreed standards and which puts people at risk of injury. –– Health and safety practitioners have responsibility for professional standards and systems and, on a large site, or in a group of companies, may also have line management responsibility for junior health and safety professionals. • Outside the Organisation Health and safety practitioners liaise with a wide range of outside bodies and individuals including: local government enforcement agencies; architects and consultants, etc.; the fire department; contractors; insurance companies; clients and customers; the public; equipment suppliers; the media; the police; medical practitioners; and hospital staff. This is a very wide brief and indicates that the safety practitioner requires a broad and extensive knowledge of health and safety matters in order to fulfil his duties. He is the organisation’s first contact when health and safety problems are encountered, and will give advice on shortterm safety solutions to problems and follow this through with perhaps a recommendation for a change in policy or the introduction of new technology or new/revised safe systems of work. He will also recommend the services of outside expert consultants where the problem requires scientific, medical or technical advice which is outside his area of expertise. He may also be involved in safety committees in a chairing role or simply in an advisory capacity during committee deliberations. 6-20 BEHAVIOURAL ASPECTS ASSOCIATED WITH CONSULTATION In any social group, conflict may arise between two or more people, interest groups, genders, ethnic or racial groups, etc. Obviously where there are assemblies of people in the workplace, there may be conflict within and between groups. Safety committee member A serves on the committee to represent his department or perhaps a particular group of workers with common skills. Similarly, committee member B represents his department members. A and B, although sharing a common membership of the safety committee, may well be pursuing different objectives. They may both be seeking improved health and safety arrangements for their members but may be in competition for the allocation of limited resources to their particular project. Peer Group Pressures The safety representative serving on a safety committee may see his role as one in which he feels the need to question and destructively criticise, as a matter of course, any suggestion advanced from a management representative on the committee. Remember, however, that the safety representative is a worker’s representative and not part of the management team - neither is he necessarily “a competent person”. His perception of health and safety problems will be different from that of management and not constrained by budgeting considerations. His role is primarily a policing one in which he monitors the safety performance of management and, because of peer group pressure, he may see himself in a conflicting, rather than co-operative, role. Dangers of Tokenism Tokenism is an approach where management goes through the motion of consultation but has no real intention of taking on board the views expressed by employees. There is no strict obligation on the employer to implement suggestions from employees arising from the consultation process (unless there is a specific legal requirement), but the employer should respond positively to information gained during the consultation process. If proposals are seen to be rejected without justification, this is likely to generate general resentment and apathy towards the process, and have a detrimental effect on the health and safety culture. Potential Areas of Conflict The safety representative can sometimes see himself as an expert on health and safety matters, while management may take the view that their opinions are correct, simply because they are management and know better. Consultation about problems where the views of all the participants are considered should lead to a lessening of conflict, and arrival at effective decisions. | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Consultation with Employees DEVELOPMENT OF POSITIVE CONSULTATIVE PROCESSES GLOSSARY Contributions of Employee Representatives/Safety Committee Members We discussed the functions of safety representatives and committee members earlier. Employee representatives for health and safety: CONSULTATION • To seek advice or information. • Will have a basic health and safety knowledge (legislation, guarding, noise, etc.). • To consider in company. • To take counsel. • Need to be active in promoting and encouraging a health and safety culture amongst their colleagues: • To give or receive professional advice. • To confer with two or more in counsel. We all have one or more of those definitions in mind whenever we see the word “consultation”, but what about “positive consultation”? Some managements believe that informing the workforce after they have decided to introduce some new technology or downsize the company by means of a redundancy programme is “consultation”. This it is certainly not. Consultation means to discuss (with others) a given agenda and to give or receive information or advice about that agenda before taking any action or arriving at decisions about possible courses of action. Positive consultation is based on a willingness on both sides - employer and worker - to consider problems together, to make use of each other’s knowledge and expertise, and to apply that collective wisdom to the problem in hand. The emphasis in positive consultation must be on prior consultation followed by effective decision-making based on the collective expertise and knowledge drawn from both sides. Consultation is particularly necessary on such matters as: • The introduction of any new measure at a workplace that may substantially affect health and safety. • Arrangements for appointing competent persons to assist the employer with health and safety, and for implementing procedures relating to serious and imminent danger. • Any health and safety information that the employer is required to provide. • The planning and organisation of health and safety training, and health and safety implications of the introduction, or planned introduction, of any new technology. We have said that consultation, to be positive, has to be a “joint” and “prior to the event” enterprise. The above four points outline management’s role in the consultative process but the representatives themselves must be active in promoting and encouraging a health and safety culture among their colleagues. To do this they must keep themselves informed of developments in health and safety, encourage co-operation between workers and the employer in the promotion of any measures designed to improve health and safety in the workplace, and above all lead by example. © RRC International –– Keeping themselves informed of developments in health and safety. –– Encouraging co-operation between workers and the employer in the promotion of any measures designed to improve health and safety in the workplace. –– Leading by example. Safety committee members: • Will have some health and safety knowledge (but probably less than the representative). • Are likely to have a more reactive role than that of the representative (discussing reactive data such as accident reports/investigations). The safety committee has an important role in following up problems which have not been satisfactorily resolved by safety representative intervention. The normal chain of events would be: • Worker complains to line management - problem remains unresolved. • Safety representative complains to line management on worker’s behalf - problem remains unresolved. • Matter is referred to the safety committee: –– Matter resolved - no further action. –– Matter unresolved - referred to senior management by resolution of committee. Urgent health and safety matters must not be delayed until the next meeting of the safety committee but referred immediately to senior management by the safety representative. It is clear from these arrangements that the safety representative and safety committee member have complementary roles which, if followed correctly, contribute effectively to the good health and safety management of any organisation. Unit IA – Element IA6: Organisational Factors v2.1 | 6-21 Consultation with Employees REVISION QUESTIONS 6. Outline the main role of worker representatives on health and safety and their typical activities. 7. Outline the typical activities of a labourmanagement safety committee. 8. What is a safety circle? 9. What do you understand by the term “positive consultation”? (Suggested Answers are at the end.) 6-22 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Health and Safety Management Information System KEY INFORMATION • It is common in many regions of the world to find legal duties (either explicit or implied) to provide information to: –– Suppliers. –– Workers. –– Enforcement authorities. –– Temporary workers. –– Employment agencies. –– Contractors. –– Members of the public. –– Customers. • The basis of sound health and safety information management comprises the collection of information, its documentation and the provision of systems for cascading information to users. • A broad range of both internal and external information is needed for an effective health and safety management information system. This includes: –– –– –– –– Loss event data. Cost data. Suppliers’ data. Results of audits and inspections. HEALTH AND SAFETY MANAGEMENT INFORMATION SYSTEMS WITHIN THE WORKPLACE The following figure illustrates how external and internal health and safety materials are combined, processed and turned into user-friendly information for use by company workers and contractors, visitors, customers, etc. The basis of sound health and safety information management comprises: • The collection of information from external sources. • The documentation of policy, organisation statements, performance standards, rules and procedures (including risk assessments, audits, inspections, test results, and accident statistics, etc.). • Provision of systems for cascading information. • Use of posters, bulletins, newspapers, etc. The starting point in the development of the system is to appoint someone with the professional competence to manage it. In many organisations this might be an existing manager or a dedicated safety professional. Whoever he/she is, the safety manager must keep up to date with developments in legislation and current practice through membership of a professional association(s) and arrange for the collection and systematic documentation of relevant developments in health and safety. He/she should subscribe to a number of professional publications and attend courses and seminars to maintain “continuing professional development” status. He/she will also be responsible for the collection and documentation of internal health and safety information, the safety policy, risk assessments, test results, accident reports and statistics, and health surveillance. The safety practitioner must be able to interpret legislation, manufacturers’ instructions, and a variety of other technical or semi-legal documents. The information collected, both externally and internally, must then be used as a management tool for the efficient running of the organisation. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-23 Health and Safety Management Information System ORGANISATION Internal Information Sources External Information Sources H & S Information Process/ Retrieval System External End-User Internal End-User Internal and external health and safety materials TYPES OF DATA WITHIN A HEALTH AND SAFETY MANAGEMENT INFORMATION SYSTEM TOPIC FOCUS EXTERNAL INFORMATION SOURCES INTERNAL INFORMATION SOURCES Legislation, codes of practice and guidance. H and S policy document. National and international Standards. Compliance data. Manufacturers’ instructions. Cost data. Risk assessments. Guidance from safety and professional bodies, e.g. ILO, WHO, IOSH. Guidance from industrial bodies. Monitoring results: • Noise. • Dust. • Lighting. • Atmospheric, etc. Job descriptions. Job safety analyses. Results of inspections/audits. Accident and ill-health reports/statistics. Training records. Management system performance data. 6-24 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Health and Safety Management Information System Such health and safety information can be assimilated into the organisation and held centrally. The appropriate material can then be redistributed throughout the organisation, or to those departments which have a specific requirement. Information can be filed manually or stored electronically for ease of retrieval and copying. REQUIREMENTS AND PRACTICAL ARRANGEMENTS FOR PROVIDING HEALTH AND SAFETY INFORMATION We have already discussed some of this under “Third parties” earlier. It is common in many regions of the world to find legal duties (either explicit or implied) to provide information to, for example: • ILO Safety and Health in Construction Convention C167 Article 33 – provision of information to workers on health and safety hazards. • ILO Prevention of Major Industrial Accidents Convention C174 Article 9 – provision of information to authorities on potential accidents, etc. Article 16 - information to the local public from competent authority on action to take in case of major accident. • Workers. • Temporary workers. • Contractors. • Customers. • Suppliers. • Enforcement authorities. • Employment agencies. • Members of the public. In terms of global guidelines, the following ILO conventions and recommendations will help illustrate the point of explicit mention of information provision (though it is implied in many other areas too, such as “cooperation” and “consultation” touched on earlier): • ILO Occupational Health and Safety Convention C155 Article 19(c) – employers to provide health and safety information to worker representatives. • ILO Protocol of 2002 to the Occupational Health and Safety Convention P155 Articles 3(a)(ii) and 4(a)(ii) – provision of information to workers regarding accident reporting systems and notified accidents. • ILO Occupational Health and Safety Recommendation R164 Article 12(2) – provision of health and safety information to safety representatives/committees, etc. Article 14 – information on health and safety policy/ organisation/arrangements brought to attention of workers. • ILO Communications Within the Undertaking Recommendation R129 Article 2(2) – dissemination of information. REVISION QUESTIONS 10. Identify categories of people to whom information would normally be provided by your organisation. 11. List the external sources of health and safety information. 12. List the internal sources of health and safety information. (Suggested Answers are at the end.) © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-25 Health and Safety Culture and Climate KEY INFORMATION • Safety culture may be defined as “a system of shared values and beliefs about the importance of health and safety in the workplace”. • The safety climate is an assessment of people’s attitudes and perceptions at a given time. • Organisational factors, e.g. training, availability of suitable equipment, behaviour of managers, etc. influence individual behaviour. • There are many indicators of the health and safety culture of an organisation, e.g. housekeeping, relationships between managers and workers. • Safety culture and climate may be assessed by: –– Perception surveys. –– Findings of incident investigations. –– Effectiveness of communication. CULTURE AND CLIMATE GLOSSARY HEALTH AND SAFETY CULTURE “A system of shared values and beliefs about the importance of health and safety in the workplace” Unfortunately there is no universal definition and many authors use the terms culture and climate interchangeably. One commonly accepted explanation is given by Cooper (2000) who distinguishes between three related aspects of culture: • Psychological aspects – how people feel, their attitudes and perceptions – safety climate. • Behavioural aspects – what people do. or “An attitude to safety which pervades the whole organisation from top to bottom and has become a norm of behaviour for every member of staff from the board of directors down to the newest juniors”. Yet another definition by the UK’s Advisory Committee on the Safety of Nuclear Installations is: “The safety culture of an organisation is the product of individual and group values, attitudes, perceptions, competencies, and patterns of behaviour that determine the commitment to, and the style and proficiency of, an organisation’s health and safety management. Organisations with a positive safety culture are characterised by communications founded on mutual trust, by shared perceptions of the importance of safety and by confidence in the efficacy of preventive measures.” 6-26 What, then, is safety climate? • Situational aspects – what the organisation has – policies, procedures, etc. It is generally accepted that safety climate refers to the psychological aspects of health and safety and is measured through a safety climate or attitude survey (see later). The important thing to remember about a safety culture is that it can be positive or negative. A company with a negative or poor safety culture will struggle to improve safety or prevent accidents, even if they have excellent written procedures and policies, and state-of-the-art safety equipment. The reason for this really comes down to people, their attitudes to safety and how this attitude is encouraged and developed. | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Health and Safety Culture and Climate IMPACT OF ORGANISATIONAL CULTURAL FACTORS ON INDIVIDUAL BEHAVIOUR • Management visibility – senior managers show commitment and are visible ‘on the shop floor’. We are all influenced to some degree by things that we see and hear. Large amounts of money are spent on television advertising because companies know how influential television can be - our behaviour is being moulded by an influential medium. In the workplace, who and what are likely to influence our behaviour when it comes to safety? • Balance of productivity and safety – the need for production is properly balanced against health and safety so that the latter is not ignored. Typical answers might include: • Job satisfaction – confidence, trust and recognition of good safety performance. • Managers and Supervisors If they appear to condone poor behaviour, then it is likely to go unchecked. Does safe behaviour rank way below productivity? Do they show commitment to safety and lead by example? Do they commit sufficient resources to health and safety? • High quality training – training is properly managed, the content is well chosen and the quality is high. Counting the hours spent on training is not enough. • Workforce composition – a significant proportion of older, more experienced and socially stable workers. This group tend to have fewer accidents, and lower absenteeism and turnover. • Work Colleagues The way that colleagues behave will probably have an influence on others. What is their attitude to risk taking? • Training Not being trained in correct procedures and use of equipment can affect health and safety. Does the organisation see training as a priority? Is the training appropriate? • Job Design Job design may be done in a way that makes safe behaviour difficult. How much consideration has been given to the layout of the job and the needs of the individual? • Work Equipment If this is not kept in good order, or is unavailable, it may affect health and safety. What is the organisation’s attitude to equipment maintenance? The UK’s HSE publication, Reducing Error and Influencing Behaviour (HSG48), identifies certain factors associated with good safety performance: • Effective communication – between, and within, levels of the organisation, and comprehensive formal and informal communication. All staff are focused on health and safety • Learning organisation – the organisation continually improves its own methods and learns from mistakes. • Health and safety focus – a strong focus by everyone in the organisation on health and safety. • Committed resources – time, money and staff devoted to health and safety showing strong evidence of commitment. • Participation – staff at different levels in the organisation identify hazards, suggest control measures, provide feedback and feel that they ‘own’ safety procedures. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-27 Health and Safety Culture and Climate INDICATORS OF CULTURE TOPIC FOCUS Indicators of safety culture within an organisation include: • Housekeeping. • The presence of health and safety warning notices throughout the premises. • The wearing of PPE. • Quality of risk assessments. • Good or bad staff relationships. • Accident/ill-health statistics. • Statements made by employees, e.g. “My manager does not care” (negative culture). Some of these indicators will be easily noticed by a visitor and help to create an initial impression of the company. CORRELATION BETWEEN HEALTH AND SAFETY CULTURE/CLIMATE AND HEALTH AND SAFETY PERFORMANCE It is quite easy to identify a correlation between cultural indicators and health and safety performance. An experienced safety practitioner can often gauge the standard of safety performance of an organisation from an initial walk-round and first impressions. The standard will often be confirmed on completion of a detailed audit/ inspection. Subjective and Objective Nature of Culture and Climate The culture of an organisation refers to objective characteristics that can be observed or inferred by an outside observer. For example, the structure of the organisation and the roles and rules can be observed. The deep-seated values of the organisation, e.g. a respect for tradition or service to customers, can be inferred by an outsider. MEASUREMENT OF THE CULTURE AND CLIMATE While there are many indicators which can give a first impression of a company’s safety culture/climate, it is possible to measure some of the indicators to obtain a more accurate picture of the sense of culture within an organisation. There are a number of measurement tools available. Safety Climate Assessment Tools The Health and Safety Laboratory (HSL) has published a safety climate tool which uses eight key factors mapped around 40 statements on which respondents are asked to express their attitude. • Organisational commitment. • Health and safety behaviours. • Health and safety trust. • Usability of procedures. • Engagement in health and safety. • Peer group attitude. • Resources for health and safety. • Accidents and near-miss reporting. The kit is available in a software format and will analyse and present the results as charts that can be easily communicated to the workforce. MORE… You can find further details of the HSL Safety Climate Assessment Tool at: www.hsl.gov.uk/products/safety-climate-tool.aspx In the UK, Loughborough University have developed a Safety Climate Assessment Tool which may be downloaded from: www.lboro.ac.uk/media/wwwlboroacuk/ content/sbe/downloads/Offshore%20Safety%20 Climate%20Assessment.pdf The climate of an organisation, however, is more subjective. This is because it is the way people within the organisation perceive its structures, roles, rules and authority, etc. For example, do individuals feel like a valued member of the organisation or do they just feel like a number? The insider’s view is more difficult to obtain and is usually only discovered by in-depth research. 6-28 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Health and Safety Culture and Climate Perception or Attitude Surveys These are survey questionnaires (often within a safety climate tool) containing statements which require responses indicating agreement or disagreement. Respondents are asked to indicate to what extent they agree or disagree with each statement, generally using a five-point scale which can then be coded to give a score. High scores represent agreement and low scores disagreement. It is not difficult to produce a questionnaire about general health and safety which would give some idea as to the safety culture within an organisation. The questionnaire must be worded to avoid bias, and to obtain truthful answers, confidentiality is necessary. When carried out properly these surveys can identify underlying anxieties and problems which would be difficult to identify by any other means. Take care, however, to make sure that the questionnaires themselves do not create anxiety or suspicion in the minds of workers. When carried out regularly, attitude surveys can identify trends and it is then possible to quantify how attitudes are changing. The process of communication requires a sender, a receiver and feedback. Feedback is the part that is often left out of the process and this is what leads to problems. Successful communication is measured by feedback which allows the sender to test whether the receiver has fully understood the communicated message. Communication methods are written, verbal or visual, or a combination of all three. The method chosen must be appropriate to the type of information to be communicated and its objectives, the sophistication of the audience (receivers), and the structure and culture of the organisation. Communication surveys can be used to find out how effectively information has been transferred to new members of staff. A sample of comparatively new members of staff can be interviewed to identify how well they have assimilated the company’s safety culture, or how much they have retained from company health and safety training. This type of survey can be done formally or informally. Effective communication involves: Findings of Incident Investigations • Including everyone who should be included. Sometimes during an accident/incident investigation the underlying cause is identified as ‘lack of care’. This may indicate individual carelessness or, where carelessness is found to be the widespread cause of accidents/incidents, then this may be an indicator of poor safety culture. • Not overloading people with large quantities of information; prioritise anything urgent. Where the same underlying cause keeps recurring, the safety manager has to introduce a process of education or re-education of the workforce to encourage a change of attitude. The findings and lessons learned from incident investigation are invaluable in preventing similar occurrences, setting policy, formulating safe systems of work, writing training materials and, after publication to the workforce, demonstrating company commitment to the principles of good safety management. • Being selective; sending only what is necessary. Effectiveness of Communication • Being brief, direct and keeping it simple. • Being fast but not at the expense of accuracy. • Encouraging feedback to ensure the message has been received and understood. • Using as few links in the communication chain as possible to prevent distortion of the original message. Evidence of Commitment by Personnel at All Levels GLOSSARY GLOSSARY COMMITMENT COMMUNICATION Can be defined as: “a declared attachment to a doctrine or cause”. “Communication is the transfer of information from one person to another with the information being understood by both the sender and receiver.” (Koontz) © RRC International It is the goal of the safety practitioner to ensure commitment to health and safety by everyone within an organisation. This commitment must start at the management board level. It is essential that management show their commitment to safety as this sets the standard for the whole organisation. The workforce will only believe in this commitment if they know that management are willing to sacrifice productivity or time in order to ensure worker safety. Unit IA – Element IA6: Organisational Factors v2.1 | 6-29 Health and Safety Culture and Climate Evidence of commitment can be seen by management visibility. If managers are not seen on the “shop-floor” or at the “sharp end of activity”, workers may assume that they are not interested in the job or health and safety. Lack of management visibility is seen as a lack of commitment to safety and this becomes part of the organisation’s safety culture. Visible commitment can be demonstrated by management: • Being seen and involved with the work and correcting deficiencies. • Providing resources to carry out jobs safely (enough people, time and money, providing appropriate personal protective equipment, etc.). • Ensuring that all personnel are competent (providing training and supervision). • Enforcing the company safety rules and complying with them personally (introducing safe systems of work and insisting on their observance). • Matching their actions to their words (correcting defects as soon as is reasonably practicable, avoidance of double standards). REVISION QUESTIONS 13. Define the term “safety culture”. 14. How may the safety climate of an organisation be assessed? 15. Name three ways in which management commitment can be demonstrated. (Suggested Answers are at the end.) 6-30 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Factors Affecting Health and Safety Culture and Climate KEY INFORMATION • A positive health and safety culture or climate is promoted by: –– Management commitment and leadership. –– High business profile to health and safety. –– Provision of information. –– Involvement and consultation. –– Training. –– Promotion of ownership. –– Setting and meeting targets. • A negative health and safety culture or climate may be promoted by: –– Organisational change. –– Lack of confidence in organisational objectives and methods. –– Uncertainty. –– Inconsistent signals from management. • To effect a cultural or climate change needs: –– Good planning and communication. –– Strong leadership. –– A step-by step approach. –– Action to promote change. –– Strong worker engagement. –– Ownership at all levels. –– Training and performance measurements. –– Feedback. • Problems with culture or climate change may arise from: –– –– –– –– Attempting to change it too quickly. Changing everything at the same time. Lack of trust in communications. Resistance from those not committed to change. High Business Profile to Health and Safety PROMOTING A POSITIVE HEALTH AND SAFETY CULTURE Management Commitment and Leadership The most important thing is ‘leading by example’. As soon as management undermines the safety standards in order to increase productivity, or ignores an unsafe act, then they lose worker respect and trust, and the whole safety culture of the organisation is threatened. It is important to ensure that management behaviour is positive in order to produce positive results and a positive culture. A positive health and safety culture can be promoted by including safety in all business documents and meetings. All newsletters, minutes of meetings, notices, advertisements and brochures can include an appropriate reference to safety; it could simply be reference to the organisation’s commitment to safety (e.g. a safety phrase appearing on all notepaper) or, with respect to meetings, it could be an opportunity for any safety concerns to be raised. If safety is seen as an integral part of the business then the profile of safety will be raised. Provision of Information It is really important to provide information about health and safety matters in the form of posters, leaflets, or in staff newsletters. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-31 Factors Affecting Health and Safety Culture Involvement and Consultation Setting and Meeting Targets It is vital to involve staff members in health and safety matters. Areas in which staff representatives or health and safety representatives can be actively involved include: Setting safety targets for individuals or teams can have a positive effect on a safety culture. Usually there will be an incentive, perhaps a bonus, linked to performance-related pay or an award or prize. The target could be, for example, to obtain a higher score in a health and safety inspection. • Risk assessments. • Workplace inspections. • Accident investigations. • Safety committee meetings. It is also a legal requirement to consult with employees in good time regarding: • The introduction of any measures which may substantially affect their health and safety. • The arrangements for appointing or nominating competent persons. • Any health and safety information to be provided to employees. • The planning and organisation of any health and safety training. • Health and safety consequences of introducing new technology. We discussed the subject of consultation with workers in depth earlier in this element. Involving and consulting with workers is an important process for getting them to take ownership of health and safety issues. The fact that they or their colleagues have been involved in health and safety matters encourages respect for safety rules and improves attitudes towards safety. These values all help to produce a more positive safety culture within the organisation. Aiming for the target should encourage people to work together in order to achieve it and this usually means people talking about health and safety and ways to improve it. Once the target is met, that standard must be maintained and further improvements encouraged by setting another target. The targets must, however, be achievable in order to prevent workers becoming disheartened and abandoning the target. FACTORS THAT MAY PROMOTE A NEGATIVE HEALTH AND SAFETY CULTURE OR CLIMATE There are a number of factors that may contribute to a negative health and safety culture. Organisational Change Company reorganisations often leave individuals worried about job security and their position in the organisation. Many people fear change and, unless it is handled correctly, will mistrust management and become suspicious of any alterations to their role or environment (even ones that are beneficial). Reasons for company reorganisation may be: • A merger. • Relocation of the business. Training • Redundancies. Training is vital to ensure that people have the right skills to carry out their job safely. Training also makes individuals feel valued and is an important part of their personal growth and achievement. Workers who receive training are more likely to be motivated and take newly-learned skills or ideas back to the workplace. • Downsizing. Promotion of Ownership There are many ways to promote ownership in individuals. We have mentioned involvement and consultation already, but simply talking to people and asking their opinion or their thoughts on a health and safety problem can encourage them to think about health and safety and what they can do to improve it. • External pressures over which the organisation has no power. Companies may offer voluntary redundancies to make the job losses more acceptable, but sometimes the redundancies are compulsory. The company may offer generous financial packages to soften the blow to workers, and in some countries there may be statutory redundancy payments. Problems may occur, however, when the retained workers have to work with reduced manpower and resources - they may feel threatened by the possibility of further redundancies, leading to bitterness and anger. Further resentment may develop where shareholders and directors are seen to benefit from the loss of colleagues who have been forced to leave the business. Where outside pressures are the cause of the reorganisation workers may be more understanding than if the changes are brought about by the need to improve profits. 6-32 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Factors Affecting Health and Safety Culture Frequent reorganisations can be damaging to a company unless they are handled well. Increased workforce dissatisfaction may lead to some workers leaving, which in turn can leave gaps in the operation which cause further difficulties. This type of situation can lead to more accidents and incidents, as well as increased sickness and absence from work. Lack of Confidence in Organisation’s Objectives and Methods Most companies have objectives relating to productivity and safety. If productivity appears to take precedence over safety, however, then worker perception will be that the company is unethical and untrustworthy with little commitment to safety, which will lead to a subsequent deterioration in the safety culture. Examples where workers may feel that safety has been compromised in order to achieve productivity include: Management Decisions that Prejudice Mutual Trust or Lead to ‘Mixed Signals’ Regarding Commitment Management decisions which are, or are perceived to be, inconsistent or poorly made can generate unrest and distrust in an organisation. There may be good reasons for the decision which is why it is extremely important that management are aware that good communication is an important part of the decision-making process. Circumstances that could give rise to distrust and doubt about management commitment generally (these could equally apply to decisions about safety) include: • Where there are no rules or no precedents, decisions may appear to be arbitrary and inconsistent. • Workers expected to wear PPE, whereas visitors or managers are not. • Safety improvements only made after incidents have occurred. • Refusal to delegate decision-making leads to demotivation and diminution of a sense of responsibility in subordinates. • Double standards in the application of safety regulations by safety advisers and management. • Constant rescinding by senior management of decisions made at lower levels of management. • Unsafe practices ignored in order to improve productivity. • Delays in making decisions. • Permit-to-work systems not being operated as they should be. • Decisions affected by conflicting goals between management and worker. • Decisions affected by conflicting goals between different departments. • Changes made to safety rules during operation. • Lack of consultation prior to decision-making. EFFECTING CULTURAL OR CLIMATE CHANGE There are three factors that should be considered when managing a change in culture: • Dissatisfaction with the existing situation, e.g. too many near misses. • A vision of the new safety culture. • Understanding how to achieve it. Unsafe practices may be ignored to improve productivity Uncertainty Security is a basic human need. In an uncertain environment, people generate feelings of insecurity. When security cannot be assured, humans cannot achieve their full potential. Uncertainty about the future can lead to dissatisfaction, lack of interest in the job and generally poor attitudes towards the company and colleagues. Uncertainty is often caused by management behaviour which sends mixed behaviour signals to the workforce. If management are seen to say one thing and then do something different, this undermines their authority and credibility, e.g. managers drinking on the job or failing to wear PPE. © RRC International Change is an inherent part of modern life, but there are many people who find change difficult to deal with and who are afraid of it. In order to effect change within an organisational culture, you have to plan the strategy and communicate from the beginning in order to involve workers and not alienate them. Planning and Communication Planning for change should start at the top of the organisation, but should encourage participation at all levels. There should be clear objectives as to what is to be achieved by the proposed change, e.g. a cost-benefit analysis of the changes suggested. Unit IA – Element IA6: Organisational Factors v2.1 | 6-33 Factors Affecting Health and Safety Culture Plans for change should clearly designate who is responsible for initiating and implementing specified changes, as well as how each stage of the change process will be conducted. Effective communication between all those implementing change is crucial. To prevent rumours circulating and misunderstandings developing, it is important to publicise information relating to the pending change as early as possible. Wherever possible, direct briefings, meetings or interviews should keep managers and staff aware of proposed changes and the progress made as changes get underway. Strong Leadership Managers at all levels need to demonstrate strong leadership and not give inconsistent or mixed messages. A Gradualist (Step-by-Step) Approach One of the ways of effecting change in an organisational culture is by taking a gradualist (step-by-step) approach, with changes phased in over a period of time. The main advantage of this approach is that it ensures that there is time for adaptation and modification; it also allows time for the change to become part of the established culture. The major disadvantage of this approach is that the changes take a relatively long time to implement. This can mean that unsatisfactory conditions and mindsets may be left in place for longer than is desirable. Action to Promote Change • Direct This is where positive action is carried out with the sole objective of effecting change, perhaps by setting up a two-tiered system, i.e. a steering group and a working party. The steering group should consist of high level personnel (e.g. directors and heads of departments) who give broad objectives, set timescales and meet approximately every three months. The working party, however, will meet every month and will consist of middle management, first-line supervisors and union/ worker representatives. The working party will carry the ‘message’ to the workforce and provide feedback. • Indirect Indirect methods bring about change, but they are not necessarily the primary reason for carrying out the method. For example, risk assessments identify deficiencies in the workplace and corrective action to put them right. Widespread use can indirectly encourage a risk assessment mindset or attitude (a culture of greater awareness of risks, etc.). Strong Worker Engagement Cultural change is not the sole responsibility of management; there also has to be significant commitment from workers who must recognise the need for change. Ownership at All Levels All individuals at all levels must be engaged in the process and be committed to change. Training and Performance Measurements • Training courses can include information about new or impending safety legislation or safety technology thereby indirectly paving the way for future changes. • Performance measurements can be introduced to encourage workers to have a greater interest and involvement in health and safety. Where performance measurements improve over time, they can be linked to an incentive scheme, but they should not be linked to accident/incident rates as this can lead to under-reporting. Performance measurements are an inexpensive way of promoting health and safety, but they need the support of management and unions to be successful. Importance of Feedback Feedback is crucial to ensure that any changes implemented are working successfully. Feedback from workers will enable management to evaluate the new processes, and fine-tune them where necessary. The chair of the working party should also be a member of the steering party and this role is usually filled by a safety professional who can act as the link between the two groups. The pace of change should be dictated by the feedback given by the working party. 6-34 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Factors Affecting Health and Safety Culture PROBLEMS AND PITFALLS RELATING TO CHANGE In many cases the introduction of change within an organisation is accompanied by problems such as conflict. Problems associated with change include: • Changing Culture Too Rapidly Where changes have occurred too quickly workers may feel extremely vulnerable, insecure, confused and angry. Where the changes have brought together new personalities, then conflict between individuals may occur. Differences of temperament are at their most obvious when people are new to each other; a measure of tolerance may build up over time. • Adopting Too Broad an Approach Trying to do too much all in one go can dilute the resources so that little impact is seen. It is better to target resources on fewer, manageable issues. It is important to be clear about what the objectives are at the start so that everyone is aware of the changes that will occur. • Absence of Trust in Communications This is unsettling and demotivating. Inconsistent management behaviour can lead to mistrust and uncertainty causing a complete breakdown in relations between management and the workforce. Poor communications in periods of change can lead to misunderstanding and confusion, which can fuel conflict. • Resistance to Change Some people are more resistant to change than others. Older people tend to be more resistant than young people, and people with heavy financial commitments tend to fear change as they need to feel secure. Some people develop set patterns of thought and behaviour which can be difficult to overcome when change occurs. This is known as perceptual set, and is the way in which observed information is processed by the individual to fit his/her internal experience, attitude, expectations, sensitivity and culture. All these factors need to be considered and dealt with as part of the change process. REVISION QUESTIONS 16. Identify the features of a positive health and safety culture within an organisation. 17. Briefly explain what is needed to effect cultural change within an organisation. (Suggested Answers are at the end.) © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-35 Summary SUMMARY Internal and External Influences Internal influences on the organisation include: • Finance. • Production targets. • Trade unions. • Organisational goals and culture. External influences include: • Legislation. • Trade unions. • Enforcement agencies. • Insurance companies. • Courts/tribunals. • Public opinion. • Contracts/contractors/clients. Types of Organisations An organisation is a group of persons who interact in order to achieve certain predetermined goals or objectives. In a formal organisation, the organisation’s structure is based on relationships from the chief executive down. This hierarchical structure is represented by the company organisation chart, or organogram. The informal organisation is represented by individual and group behaviour, and depends on the quality of personal relationships. The organisation can be viewed as a system; different parts of an organisational system are functionally interrelated change in one part affects other parts of the organisation. Conflict may arise as a result of individual goals not being consistent with those of the organisation. Third Party Control Definitions in this area: • Third parties: –– Contractors. –– Visitors and trespassers. –– Members of the public. • The particular difference between contractors and other parties. There are legal, moral and economic reasons for ensuring that third parties are covered by health and safety management systems. Basic duties owed to and by third parties include those of: • Designers, manufacturers and suppliers to customers/users. • Occupiers of premises/land to visitors. • Contractors to clients and vice versa. When using contractors procedures need to be adopted to ensure: • Planning - including risk assessment. • Selection - competent contractor. • During contract – ensure contractor is inducted and is aware of local procedures. • Checking of performance. • Review of procedures. 6-36 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Summary Consultation with Workers ILO Occupational Safety and Health Convention (C155), Article 20 and ILO Occupational Safety and Health Recommendation (R164) contain useful principles regarding consultation in the workplace. • Formal consultation involves worker representatives on health and safety and the safety committee. • Informal consultation can include discussion groups, safety circles and departmental meetings. The health and safety practitioner has an important role to play in the consultative process. There are behavioural aspects associated with consultation; peer group pressures and identification of potential areas of conflict are two of these. Positive consultation is based on the employer and worker being prepared to consider problems together, making use of each other’s knowledge Health and Safety Management Information System It is common in many regions of the world for there to be legal duties (either explicit or implied) to provide information to various categories of people. The basis of sound health and safety information management comprises the collection of information, its documentation and the provision of systems for cascading information to users. A broad range of both internal and external information is needed for an effective health and safety management information system. This includes: • Loss event data. • Cost data. • Suppliers’ data. • Results of audits and inspections. Health and Safety Culture and Climate Safety culture may be defined as “a system of shared values and beliefs about the importance of health and safety in the workplace”. Safety climate is an assessment of people’s attitudes and perceptions at a given time. Organisational factors, e.g. training, availability of suitable equipment, behaviour of managers, etc. influence individual behaviour. There are many indicators that give a first impression of a company’s health and safety culture and climate. It is possible to measure some of the indicators to gain a more accurate picture of the sense of the culture within the organisation, using: • Safety climate assessment tools. • Perception or attitude surveys. • Findings of incident investigations. • Effectiveness of communication. • Evidence of commitment by personnel at all levels. Factors Affecting Health and Safety Culture and Climate A positive health and safety culture can be promoted by various factors, such as: the commitment of management, a high business profile, provision of information, involvement and consultation, training, promotion of ownership, and the use of targets. A negative health and safety culture can also be affected by various factors, such as: organisational change, lack of confidence in an organisation’s objectives and methods, uncertainty, and inconsistent management decisions. A change in attitudes towards the health and safety culture can be achieved by planning and communication, and should be introduced using a gradual approach. Action to promote such a change can be direct or indirect. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-37 Exam Skills QUESTION By now you should be familiar with the style of NEBOSH exam questions; the next one is a straightforward 10 mark question on health and safety culture. Question Outline how safety tours could contribute to improving health and safety performance and to improving health and safety culture within a company. Discussion of the specific health and safety requirements, problems or standards that such tours may address, is not required. (10) SUGGESTED ANSWER OUTLINE Remember this is a 10 mark question so try to identify 12 points in order to gain full marks. The Examiner would be looking for some of the following points to be included in your answer. Safety tours can be used in an organisation to help improve its health and safety performance and culture by: • Identifying compliant and non-compliant behaviours. • Ensuring compliance with legislation and good practice. • Seeing how effective its actions are. • Establishing that new programmes are working as expected. • Identifying good practice across the company. • Consolidating good relationships with the workforce during tours. • Assessing workforce behaviour on an unscheduled basis. • Spotting local issues. • Identifying company-wide issues. • Demonstrating leadership/engagement and commitment. • Highlighting management commitment. • Ensuring that local remedial actions to solve issues raised have been implemented. • Encouraging local ownership of health and safety. • Highlighting the importance of safety. • Combining it with other types of tours (quality/ environmental, etc.) saving time/resources, etc. • Sharing the findings with the workforce, showing openness. • Making it easier to communicate on a regular basis with workers. 6-38 | Unit IA – Element IA6: Organisational Factors © RRC International v2.1 Exam Skills POSSIBLE ANSWER BY EXAM CANDIDATE Safety tours can contribute to improving health and safety performance and the culture as they should be used to identify good and poor H&S behaviours on the shop floor of the organisation. This information can be used in a simple manner to trend on performance against set behaviours via a performance feedback sheet, such as PPE being worn v. not worn – has it improved since last time or got worse? The tours can be used to target new understanding or compliance with new initiatives and programmes the company introduces and is an effective way of engaging the workforce across an organisation to support these. The actions raised should be solved locally, visually and quickly, which demonstrates leadership and commitment of the company and enables best practice sharing. If the safety tours are carried out by managers they can be an effective demonstration of management commitment to safety; however this does require action to be taken as a result of the tour. REASONS FOR POOR MARKS ACHIEVED BY CANDIDATES IN EXAM An exam candidate answering this question would achieve poor marks for: • Describing how to carry out a safety tour. • Looking at specific issues, although the question particularly said not to. • Focusing on the timing/frequency of tours and not looking at how tours can help improve health and safety performance. © RRC International Unit IA – Element IA6: Organisational Factors v2.1 | 6-39 v2.1 ELEMENT HUMAN FACTORS 7 LEARNING OUTCOMES On completion of this element, you should be able to demonstrate understanding of the content through the application of knowledge to familiar and unfamiliar situations and the critical analysis and evaluation of information presented in both quantitative and qualitative forms. In particular you should be able to: Outline psychological and sociological factors which may give rise to specific patterns of safe and unsafe behaviour in the working environment. the nature of the perception of risk and its Explain relationship to performance in the workplace. Explain the classification of human failure. appropriate methods of improving individual Explain human reliability in the workplace. how organisational factors could contribute Explain to improving human reliability. Explain how job factors could contribute to improving human reliability. the principles, conditions and typical content Outline of behavioural change programmes designed to improve safe behaviour in the workplace. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-1 Contents HUMAN PSYCHOLOGY, SOCIOLOGY AND BEHAVIOUR Meaning of Terms Influences on Human Behaviour Key Theories of Human Motivation Factors Affecting Behaviour On-Line and Off-Line Processing Knowledge-, Rule- and Skill-Based Behaviour (Rasmussen) Revision Questions 7-3 7-3 7-3 7-3 7-5 7-7 7-7 7-9 PERCEPTION OF RISK Human Sensory Receptors Process of Perception of Danger Errors in Perception Caused by Physical Stressors Perception and the Assessment of Risk Perception and Sensory Inputs Individual Behaviour in the Face of Danger Revision Questions 7-10 7-10 7-11 7-11 7-12 7-12 7-14 7-16 HUMAN FAILURE CLASSIFICATION HSG48, Classification of Human Failure Contribution of Human Error to Serious Incidents Revision Question 7-17 7-17 7-20 7-24 IMPROVING INDIVIDUAL HUMAN RELIABILITY IN THE WORKPLACE Motivation and Reinforcement Selection of Individuals Revision Question 7-25 7-25 7-26 7-27 ORGANISATIONAL FACTORS Effect of Weaknesses in the Safety Management System on the Probability of Human Failure Influence of Safety Culture on Behaviour and Effect of Peer Group Pressures and Norms Influence of Formal and Informal Groups Organisational Communication Mechanisms and their Impact on Human Failure Probability Procedures for Resolving Conflict and Introducing Change Revision Questions 7-28 7-28 7-29 7-30 7-33 7-37 7-37 JOB FACTORS Effect of Job Factors on the Probability of Human Error Application of Task Analysis Role of Ergonomics in Job Design Ergonomically-Designed Control Systems Relationship Between Physical Stressors and Human Reliability Effects of Fatigue and Stress on Human Reliability Revision Questions 7-38 7-38 7-39 7-39 7-42 7-43 7-44 7-44 BEHAVIOURAL CHANGE PROGRAMMES Principles of Behavioural Change Programmes Organisational Conditions Needed for Success in Behavioural Change Programmes Example of Typical Behavioural Change Programme Contents Revision Question 7-45 7-45 7-46 7-47 7-48 SUMMARY 7-49 EXAM SKILLS 7-52 7-2 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Human Psychology, Sociology and Behaviour KEY INFORMATION • Human behaviour is influenced by the personality, attitude, aptitude and motivation of the individual. • Different theories have been proposed to help explain what motivates individuals at work. • Experience, social background and education/training affect behaviour at work. • Rasmussen has proposed three levels of behaviour – skill-based, rule-based and knowledge-based. MEANING OF TERMS A study of the human personality. • Motivation – the factors that influence an individual to behave in a certain way. Most people are generally motivated to avoid accidents and ill health, although other motivators may conflict with the general principle. For example, wearing PPE may be uncomfortable and interfere with the task and so may encourage people to take greater risk by not using it. SOCIOLOGY KEY THEORIES OF HUMAN MOTIVATION A study of the history and nature of human society. There are a number of theories which have been developed to try to explain why people do what they do. GLOSSARY PSYCHOLOGY INFLUENCES ON HUMAN BEHAVIOUR • Personality - the combination of characteristics or qualities that form an individual’s distinctive character. The main dimensions of personality are: –– Extroversion/introversion – extroverts are more outgoing than introverts. –– Neuroticism – neurotics have high levels of anxiety. –– Conscientiousness - such people tend to be well organised. –– Agreeableness – these people are more willing to co-operate with others and avoid conflict. –– Openness to experience – such people tend to welcome new experiences and are more curious. Some of these characteristics, such as conscientiousness and agreeableness, are likely to be positive traits in terms of health and safety. • Attitude – reflects how a person thinks or believes about something (often called the object of the attitude) and this may then extend to how they behave. For example, as a result of experiencing a workplace transport accident a person is more likely to become safety conscious (at least initially) in relation to work transport hazards. • Aptitude – the ability of an individual to undertake a given task safely. Training and supervision usually increase aptitude. © RRC International F. W. Taylor Frederick Winslow Taylor is best known for his early 20th century publications on improving industrial efficiency. Taylor suggested that the reasons for inefficiency were: • The fallacy that increased output per man will lead to unemployment. • Defective systems of management which make it essential for workers to work slowly to protect their best interests. • Inefficient methods based on a rough and practical approach which waste workers’ efforts. The principles Taylor developed are stated as: • Develop a science for each element of a man’s work, to replace the rough and practical approach. • Scientifically select, train and develop the workman, instead of letting him choose his own method and train himself. • Co-operate with the workers to ensure that all the work is done in accordance with the principles of the science which has been developed. • Management to assume responsibility for the jobs for which they are better suited than the workman, i.e. planning the work. Unit IA – Element IA7: Human Factors v2.1 | 7-3 Human Psychology, Sociology and Behaviour Taylor’s methodology was to: Maslow (Hierarchy of Needs) • Design efficient methods for doing work, based on a scientific approach, e.g. time and motion studies. Abraham Maslow suggested five levels of human need, which he arranged in a hierarchy. • Set productivity goals. Self-Actualisation • Give financial rewards for meeting the goals. • Train the workers to use the methods. Taylor conducted a number of experiments which all led to much higher productivity and wages for individuals. The incentive used in each case was entirely financial; no thought was given to aspects such as ‘job satisfaction’. Esteem Task needs Safety or Security Mayo (Hawthorne Experiments) One of the most significant contributions to the study of work groups took place in 1927 at the Hawthorne Works of WEC in the USA. The Hawthorne Experiments were originally designed as a short project to study the “relation of quantity and quality of illumination to efficiency in industry”. What surprised the observers, who had thought they could predict what was going to happen, was that output varied with no relationship to the amount of illumination. The observers then realised that motivation of the individual is not just to do with money or intensity of lighting. They started to ask themselves what motivated individuals working in groups. A psychologist named Elton Mayo was allowed to conduct a series of experiments and important findings included: • Working in a small, harmonious group can have a significant effect on productivity. • Having a chance to air grievances seems to be beneficial to working relationships. One of the essential principles here is that when you show concern for, or pay attention to people, it can spur them on to perform better. In other words, just the fact that the workers being studied improved their performance. This is known as ‘the Hawthorne effect’ or the ‘somebody upstairs cares’ syndrome. Social Biological The order in which the needs are listed is significant in two ways: • It is the order in which they are said to appear in the normal development of the person. • It is the order in which they have to be satisfied and if earlier needs are not satisfied, the person may never get around to doing much about the later ones. From this theory you might expect that people in a poor society will be mostly concerned with physiological and safety needs, whereas those in an affluent society will manage to satisfy those lower needs in the hierarchy and, in many cases, will be preoccupied with the need for self-actualisation. However, Maslow’s hierarchy stresses that co-operation can occur only at higher levels between mature individuals, the lower order needs leading to conflict between individuals. Yet primitive tribes seem to co-operate more than advanced societies, where conflict between individuals is encouraged. This seems to suggest that there may be a flaw in Maslow’s analysis. The need for self-actualisation refers to the person’s need to develop his or her full potentialities; the meaning varies from person to person, for each has different potentialities. For some it means achievement in literary or scientific fields; for others, leadership in politics or the community; for still others, merely living their own lives fully without being unduly restrained by social conventions. ‘Selfactualisers’ are found among professors, businessmen, political leaders, artists and housepersons. Not all individuals in any one category are able to achieve self-actualisation; many have numerous unsatisfied needs and, because their achievements are merely compensations, they are left frustrated and unhappy in other respects. 7-4 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Human Psychology, Sociology and Behaviour D. C. McClelland Douglas McGregor D. C. McClelland was, from the early 1960s, concerned with the analysis of human needs. He concentrated on three key needs: Writing in the early 1960s, Douglas McGregor developed the ideas of Theory X and Theory Y. Theory X was the ‘classical’ view that, by nature, people are lazy. They would work ‘as little as possible for as much as possible’, i.e. people do not really like responsibility, and they only take it as a means of getting more money. Given a chance, people who have been promoted would pass the responsibility on to others but still go on collecting the higher salary. This view goes on to argue that people are resistant to change, and put their own interests above those of the organisation as a whole. It shows individuals as reluctant participants in organisational life. Organisations must offer incentives for good work and punishment for lack of effort. If the two are combined, it is argued, workers will function along the lines that organisations wish them to. • Need for Affiliation The needs of human beings for friendship and meaningful relationships. • Need for Power Some people seek power in their work situations; they want to make a strong impression on people and events. • Need to Achieve To many people the sense of ‘getting on’, progressing or being promoted, is very important. These three points relate to the functioning of people at various levels of authority in an organisation. People ‘high up’ will have a strong drive for power and making an impact; people in the middle have considerable achievement needs and compete with each other. At the lower levels, the drive for affiliation should be strong. Herzberg’s Two-Factor Theory Frederick Herzberg, writing in the late 1950s, identified two distinct sets of needs in individuals working in organisations: the need to avoid pain and discomfort, and the need to develop psychologically as a person. Herzberg identified two areas of concern for the organisation: • Hygiene Factors These include working conditions, company policy and administration. If these are not adequate there will be dissatisfaction, and work output will suffer; however if they are satisfactory they will not motivate workers. For example, a cold office is a cause of dissatisfaction but a comfortable office is not a specific motivator. • Motivators Here, Herzberg included achievement of work tasks; recognition by supervisors of achievement and quality of work; the giving of increased responsibility as a reward for successful work efforts; and the opportunity for psychological development in the work role and growth. Since these are the characteristics that people find intrinsically rewarding, they will work harder to satisfy them through their job. In Herzberg’s model it is possible to avoid job dissatisfaction without necessarily achieving job satisfaction. This is possible where an organisation meets a high level of hygiene factors, but fails to provide a high level of motivators. © RRC International McGregor argued that Theory X was wrong and put forward Theory Y, that people are often self-motivated to work and perform best with a minimum of supervision and control. McGregor suggests that management should assume that in many cases workers will contribute more to the organisation if they are treated as responsible, valuable and industrious people. Management should reduce controls, but retain accountability, i.e. they should replace direction and threats with the giving of responsibility. The workplace should allow the worker to gain satisfaction in the pursuit of objectives to which he is committed. FACTORS AFFECTING BEHAVIOUR Experience We have already noted that risk assessments should consider groups who are particularly at risk, including the young and inexperienced. With increasing experience we would expect workers to become more competent and to increase in ability to cope with situations, but there may also be complacency and a tendency to cut corners. Age and experience are correlated with differences in accident susceptibility as the following graph indicates. Though its exact shape will vary with circumstances, the curve will remain roughly the same. Unit IA – Element IA7: Human Factors v2.1 | 7-5 Human Psychology, Sociology and Behaviour Accident susceptibility in relation to age and experience Social and Cultural Background An individual’s background will initially have a significant effect on their behaviour. The society and culture in which an individual is brought up teaches acceptable and unacceptable behaviour. Being brought up in a society where there is little work and it is a struggle to find adequate food is likely to make people undertake tasks with less consideration for safety compared to those from more affluent cultures. This relates to Maslow’s hierarchy of needs. Education and Training Education is often thought of as the act of acquiring knowledge, whereas training is thought of as giving a person more specific skills for a particular task. In many ways the concept of safety training is a myth. Certainly the notion of ‘bolt-on’ training to accompany job training is at best misguided. Training which teaches workers how to perform tasks correctly, teaches them how to perform those tasks safely at the same time. Remember the saying: ‘the right way to do the job is the safe way to do the job’. Safety training should be integrated into skills training If successful both education and training will secure a positive change in the behaviour of personnel. It is therefore essential to identify the changes in behaviour required before training begins and to set outcomes which can be demonstrated after the training has been completed. This approach allows the success of the training to be measured and evaluation and feedback on success to be provided. The safety practitioner and the training manager should ensure that safety is built into the training package when identifying training needs. In this way, safety is further integrated into the quality and efficiency programme and not left outside it, where money is not available during lean years and time is not available during boom years. Of course, there are times when safety training has to stand alone, such as during induction training, when new workers should be told of specific safety procedures, e.g. fire procedures, first-aid arrangements, etc. In general, however, the more safety training can be integrated into skills training, the better. 7-6 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Human Psychology, Sociology and Behaviour ON-LINE AND OFF-LINE PROCESSING Decisions have to be made during any working situation; these decisions can be regarded as on-line and off-line processing. • On-line processing involves those decisions which have to be made as a work process is in operation. Since the human brain can only really deal with a few matters at the same time, operations and the decisions involved tend to be grouped. For example, a machine will be set up to perform a sequence of operations. Once set in motion, it may be difficult to stop the operation until the sequence has been completed. On-the-spot decisions of this type have to be made without too much thought, and so tend to be skillbased. A wrong decision or a missed danger signal can lead to situations where the condition is quickly made worse. Trial and error involves on-line processing. • Off-line processing involves those decisions that can be made after consideration of a number of alternatives. It is often possible to consider, and reject, unsuitable alternatives without the need to try them out first. Often this will involve knowledge and intelligence. Problems occur when we assume that we have correctly interpreted the data available and come up with a solution to the situation. We then fail to search for alternatives, and opt for a wrong course of action. Other errors occur when we attempt to solve a complicated problem mentally, when really it requires a more detailed, written-down, mathematical treatment, or a group decision might be more sensible. Our mental capacity not only depends on knowledge, intelligence and ability, but also on our fatigue levels and our mental state at the time. It is not easy to make correct decisions under situations of pressure, stress or panic. KNOWLEDGE-, RULE- AND SKILL-BASED BEHAVIOUR (RASMUSSEN) TOPIC FOCUS Rasmussen’s model suggests three levels of behaviour that explain the human error mechanisms: • Skill-based behaviour describes a situation where a person is carrying out a tried and tested operation in automatic mode. A competent cyclist can ride a bicycle without any conscious effort, or an experienced driver can change gear without thinking of the sequence of events involved. Little or no conscious thought is required; in fact, thinking about the task makes the task less smooth and efficient, and increases the chance of error. In this situation, errors occur if there are any problems such as a distraction. • Rule-based behaviour is at the next level - the situation where the operator has available a wide selection of well-tried routines (i.e. rules) from which appropriate ones can be selected to complete the task, i.e. if X happens, then I do Y. An example is obeying local codes when driving; if there is a red traffic signal, the usual rule is to stop. In this situation, errors occur if the wrong rule is applied. • Knowledge-based behaviour is for situations where a person has to cope with unknown situations, where there are no tried rules or skills. The individual, using their experience and perhaps trial and error, tries to find a solution to solve a novel situation. In these circumstances the chance of error is the greatest. Rasmussen’s model is modified by James Reason to produce the version given in Safety at Work (7th Edition, John Ridley & John Channing, ButterworthHeinemann Ltd, ISBN: 9780750680356) and this is probably the most useful version since it shows the model in the form of an algorithm (see the following figure). It shows the individual decision-making/problem-solving processes which lead to the action taken: • We start in skill-based mode. • If we do not have the requisite skill we move to rulebased behaviour. • If no rule is available we finally resort to knowledgebased behaviour. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-7 Human Psychology, Sociology and Behaviour Although all three are shown in the model as being distinct, there is in reality a smooth transition between them and for a more complex task all three modes of behaviour may apply. Dynamics of generic error-modelling system 7-8 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Human Psychology, Sociology and Behaviour REVISION QUESTIONS 1. Define the terms ‘psychology’ and ‘sociology’. 2. Draw a diagram to explain Maslow’s hierarchy of needs. 3. According to Rasmussen’s model, what are the three levels of behaviour? (Suggested Answers are at the end.) © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-9 Perception of Risk KEY INFORMATION • Each of our senses send signals to the brain. • We tend to screen out things we are not interested in. • Sensory defects increase with age and ill health. • Perceptual set is dangerous because we assume both the danger and the solution without seeing the real issues. • Our perception of hazards can be distorted. • Errors of perception can also be caused by physical factors such as fatigue and stress. • An individual’s perception of a situation is based on two sources of data: –– Information from the senses. –– Expected information. HUMAN SENSORY RECEPTORS The natural senses are: • Sight. • Hearing. • Taste. Each of our other senses work by sending signals to the brain. There is a time interval between the signal being sent from the sensory receptor and the brain making us aware of the situation. Remember that our senses are the main way in which we get warning of personal danger. Sensory Defects and Basic Screening Techniques • Smell. • Touch. (Note that there are others, such as the sense of temperature and the sense of acceleration.) Personal safety involves reacting to the signals sent by our human sensory receptors to the brain. We actually see with our brains rather than with our eyes. Our eyes send small electrical signals to the brain, where the visual image is constructed and interpreted. You may have seen examples of optical illusions. You will be aware, on occasions, of not seeing or hearing something which was very plain to someone else. Sensory defects increase with age and failing health. Some people need spectacles and hearing aids, and you should have a general idea of why this could be so. The safety practitioner probably needs to be more concerned about those who don’t know that they have sensory defects or try to forget about it. We also have the ability to shut out those things that we are not interested in, i.e. screen out those things we consider not worth concentrating on at the moment. Even as you read this, you will be skipping over those ideas that you already know, or think that you know, and perhaps concentrating more on other items. We have to do this in life. • You may live within two miles of a motorway, but really have to concentrate to hear the traffic on it. • A worker is able to filter out background noises in a workshop and maintain a conversation. Optical illusion Which centre dot is larger? They are, in fact, the same size - your eyes see them one way, but your brain interprets them differently. 7-10 • When driving a car or operating a work machine, or typing on a keyboard, most of the operations are done in ‘auto-pilot’ mode. This saves effort and allows us to concentrate on other things, or think ahead. This is a useful asset to have, but it is the reason for many accidents. You cannot expect 100% concentration on safety matters from others if you seldom give 100% attention yourself. | Unit IA – Element IA7: Human Factors © RRC International v2.1 Perception of Risk PROCESS OF PERCEPTION OF DANGER GLOSSARY PERCEPTION The recognition and interpretation of sensory stimuli based chiefly on memory. Research into perception of danger by individuals and groups shows that there is a clear distinction between how we perceive risks to personal safety, dangers to health, and dangers to society. Individuals who take part in hazardous sports and activities may be very reluctant to take even a small risk in the work situation. The factors involved in perception are: • Signals from the Sensory Receptors Our eyes, ears, nose, touch and perhaps taste make us aware of the situation, but these signals can be misleading if we suffer from a sensory defect. • Expected Information from the Memory We have an expectation of what to see and hear; this signal is from the memory. We sometimes see things that are not there, and don’t see things that are. This signal can also be misleading, particularly if it is affected by stress, alcohol, drugs, fatigue, or just familiarity. These two signals combine to give us a ‘picture’ of the hazard situation, which is then processed by the brain. We then take, or decide not to take, action. Perceptual Set This is sometimes called a ‘mindset’. We have a problem and immediately perceive not only the problem, but also the answer. We then set about solving the problem as we have perceived it. Further evidence may become available which shows that our original perception was faulty, but we are now so pleased with our intelligent solution that we fail to see alternative causes and solutions. This is a basic cause or factor in many accidents and disasters. Students often get such mindsets when answering examination questions and assignments. You have prepared yourself well for a particular type of question. This seems to be there on the examination paper and you immediately set about writing the answer. Later, when discussing this with others or rereading the question, you wonder how you could have missed the point. The examination committee spent a great deal of effort to make it perfectly clear what was needed, but all to no avail. The same thing can happen in work situations. For example, a signalman was expected to check that there was a red light at the back of every train which passed his signal box. He had never seen a situation where this was not so in the ten years that he had been doing his job. However, on one occasion part of the train had become uncoupled, but he distinctly remembered checking and ‘seeing’ the red light as the train passed. A following train collided with the part of the train that had become uncoupled. This was a typical case of mindset or perceptual set. Perceptual Distortion Everyone’s perception of hazard is faulty because it gets distorted. Things that are to our advantage always tend to seem more right than those that are to our disadvantage. Management generally tend to have a different perception of hazard from that of workers. When it affects work rates, physical effort, or bonus payments, workers also suffer from perceptual distortion. ERRORS IN PERCEPTION CAUSED BY PHYSICAL STRESSORS In examining the cause of errors in perception, we also need to consider the effects of fatigue, overwork, overtime, stresses from the workplace, and stresses from home and outside activities. Shift work is a major factor. Our bodies operate best when we have a regular routine. Human beings have an inbuilt clock (the Circadian Cycle) and the pattern of work, rest and sleep is upset by a change of work pattern. It is even possible that we are locked into a seven-day pattern. Perception is affected by having to keep awake and alert when the body is saying that it is time to sleep. Fatigue is more than tiredness of the muscles and the mind; there is a physical, mental and psychological dimension. Fatigue can lead to errors in perception HINTS AND TIPS Always answer the question which has been set, not the one you wish had been set! © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-11 Perception of Risk PERCEPTION AND THE ASSESSMENT OF RISK If there are problems in our basic perception of a situation, then there are going to be errors in our perception of risk. In assessing a risk there is safety in numbers. My faulty perception of a risk could be corrected by another person’s clearer perception of an issue. Perception also depends upon knowledge and experience. A group will usually have more to contribute than an individual. Perception and the Limitations of Human Performance Even when we have achieved perfection in the realm of perception – and this is very unlikely – we still have to put the solution into effect. As human beings we have limitations in knowledge, strength, physical and mental ability. We have plenty of excuses for getting things wrong. The major problem is that legislation, the courts, the media and the public at large expect perfection in the realm of health and safety. Representatives of the media will ask: “Can you guarantee that this will never happen again?” when investigating an industrial accident situation. We can only say something like: “We have learned from this mistake and we consider the possibility as now remote”. Filtering and Selectivity as Factors for Perception Filtering and selectivity are vital human activities, since we often tend to do many activities in ‘auto-pilot mode’. From a safety point of view, however, the process of filtering and selectivity presents a danger. While concentrating on a particular topic, to the selective exclusion of others, we can easily miss a vital signal which should have warned us of danger. However, we do tend to notice changed situations. Danger signals and warnings are more likely to be noticed if they involve loud bells or klaxons and flashing rather than fixed lights. PERCEPTION AND SENSORY INPUTS The Hale and Hale Model An article by Professor A. R. Hale and M. Hale, Accidents in Perspective, was published by the National Institute of Industrial Psychology in 1971. This includes a model of accident causation which includes the idea of perception. Professor Hale has written one of the chapters in Safety at Work by Ridley (Ed.), in which a version of this diagram is shown and explained. Professor Hale suggests that accident research dealing with accident proneness and unicausality shows confused thinking. He suggests that his model allows any accident to be investigated and the root cause determined by finding the place, or places, on the model which represent(s) the major source of error. It follows that, if you have correctly determined the cause of the accident, then it is easier to find the solution. In this case we are looking for human factors. Our senses are continuously receiving information and the brain is processing it. However, we cannot keep our mind continuously on all that is coming to us: we use a filter mechanism. Information passed to higher levels of management is also filtered. From all the information available, only the vital elements are passed on. In much the same way, we tend to be continuously screening out those items that are not of immediate interest. In a noisy workshop, an operator will tend not to hear the background noise, but only those factors that are of interest to his particular job. Although we see all in front of us, we can concentrate on one particular subject and filter out other matters. We don’t hear a constantly ticking clock, but would be immediately aware if it stopped. If you are able to ‘speed read’ then you would not see each individual word, but would quickly scan a page, only seeing those word forms which convey vital information. For instance, if you were looking for some information about ‘filtering’, you could rapidly scan an article and be stopped by the occurrence of the word ‘filter’, without reading the whole article. 7-12 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Perception of Risk Accident causation model according to Hale and Hale An individual’s perception of a situation is based on two sources of data: • Information from the senses. • Expected information. Both of these sources could be incomplete or incorrect. Physical defects of sight or hearing can affect the presented information, while fatigue, stress, or drugs can alter the expected information. From past experience, or some stereotyped expectation, we sometimes see a situation other than the actual one. © RRC International Other errors can occur in decisions as to possible actions and the internal processing of information. This also involves some cost/benefit decision. Errors can occur because of our lack of knowledge, our ideas of possible actions and in our estimate of effects of any action. The action, whether good or bad, will affect the situation and so produces a feedback loop. New information will be presented and there is a possibility of a trial and error situation. Unit IA – Element IA7: Human Factors v2.1 | 7-13 Perception of Risk INDIVIDUAL BEHAVIOUR IN THE FACE OF DANGER Model The Hale and Glendon Model • Accident proneness model. Here is some brief information regarding this model. System Approach A system comprises an organisation of a number of interrelated elements interacting with each other within a system boundary. In these systems the elements are usually hardware (machines, buildings, materials) and people, which interact physically or through the exchange of information governed by rules and procedures. The system boundary may be the factory walls, those of the department, the confines of the car someone is driving, or some other boundary appropriate to the level of the analysis undertaken. Outside the boundary is the system environment. The system has a number of goals or objectives that it is attempting to achieve, e.g. making a profit, producing a given output, or getting from A to B without having an accident. Implicit in the existence of goals is the need for a feedback mechanism, whereby the system compares its current position and state with those goals in order to guide that progress. The book looks at the following models: • Engineering models, e.g. fault tree analysis – this does not work well for humans because they have too many failure modes. • Interactive models, e.g. Hale and Hale involving perception. The models suggested by Hale and Hale, and by Rasmussen and Reason, are combined to produce the model of behaviour in the face of danger given in the following figure. This diagram is also reproduced in Ridley. The figure is in the form of an algorithm and is relatively easy to follow. You start at the bottom centre with the OBJECTIVE DANGER. A solution to the situation is sought using increasing levels of activity. An open system communicates across the system boundary with its environment and with other systems. Some Definitions • Danger: a situation or system state in which there is a reasonably foreseeable potential for unintended harm to human or physical elements in the system. • Hazard: a specific agent which in defined circumstances would cause damage to a system element. Every dangerous situation therefore contains one or more hazards. • Risk: the probability that damage of a specific type to specified system elements will occur in a given system over a defined time period. • Harm: damage to a system element so that it can no longer carry out its system function and requires repair, treatment or rehabilitation over a significant period. • Accident: the process of occurrence of unintended harm where exposure to the hazard results immediately in harm. • Safety: the converse of danger; a situation in which the system is under control and the harm process has not begun. 7-14 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Perception of Risk Behaviour in the face of danger model (Reproduced from Individual Behaviour in the Control of Danger by A. R. Hale and A. I. Glendon (1987) with kind permission from Elsevier Science - NL, Sara Burgerhartstaat 25, 1055 KV Amsterdam, The Netherlands) © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-15 Perception of Risk REVISION QUESTIONS 4. Outline, with examples, how the human sensory receptors react to danger. 5. Explain how failings in the human sensory and perceptual process may lead to accidents. (Suggested Answers are at the end.) 7-16 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Human Failure Classification KEY INFORMATION • Human failure can be classified as errors and violations. • Errors are actions or decisions which were not intended, and involved a deviation from an accepted standard which led to an undesirable outcome. • Errors can be split into three types: slips, lapses and mistakes. • Violations are a deliberate breaking of safety rules. • There are three types of violation: routine, situational and exceptional. • The study of actual incidents gives us insight into the way that human error can contribute to major disasters. HSG48, CLASSIFICATION OF HUMAN FAILURE The UK’s HSE publication, Reducing Error and Influencing Behaviour, HSG48, identifies two types of predictable human failure: errors and violations. Errors Errors are actions or decisions which were not intended and involved a deviation from an accepted standard which led to an undesirable outcome. Errors can be further split into several types (based on the Rasmussen’s skill-, rule- and knowledge-based behaviour theory). Errors Skill-based Errors Slips of Action Mistakes Lapses of Memory Rule-based Mistakes Knowledgebased Mistakes Types of error © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-17 Human Failure Classification TOPIC FOCUS Skill-Based Errors (Note: The term “skill” as used by Rasmussen (and here) is not used in the way people generally understand it.) These types of errors occur in very familiar tasks which require little conscious attention, e.g. an experienced driver driving on a familiar road. Errors can occur when we are distracted or interrupted. • Slips – failures in carrying out the actions of a task. Examples include: –– Performing an action too soon or too late. –– Leaving out a step or series of steps from a task. –– Carrying out an action with too little or too much strength. –– Performing the action in the wrong direction. –– Doing the right thing but with regard to the wrong object (or vice versa). • Lapses – forgetting to carry out an action, losing a place in a task or forgetting what we had intended to do. These are often linked to interruptions or distractions. Using a simple checklist can help to reduce the likelihood of lapses occurring. Possible prevention strategies for skill-based errors include: verification checks, such as checklists; feedback warning signals if wrong action selected; design of routines to be distinct from each other; and supervision. Mistakes These are where we do the wrong thing believing it to be right. The failure involves our mental processes that control how we plan, assess information, decide on our intentions and judge consequences. • Rule-Based Mistakes These occur when our programme is based on remembered rules or procedures. We have a strong tendency to try to use or select familiar rules or solutions. Errors occur if: –– No routine is known which will solve the new situation, so we don’t know what to do. –– We try to apply the usual remembered rules and familiar procedures because of familiarity with similar problems from previous experience, even when they are not appropriate. –– The wrong alternative is selected, or there is some error in remembering or performing a routine. Possible prevention strategies include: simple, clear rule sets; system designed to highlight unusual or infrequent occurrences; clear presentation of information. • Knowledge-Based Mistakes These may occur in unfamiliar situations where no tried and tested rule exists. They are often related to incomplete information being available or misdiagnosis where, when facing new or unfamiliar situations, we are trying to solve problems from first principles. Errors occur when: –– Some condition is not correctly considered or thought through or when the resulting effect was not expected or is ignored. –– There is insufficient understanding or knowledge of the system. –– There is insufficient time to properly diagnose a problem. Possible prevention strategies include: training; supervision; use of checking systems; provision of sufficient time and knowledge. Violations Violations are a deliberate deviation from a rule or procedure, e.g. driving too fast or removing a guard from a dangerous piece of machinery, both of which increase the risk of an accident. Health risks are also increased by rule breaking, e.g. a worker who does not wear ear defenders in a noisy workplace increases their risk of occupational deafness. 7-18 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Human Failure Classification TOPIC FOCUS There are three types of violation: Routine A routine violation is the normal way of working within the work group and can be due to a number of (sometimes overlapping) factors, including: • Cutting corners to save time and/or energy – which may be due to: –– Awkward, uncomfortable or painful working posture. –– Excessively awkward, tiring or slow controls or equipment. –– Difficulty in getting in or out of maintenance or operating position (posture). –– Equipment or software which seems unduly slow to respond. –– High noise levels which prevent clear communication. –– Frequent false alarms from instrumentation. –– Instrumentation perceived to be unreliable. –– Procedures which are hard to read or out of date. –– Difficult to use or uncomfortable personal protective equipment. –– Unpleasant working environments (dust, fumes, extreme heat/cold, etc.). –– Inappropriate reward/incentive schemes. –– Work overload/lack of resources. • Perception that rules are too restrictive, impractical or unnecessary (particularly where there has been a lack of consultation when they were drawn up). • Belief that the rules no longer apply. • Lack of enforcement of the rules (e.g. through lack of supervision/monitoring/management commitment). In certain cases the violation may even be sanctioned by management “turning a blind eye” in order to get the job done (related to cutting corners, see above). • New workers starting a job where routine violations are the norm and not realising that this is not the correct way of working. This in itself may be due to culture/peer pressure or a lack of training. Situational Situational violations are where the rules are broken due to pressures from the job, such as: • Time pressure. • Insufficient staff for the workload. • The right equipment not being available. • Extreme weather conditions. Risk assessments should help to identify the potential for such violations, as will good two-way communications. Exceptional Exceptional violations rarely happen and only occur when something has gone wrong. To solve a problem, workers believe that a rule has to be broken. It is falsely believed that the benefits outweigh the risks. Means of reducing such violations could include: • Training for dealing with abnormal situations. • Risk assessments to take into account such violations. • Reduction of time pressures on staff to act quickly in new situations. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-19 Human Failure Classification HSG48 provides a powerful model showing the type of human errors and violations that can be predicted from consideration of organisational, job and individual factors. Such a model can be used both in risk assessments and accident investigations to suggest the control measures required to prevent either an occurrence or a recurrence. MORE… You can download Reducing Error and Influencing Behaviour, HSG48, from the HSE website at: www.hse.gov.uk/pubns/priced/hsg48.pdf CONTRIBUTION OF HUMAN ERROR TO SERIOUS INCIDENTS No study of human error will be complete without some consideration of major incidents. In each case you need to consider the part played by human error. An investigation usually apportions blame, but although some blame will be attached to those who are directly involved, the majority of the blame is usually placed on those in responsible management positions. Safety practitioners usually carry some responsibility as well. Seveso (near Milan, Italy), 1976 This disaster is named after the village near Milan, Italy, whose inhabitants were so badly affected. It involved the release of a cloud containing, amongst other things, the highly toxic and carcinogenic compound, 2,3,7,8-tetrachlorodibenzodioxin (also called simply “dioxin”) from a chemical plant run by Icmesa Chemical Company. The plant at Seveso was running a process to manufacture pesticides and herbicides. Dioxin was normally produced as a by-product of the reaction, but only in very small quantities if the temperature was controlled below critical levels. The incident happened at the weekend, when the plant was shut down (required by Italian law). However, the plant had been shut down partway through production so that the steam-heated vessel had been left full of reactants. It is thought that, as other processes in the plant were shut down, the steam temperature rose. A reaction occurred which eventually overheated and became a thermal runaway (the reactor had no automatic cooling). The ensuing very high temperatures produced large quantities of dioxin as a by-product. The pressure increased greatly, rupturing a bursting disc off the reaction vessel and resulting in the release of most of its contents into the atmosphere via a vent set at roof level. Approximately 6 tonnes of reactants (including sodium hydroxide) and an estimated 1 – 2 kg of highly toxic dioxin were dispersed into the atmosphere. The cloud drifted to the nearby village of Seveso. 7-20 The seriousness of the effects on the population was not immediately recognised. Dioxins are fatsoluble. Consequently they have a strong tendency to bioaccumulate (i.e. accumulate in the body from the surroundings and remain in the body for some considerable time). Approximately 2000 people were treated for dioxin poisoning. The area was made uninhabitable due to contamination. Recorded health effects included birth defects, skin disease (chloracne) and liver cancer. Factors contributing to the accident: • The legislative environment – well-intentioned law regarding weekend plant shutdowns that did not allow management discretion to complete a batch process. • The process was stopped at an unusual stage (never before stopped at this stage). • No systematic hazard analysis, such as HAZOP, had been carried out on the process – the potential consequences would almost certainly have been picked up if a HAZOP had been conducted. • Inadequate reaction/process control: no cooling or stirring when the process was stopped for the weekend; inadequate sensors for measuring critical process parameters; lack of automatic systems; no catch-pot system to intercept toxic by-products instead they were vented directly to atmosphere when the bursting disc failed during overpressure. • No emergency response plan; indeed no safety management system. The disaster led to the creation of new laws throughout Europe on the control of such major accident hazard sites. | Unit IA – Element IA7: Human Factors © RRC International v2.1 Human Failure Classification Chernobyl (Ukraine), 1986 Factors that led to the accident: Chernobyl is situated just north of Kiev, in Ukraine. At the time, Ukraine was part of the Soviet Union. The power station had several reactors and the accident happened with reactor number 4. This accident occurred during experiments carried out during a planned shut-down. The proposed experiments were reasonable, but there were a number of errors of judgment that occurred. The sequence of events is quite complicated so only a short summary is provided here, as we are focusing more on lessons to be learned. • The reactor design was flawed – there are inherently safer designs. There was also no trip system to prevent running at low outputs. There was an automatic shutdown system to insert all the control rods to shut down the reactor but this had been disabled (see earlier). In this design of reactor, called a Boiling Water Reactor, the nuclear fuel is held in zirconium alloy tubes which are embedded in a block of graphite (which acts as a “moderator” and enables the desired nuclear reaction to take place). Boiling water is passed through these tubes as a coolant. Control rods (of which there were about 200 in this design) control the rate of the nuclear reaction (by absorbing neutrons) as they are moved in (and out) of the graphite block. They can be used to shut down the reactor under emergency conditions. Even if the reactor is shut down, residual heat is still produced by the normal radioactive decay. Because of this, cooling must always be maintained. This nuclear core was encased in a concrete shield. Management wanted to conduct several repeats of the experiment. In between these experiments, the reactor should have been shut down. However, because time was short, they had decided instead to simply take the reactor down to low output conditions between experiments (it would otherwise take far too long to bring the reactor on-line from a shut down). This would be achieved by lowering control rods into the reactor core. However, it was well known that this design of reactor was unstable under low output conditions (this design of reactor is not used outside of the former Soviet Union). Prolonged running at low output levels produces a build up of a by-product (Xenon) which actually “poisons” the reactor, greatly reducing its output. Consequently, it appears that the output fell quicker and to much lower levels than intended. In an attempt to correct the situation, control rods were raised and an automatic shut-down system (which operates under fault conditions) was disabled. At first, power began to rise again but then suddenly surged uncontrollably. By now, around six control rods remained in the core – the minimum should be 30. • Basic safety rules were not clearly stated (there should have been an instruction to forbid running at low output levels) and normal safety rules were not followed during the experiment. (It was important to keep the reactor output above a minimum of 20%, as below this it could become unstable. In the experiment, it went down to around 6% output.) Also, at least 30 control rods should always have been in place as a minimum – instead, all but six were removed. Protective systems were disabled – the automatic trip which would have shut down the reactor under fault conditions was isolated. • Poor safety culture – turning a blind eye to rule breaking; lack of proper authorisation of the experiments (at the appropriate management level); lack of inspection/regulation; culture of “sloppiness”. • Lack of proper planning of the experiment – in particular, consideration of how things might go wrong and their potential consequences. • Poor understanding of the consequences of their actions by the operators (e.g. they did not understand the importance of keeping a minimum number of control rods in place to control the reactor). Despite activating emergency manual shutdown (manual insertion of the control rods), it was too late. The reactor core temperature had risen enormously (heat output increased 100 fold in one second!), rising to around 4000°C. Eventually, several explosions shattered the reactor roof, allowing radioactive material to be released into the atmosphere and, eventually, spread all over the world’s northern hemisphere. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-21 Human Failure Classification Three Mile Island (USA), 1979 Bhopal (India), 1984 Three Mile Island nuclear plant is near Middletown, in Pennsylvania, USA. This is another nuclear incident, though with far less serious consequences than that of Chernobyl. Though the reactor core went into meltdown, there were only small releases of radioactivity and no deaths/injuries. The reactor in this case was of a different design to that of Chernobyl – it was a Pressurised Water Reactor (PWR), which is a very common design throughout the world (other than in the former Soviet Union). In this design, the primary coolant water is kept pressurised so that it does not boil. The primary coolant water passes the heat on to a secondary water system (via a heat exchanger), which is allowed to boil – the steam driving a turbine to generate electricity. Bhopal is in India. A Union Carbide chemical plant was situated here. The accident involved a leak of some 25 tonnes of highly toxic methyl isocyanate (MIC) from a storage vessel. The cloud of MIC dispersed and killed around 2000 people and injured another 200000. These were official figures - estimates put the real number of fatalities closer to 10000. To summarise, the incident started with a failure of the secondary circuit – which prevented heat removal. This caused the reactor to shut down and the pressure in the primary circuit to increase. This in turn triggered the opening of a pressure relief valve which, unfortunately, stuck open instead of closing again when the pressure had reduced. As it happened, the signals on the operating consoles indicated that the valve had shut (the lamp was triggered by the circuit signal to the valve rather than the actual valve position). The continued escape of the coolant through the valve allowed the core to overheat. Coupled with this was the confusing instrumentation available to the operators. There was no coolant level indicator – instead it was inferred from levels elsewhere in the system (but these levels had actually been raised by bubbles of steam). Alarms began to sound but at that stage the nature of the unfolding incident was not recognised as a “loss of coolant” incident. Immediate actions included reducing the coolant flow in the core (their training had emphasised the danger of too much coolant and, of course, they believed, from the instrumentation, that the pressure relief valve was shut); this made things worse. If they had done nothing, the plant would have cooled down on its own. Instead, the core continued to overheat and the fuel began to melt. Factors that led to the accident: • Operators were under considerable stress – many alarms were going. They had incorrectly diagnosed what they thought was the problem and stuck to a course of action, despite apparently overwhelming evidence to the contrary. • Operator training was inadequate. Operators of complex plant cannot just be given a series of instructions to follow. Things are bound to go wrong outside of this. They also need to understand the principles of the process, and be trained in diagnosing problems (both foreseen and unforeseen) and in the use of diagnostic aids. • The crucial indicator (of the status of the pressure relief valve) was wrong. This did not look at the status of the relief valve directly – it should have done. 7-22 MIC was used by Union Carbide as an intermediate in the manufacture of an insecticide. The storage vessel containing MIC became contaminated with large quantities (tonnes) of water and chloroform. There is considerable debate on how this could have happened, but one serious possibility is that it was deliberate sabotage. This initiated a thermal runaway reaction (water reacts violently with MIC), which caused the pressure and temperature to increase. Instruments indicating the high pressure and temperature were ignored (they were considered unreliable). The growing vessel pressure was vented to atmosphere by the operation of a pressure relief valve. Because of the toxic nature of this compound, it should never have been allowed to be vented into the open, or at least discharge should have been kept to a minimum. Protective systems installed in/on the storage vessel included a refrigeration system (which would have cooled the reaction), a scrubber (to absorb much of the vapour discharged) and a flare stack (which would have burnt off any remaining vapour). However, none of these were working at the time. Factors that contributed to the accident: • The large inventory of the intermediate. This was unnecessary. It was not a raw material nor a product but an intermediate. It should not have been stockpiled but instead used in the next stage of the process as it was produced, or at least kept to a minimum. • The plant was located next to a sizable population. A shanty town (temporary housing) had been allowed to grow up very close to the plant. This should not have been allowed - either by planning legislation or by Union Carbide buying and fencing off the surrounding land. • Protective systems were not kept in working order. Even if they had been working, they are likely to have been inadequate to control a thermal runaway of this magnitude (but would certainly have reduced the effects). • No systematic study (such as HAZOP) undertaken to identify any suggested contamination routes (it is well known that water and MIC react together violently) and therefore implement measures to eliminate the likelihood of this happening. • Process parameter instrumentation was poorly maintained and unreliable - led to early signs of pressure/temperature increase being ignored. | Unit IA – Element IA7: Human Factors © RRC International v2.1 Human Failure Classification • There is some suggestion that managers and operators at the plant had insufficient experience and knowledge. The plant was a joint venture – part owned by Union Carbide and part owned locally. • Poor emergency planning. Buncefield (UK), 2005 The Buncefield incident was a major fire caused by a series of explosions in the early hours of Sunday 11 December 2005 at the Buncefield Oil Storage Depot, Hemel Hempstead, Hertfordshire, UK. At least one of the initial explosions was of massive proportions and there was a large fire which engulfed a large proportion of the site. Over 40 people were injured but there were no fatalities. Significant damage occurred to both commercial and residential properties in the vicinity and a large area around the site was evacuated on emergency service advice. The fire burned for several days, destroying most of the site and emitting large clouds of black smoke into the atmosphere. The cause of the incident was the formation of a flammable mixture of petrol, or similar spirit, and air that ignited, leading to the explosions and fire. The sequence of events was as follows: 10 December 2005: Around 19.00, Tank 912 in bund A at the Hertfordshire Oil Storage Ltd (HOSL) West site started receiving unleaded motor fuel from the T/K South pipeline, pumping at about 550m3/hour. 11 December 2005: At approximately midnight, the terminal was closed to tankers and a stock check of products was carried out. When this was completed at around 01.30, no abnormalities were reported. From approximately 03.00, the level gauge for Tank 912 recorded an unchanged reading. However, filling of Tank 912 continued at a rate of around 550m3/hour. Calculations show that at around 05.20, Tank 912 would have been completely full and starting to overflow. Evidence suggests that the protection system which should have automatically closed valves to prevent any more filling did not operate. From 05.20 onwards, continued pumping caused fuel to cascade down the side of the tank and through the air, leading to the rapid formation of a rich fuel/air mixture that collected in bund A. At 05.38, CCTV footage shows vapour from escaped fuel starting to flow out of the north-west corner of bund A towards the west. The vapour cloud was about 1m deep. At 05.46, the vapour cloud had thickened to about 2m deep and was flowing out of bund A in all directions. By 05.50, the vapour cloud had started flowing off site near the junction of Cherry Tree Lane and Buncefield Lane, following the ground topography. It spread west into Northgate House and Fuji car parks and towards Catherine House. At 06.01 the first explosion occurred, followed by further explosions and a large fire that engulfed over 20 large storage tanks. The main explosion event was centred on the car parks between the HOSL West site and the Fuji and Northgate buildings. The exact ignition points are not certain, but are likely to have been a generator house in the Northgate car park and the pump house on the HOSL West site. At the time of ignition, the vapour cloud extended to the west, almost as far as Boundary Way in the gaps between the 3-Com, Northgate and Fuji buildings; to the north west it extended as far as the nearest corner of Catherine House. It may have extended to the north of the HOSL site as far as British Pipelines Agency (BPA) Tank 12 and south across part of the HOSL site, but not as far as the tanker filling gantry. To the east it reached the BPA site. There is evidence suggesting that a high-level switch, which should have detected that the tank was full and shut off the supply, failed to operate. The switch failure should have triggered an alarm, but that too appears to have failed. The UK Health Protection Agency and the UK Major Incident Investigation Board provided advice to prevent incidents such as these in the future. The primary need was for safety measures to be in place to prevent fuel from exiting the tanks in which it is stored. Added safety measures were needed for when fuel does escape, mainly to prevent it forming a flammable vapour and to stop pollutants poisoning the environment. Piper Alpha Oil Rig Explosion (North Sea), 1988 On 6 July 1988, there was a disastrous fire on the Piper Alpha oil rig in the North Sea; 167 men were killed and many who survived were injured and traumatised. The rig was operated by Occidental Petroleum (Caledonian) Limited. Piper Alpha was part of a linked operation involving four rigs. The operation involved gas, compressed gases and crude oil. The various operations on Piper Alpha were in modules which were stacked on top of each other. The helicopter landing pad was on the highest level, and on top of the main accommodation module. Two-hundred and twenty-six men were on the platform; 62 were working the night shift, and the majority of the others were in the accommodation modules. Between 05.50 and 06.00, the pumping rate down the T/K South pipeline to Tank 912 gradually rose to around 890m3/hour. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-23 Human Failure Classification At 22.00 hours there was an explosion followed by a fireball which started from the west end of B module. This was quickly followed by a series of smaller explosions. The emergency systems, including fire water systems, failed to operate. Three mayday calls were sent out, and the personnel assembled on D deck. The radio system and the lighting then failed. At 22.20 hours there was a rupture of the gas riser of the Tartan supply (another rig – but the pipeline was connected to Piper Alpha), followed by another major explosion, with ignition of gas and crude oil. At 22.50 there was a further explosion with a collapse of much of the structure. There was a mass of photographic evidence, taken from the other rigs and ships in the area, but some problem in fixing the exact time of each. The enquiry was very thorough, but unable to come up with clear conclusions. Gas detection equipment was working, but some water systems had been turned off, and some welding operations were in progress. The report criticised the platform design, and the lack of safety systems. It called for major changes in disaster planning and auditing. The key factors leading to the disaster included: • Failure in the permit-to-work system. • Design failure in that the rig containment wall was fireresistant but not blast-resistant. • Other rigs did not shut down and continued to feed into Piper Alpha, fuelling the fire. • Inadequate emergency procedure for rig evacuation. Texas City (USA), 2005 On 23 March 2005, a series of explosions occurred during the restarting of a hydrocarbon isomerisation unit at BP’s Refinery in Texas City, Texas, USA. A distillation tower flooded with highly flammable liquid hydrocarbons and was over pressurised, causing a release of liquid from the top of the stack and a cloud of flammable vapour to form over the refinery. A diesel pickup truck that was idling nearby ignited the vapour, initiating a series of explosions and fires that swept through the unit and the surrounding area. Most of the 15 people killed were in administration trailers placed too close to the tower, which instantly disintegrated. A further 180 people were injured, 70 vehicles were damaged and windows shattered as far away as three quarters of a mile. The US Chemical Safety and Hazard Investigation Board investigation found that approximately 7600 gallons (28800 litres) of flammable liquid hydrocarbons - nearly the equivalent of a full tanker truck of gasoline - were released from the top of the blow-down drum stack in just under two minutes. The ejected liquid rapidly vaporised due to evaporation, wind dispersion, and contact with the surface of nearby equipment. High overpressures from the resulting vapour cloud explosion totally destroyed 13 trailers and damaged 27 others. People inside trailers were injured as far as 500 feet (152 metres) away from the blowdown drum, and trailers nearly 1000 feet (305 metres) away sustained damage. The distillation tower overfilled because a valve allowing liquid to drain from the bottom of the tower into storage tanks was left closed for over three hours during the start-up on the morning of 23 March, which was contrary to unit start-up procedures. The investigation found that procedural deviations, abnormally high liquid levels and pressures, and dramatic swings in tower liquid level were the norm in almost all previous start-ups of the unit since 2000. Operators typically started up the unit with a high liquid level inside and left the drain valve in manual - not automatic - mode to prevent possible loss of liquid flow and resulting damage to a furnace that was connected to the tower. These procedural deviations - together with the faulty condition of valves, gauges, and instruments on the tower - made the tower susceptible to overfilling. The investigation identified numerous failings in equipment, risk management, staff management, working culture at the site, maintenance and inspection, and general health and safety assessments. REVISION QUESTION 6. How did human error contribute to the Three Mile Island incident? (Suggested Answer is at the end.) 7-24 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Improving Individual Human Reliability in the Workplace KEY INFORMATION Human reliability may be improved by: • Incentive and reward schemes. • Increasing job satisfaction. • Appraisal schemes. • Selecting appropriate individuals for the job: –– –– –– –– –– Matching skills and aptitudes. Training and competence assessment. Ensuring fitness for work. Health surveillance. Support for ill health including stress-related illness. MOTIVATION AND REINFORCEMENT Workplace Incentive and Reward Schemes GLOSSARY INCENTIVE An inducement that provides a motive for someone to do something, usually in the form of some sort of reward for achieving a particular goal or milestone. (Note that the words ‘incentive’ and ‘reward’ in this context are routinely used interchangeably.) Workplace incentive or reward schemes can be a good way of motivating workers to focus on the job and conform to the organisational goals. The incentive encourages workers to work harder in order to receive a payment or benefit. For example, achieving a set target or exceeding that target may mean that individuals receive a financial bonus or a prize. The scheme may operate on an individual basis or as a team effort, in which case the incentive would be for the team to achieve the target. The incentive scheme may be set up so that a winning team or individual is identified every month, for example, and the winner is given a prize. This type of incentive motivates individuals to work harder, but also motivates teamwork. Some pay schemes work by paying a very low actual salary, but having bonus payments which are paid when targets are met, e.g. sales jobs. The motivation to sell more is clearly through the financial gain. Piecemeal work, i.e. where workers are paid per work unit completed, (e.g. for each sheep sheared) encourages individuals to work quickly so that they can earn more money. This may have implications with respect to safety as the workers are not encouraged to necessarily consider safety as their first priority. © RRC International Incentive schemes aimed at improving safety are more difficult as they may need to monitor the results over a reasonable time period, e.g. one year. Incentive schemes can often lose their momentum and their effectiveness over time. For this reason, it is important to either keep the time periods short or continue to keep the momentum high. Incentive schemes for safety may relate to obtaining improved ‘scores’ during routine audits or inspections. This type of incentive would be aimed at ensuring all members of the workforce made their work area as safe as possible and that work was carried out in a safe manner. Avoid incentives aimed at reducing accidents specifically, i.e. where measurement would be a decrease in accident rates, as this may result in under-reporting of accidents in order to obtain the incentive. Job Satisfaction For some people, job satisfaction is all that they require to be motivated. Job satisfaction is also very individual to each person: • Some people are satisfied with a good working environment and regular rest breaks. • Other people require challenging, stimulating work where they receive positive feedback. You will remember that Herzberg identified particular motivating factors which, when present, increase satisfaction from work and provide motivation towards superior effort and performance. These include recognition, responsibility, achievement, advancement and the work itself, and are distinct from other factors that increase dissatisfaction when absent, but when present, do not result in positive satisfaction and motivation. Herzberg termed these “hygiene” factors. They include: type of supervision, salary/wages, working conditions, company policies, rules, etc. Unit IA – Element IA7: Human Factors v2.1 | 7-25 Improving Individual Human Reliability in the Workplace Appraisal Schemes GLOSSARY APPRAISAL SCHEME A formal means of placing value on achievement or effort, generally carried out on an annual basis. The results may be used to determine the level of a pay rise or a promotion. Appraisal schemes usually involve the worker filling in a self-appraisal form that is discussed at an interview with their manager. A report is produced at the end of the interview with a copy being provided to the worker and to a senior manager, and a copy placed on the worker’s personal file. The self-appraisal form may request information about what the worker feels they have accomplished in the past year and their high and low points. It may also ask what areas the worker is dissatisfied with and what improvements they would like to see. The form may also ask about the worker’s aspirations for the coming year. In this way, the worker is given an opportunity to identify what areas of their job they are satisfied with and what areas they are dissatisfied with. They may also come up with ideas to improve their job or to improve themselves, e.g. additional training. This scheme gives the manager an opportunity to discuss with the worker their thoughts on the worker’s progress, and give praise and encouragement where required. Some appraisal schemes give the worker the opportunity to comment on their manager. This needs to be anonymous if there is a chance of reprisal. Appraisal schemes are an excellent way of finding out what problems exist within a workplace and, therefore, give the opportunity for improvement. They also provide a measure of the safety culture within an organisation. More importantly, they allow the worker to comment on their own progress and to voice their opinions. Workers in appraisal schemes will often feel more motivated than those not in such a scheme, particularly where hard work and improvements are rewarded. Appraisal schemes usually require the worker to complete an appraisal form SELECTION OF INDIVIDUALS Matching Skills and Aptitudes An employer may wish to select only those workers who will conform to his or her safety standards – either existing workers for new or different tasks or prospective workers. This selection process is often by interview (at least in part) and sometimes involves aptitude tests. Be aware that selection in this way may not lead to large improvements in reliability because people may behave differently once they have the job. Some of the best selection techniques involve competency-based interviewing which identifies the skills, talents and abilities required by the job and may assess: • Effectiveness of communication (verbal and written). • Problem-solving ability. • Ability to use technology. • Whether they provide input or views on safety issues. • Whether they follow safety instructions. • Teamwork, etc. 7-26 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Improving Individual Human Reliability in the Workplace Training and Competence Assessment • On-the-Job Training On-the-job training provides trainees with experience which is a combination of work-based knowledge and skills development. As the trainee gains experience, the range and complexity of tasks that he/she can undertake without detailed guidance increases. The process of learning can be improved by: –– Demonstration. –– Coaching (carrying out tasks with guidance). –– Projects. The instructor assesses the competence of the trainee as their skill level increases. This training is effective, providing the trainee is shown the correct way of carrying out the task; bad habits can develop from the start if the trainee is placed with someone who does not follow the correct procedures. • Off-the-Job Training Off-the-job training is carried out away from the work environment in a number of ways: –– Lectures - one-way communication in which all the talking is done by the lecturer. It is a good way of teaching a large number of students simultaneously. The limitations are: –– There is a very low rate of retention. Adequate backup notes are essential. –– Students may not understand the presentation and be unable to seek clarification. • Seminars - where discussion is encouraged and students can learn from the instructor and from each other. The number of students who can usefully take part at one seminar is a limiting factor. • Programmed instruction - provided through a combination of distance learning or open learning packs, computer or audio-visual programmes with no direct involvement of an instructor. However many distance learning packages do have access to tutors for advice or assistance through e-mail or telephone contact. Fitness for Work and Health Surveillance Some jobs, often called ‘safety critical’, involve activities that require a person’s full, unimpaired control of their physical and mental capabilities. For example, a tower crane operator will need: • To be able to climb safely up the mast to the cab. • Good eye sight. • To not suffer from any condition that might make him or her prone to lose consciousness. © RRC International In such circumstances the employer would require a full medical assessment of the prospective worker by an occupational health practitioner. Although the results of the assessment are confidential to the worker and the practitioner, the employer can expect to be given a general report specifying whether the prospective worker is: • Fit for work. • Fit for work with restrictions. • Temporarily unable to meet the fitness standard. • Unable to meet the fitness standard for work to carry out specific jobs. Health surveillance involves implementing systematic, regular and appropriate procedures to detect early signs of work-related ill health among workers exposed to certain health risks and then taking appropriate action. Examples include hearing tests, lung function tests and blood tests for substances such as lead. For most workers, employment health surveillance is not necessary, but criteria to indicate where health surveillance could be valuable include: • Specific legal requirements. • An identifiable disease or adverse health condition related to the work concerned. • Valid techniques available to detect indications of the disease or condition. • A reasonable likelihood that the disease or condition may occur under the particular conditions of work. • Surveillance likely to further the protection of the health and safety of the workers to be covered. Support for Ill Health and Stress Providing support for workers suffering from ill health (including stress) will be beneficial for both the worker and the employer. A good occupational health service will advise on a rehabilitation programme so that the worker can readjust to the work environment and not jeopardise their recovery. For example, an individual who has suffered from a stress-induced illness, such as symptoms of anxiety or depression (whether or not it has been caused or made worse by the work) is likely to benefit from working parttime before returning to full duties. REVISION QUESTION 7. Identify four different methods by which employees can be motivated. (Suggested Answer is at the end.) Unit IA – Element IA7: Human Factors v2.1 | 7-27 Organisational Factors KEY INFORMATION • Human error is increased by inadequacies in: –– Policy. –– Setting of standards. –– Planning. –– Information. –– Responsibilities. –– Monitoring. • The safety culture of an organisation has a major influence on behaviour as does the development of small groups and peer pressure. • In any organisation there are both formal and informal structures. • Communication mechanisms within an organisation vary in their complexity, reliability and formality. • During periods of change, conflict may occur which needs to be resolved. EFFECT OF WEAKNESSES IN THE SAFETY MANAGEMENT SYSTEM ON THE PROBABILITY OF HUMAN FAILURE Information Inadequacies in Policy • Accurate, Organisations must recognise that they need to consider human factors as a distinct element which must be recognised, assessed and managed effectively in order to control risks. For this reason, human factors must be considered and included in the company health and safety policy; if they are not, then it is more likely that these important factors that can affect the way in which individuals work will be overlooked and human failure is more likely to occur. For example, some of the common organisational causes of human failure include: • Inefficient co-ordination of responsibilities. • Poor management of health and safety. Both of these stem back to inadequacies in policy. If the health and safety policy defines the responsibilities correctly and the ways in which health and safety are to be managed, then failure is less likely to occur due to these causes. The availability of information within an organisation or system is vital and the information should be: • Timely (e.g. it is no good being informed of a new procedure three weeks after the implementation date), and • Relevant. Too much information can be overwhelming and will mean that the important bits may get overlooked. Providing the right information, at the right time, and to the right people, is not easy, but it goes a long way to ensuring a good working system and one where the workers feel involved and appreciated. One example is ensuring written instructions (including warning signs) are clearly understood by everyone in an appropriate language. Anyone who has worked for a company where information was not provided adequately knows the confusion and mistrust this can cause. The information required may range from the structure of the organisation and the responsibilities within it, to the operating instructions for a piece of equipment. Setting of Standards The setting of standards and the use of benchmarking is a feature of any safety management system. Recognising human error is essential in such areas as identifying foreseeable misuse is a necessary element of a suitable and sufficient risk assessment. 7-28 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Organisational Factors Planning The proper planning of a system ensures that it works effectively, and so all aspects of it must be taken into account. This includes the inputs, the outputs, the work in the middle (production/processing) as well as the effect of the environment. All these areas need to be looked at to see how they affect the system or how the system affects them. Different scenarios should be considered so that the system can operate in changing circumstances. For efficient working, system planning must take account of relationships between processes, i.e. the organisation and communications, and the ability to adapt to change. This might include: • Proper work planning, including the task steps as well as relationships with other tasks – to remove unnecessary work pressure. • Properly integrated procedures and safe systems of work. • Proper co-ordination. • Communications – two-way to allow feedback for improvements and clarification. Responsibilities To implement an effective system, everyone involved must understand their role and how it integrates into the system. Each person must also appreciate the effect on the system as a whole if they don’t play their part. Unless responsibilities are clearly defined and understood, there will be an increased risk of tasks not being fulfilled, e.g. maintenance. This will have a consequential effect on safety and health. Monitoring Feedback and monitoring of a new system is vital to ensure that the system works and that, where necessary, improvements are made. Human error is significantly reduced by providing proper, timely feedback to the individual or group. INFLUENCE OF SAFETY CULTURE ON BEHAVIOUR AND EFFECT OF PEER GROUP PRESSURES AND NORMS The safety culture of an organisation has a profound impact on the behaviour of those who work within it. A poor safety culture will tolerate indifferent and even dangerous behaviour, which will inevitably become the norm so that even workers well aware of unsafe practices will tolerate poor practices. One such influence is peer pressure from work colleagues. GLOSSARY PEER A person of the same level or rank. Group Formation In a social situation we group ourselves with those of a similar outlook. In the work situation, we have little choice as to who we work with. A lot of work situations involve group work or committees and discussion groups. Social groups are an essential part of life, since many activities cannot be performed alone. Group Reaction In large groups, the majority scarcely speak at all; there is often a wide variety of personalities and talent. There are differences in behaviour and opinions, discussion is restrained, and disagreement is easily expressed. The group tends to create rules and arranges for division of labour. Most people prefer to belong to a fairly small group. Each individual can then exert influence on the group, and speak when they wish to, and there is adequate variety of personality to tackle common tasks, and for social purposes. Group Development Groups develop ‘pecking orders’ in terms of the amount of speech and influence permitted. Dominant individuals struggle for status and an order develops, which might not be the one that management would want. Low status members talk little, speak politely to senior members, and little notice is taken of what they have to say. A person’s position in the group depends on his or her usefulness. The system is maintained. A person who talks too much is stopped. High status members are encouraged to contribute. Group interaction depends on the person’s status within the group. When away from the group, a person reverts to his or her own individual personality. A person can be dominant at work, and yet introverted when away from the workplace. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-29 Organisational Factors Group Control A group will: • Establish standards of acceptable behaviour or group ‘norms’. • Detect deviations from this standard. Nearly all organisations are hierarchical in structure, i.e. they have different levels of authority and responsibility within their structure. The simplest way of depicting such a functional hierarchy is with a line diagram (or organisation chart) similar to the one that follows. • Have power to demand conformity. Attempts to modify the behaviour of an individual group member who does not conform to group norms might involve: • The “cold shoulder”. • Verbal hostility and criticism. • Ridicule. • Spreading unflattering gossip. • Harassment. • Disruption of work. • Overt intimidation. • Physical violence. There are differences between the methods used by groups of men and groups of women; groups may engage in gender and racial discrimination, which is difficult for management to control. A lot of safety and health activity tends to be aimed at the individual, when it is much better to target the group. If the dominant leader of the group is very safety-conscious, then safety can quickly become a group norm. INFLUENCE OF FORMAL AND INFORMAL GROUPS Formal Groups You will remember that we looked at formal and informal organisations in an earlier element. Formal organisations: • Are established to achieve set goals, aims and objectives. • Have clearly defined rules, structures and channels of communication. • Are often divided into productive and nonproductive, productive organisations being involved in the production of goods and services. To be successful, an organisation has to have clearly defined objectives and be positive in aiming to achieve them in the most efficient manner. Where this positive direction is lacking, an organisation is likely to fail. 7-30 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Organisational Factors Managing Director Executive Director, Marketing Executive Director, Production Executive Director, Finance Human Resources Manager Executive Director, Human Resources Training Officer Safety Practitioner Functional hierarchy HUMAN RESOURCES FINANCE SALES SITE A SITE B SITE C Matrix chart of organisational structure © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-31 Organisational Factors Organisations also make use of matrix charts to depict organisational structure. In the figure below, staff functions are shown across the top and line functions down the side. (Can you remember the difference between staff and line functions from an earlier element?) Interaction takes place where the functions cross. Concentric circle charts (see the following figure) show the management functions to be the hub of the organisation around which all other decisions and functions revolve. Concentric circle chart 7-32 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Organisational Factors Informal Groups The organisation chart shows the formal organisation of the company and indicates the direction of communications. There will also be formal working groups and committees. In a large organisation this can be cumbersome and some decision-making processes use informal routes. The safety practitioner needs to be aware of these informal methods. Although a formal structure would suggest that he might communicate with the works foreman by reporting to the human resources manager, who contacts the managing director, who then passes the information or instruction to the foreman via the production manager and supervisor, in practice the safety practitioner goes direct to the foreman and, if necessary, reports this using the formal channels. Within any organisation there is a ‘grapevine’. This is usually very effective in passing on gossip and information. Since the source is difficult to trace, the information might not be totally reliable. So, superimposed on the formal organisational structure is an informal structure of communication links and functional working groups. These cross all the barriers of management status and can be based on: • Family relationships. • Out-of-work activities, such as the golf club, or the local gym. • Valuable experience or expertise. ORGANISATIONAL COMMUNICATION MECHANISMS AND THEIR IMPACT ON HUMAN FAILURE PROBABILITY Every organisation depends upon an intricate communication network; the bigger the organisation, the more elaborate the system. The precise form of the network will vary from company to company. The following networks and the direction of communication they deal with are the most common, although in practice the communication system in a particular company will inevitably be far more complex. Communication systems vary in their complexity, reliability and formality. Modes of Communication Communication can be either one-way or two-way. In one-way communication: • Sender identifies the message. • Sender transmits the message. • Receiver receives the message. • Receiver interprets the message. Although this is quick and gives the perception of efficiency and control, there is no opportunity for feedback and the assumption is that the receiver has paid adequate attention. Examples include: a tannoy message in a factory, a safety poster, following written or e-mail instructions. In two-way communication there is the opportunity for the receiver to transmit information or questions back to the original sender and for the sender to respond, such that a conversation takes place. Although more complex and time consuming, two-way communication is likely to be more effective and reliable by placing the onus on both parties rather than one. Achieving a mutual understanding between the two parties ensures that the correct message is received and understood, and contributes to an improved safety culture. Examples include: a one-to-one meeting, a tool box talk with the opportunity for questions, etc., or a telephone call. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-33 Organisational Factors Shift Handover Communication Shift working and shift handovers are characteristic of many organisations, not only in the process industries, but also in health care. During shift handover, relevant information has to be communicated to maintain the continuity of the activities; if this fails there is the risk of serious consequences. A key factor in the Piper Alpha disaster in 1988 (see earlier) was the failure in the permitto-work system, such that the oncoming shift members were unaware of the removal of a safety valve. This failure led to actions that initiated the disaster. Board Principal Executive The UK British Medical Association has published guidance on good practice handovers in healthcare, and detailed five questions: Departmental Managers • Who should be involved? – All key personnel at all grades. • When should handover take place? – At fixed times, of sufficient length and arranged to allow both the off-going and on-going shifts to attend within their working hours. Middle Managers • Where should it take place? – Close to the most used work sites so that there is room for both sets of staff to attend. • How should handover happen? – a specific formal format should be devised and consistently followed. Supervisors • What should be handed over? – this might include written notes as well as electronic information. Organisational Communication Routes Vertical Communication First-Line Supervisors The amount of communication downwards tends to exceed that going upwards. • Downwards Communication will usually be made along the lines of authority, from managing director down to section leader and on to the clerk and shop-floor worker (see following figure). Employees Vertical communication – downward and upwards At each managerial level there must be responsibility for passing on information. Each superior level must be responsible for ensuring full, accurate knowledge and understanding at the next subordinate level. The importance and use of communication must, therefore, be included in any management training programme. The passing ‘downwards’ of some directive, communication or instruction, implies temporary ‘storage’ of that information in the mind, or the “in-tray”, of all intermediate handlers. Careful consideration must be given, therefore, to the most appropriate type of information storage and display system. 7-34 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Organisational Factors Some senior staff believe that the only effective way to pass information is by word of mouth – their mouth! They think they are the only really effective communicators in the organisation, but this can mean that they find themselves with no time to make decisions because all their time is taken up ensuring that the decisions they have made have been passed on to ‘all concerned’. Office Manager Invoicing Supervisor Wages Supervisor Costing Supervisor Ledger Supervisor Services Supervisor Costing Senior Clerk Estimating Senior Clerk Stock Control Senior Clerk Bought Invoices Senior Clerk Clerks Clerks Clerks Clerks Vertical communication within a department • Upwards Communication upwards is equally important in any organisation - ideas, suggestions for improvements, and opinions on existing systems, communications and techniques are all important for management to consider and use. Although the amount of downwards communication is usually greater than that going up, managers should encourage an increase in the flow upwards, although much depends on the time the manager has available to deal with the upwards communications. Office and shop-floor workers are in direct contact with the actual work carried out and can often see ways to improve processes and production. The regular flow of such ideas has been of considerable value to organisations in reducing costs, cutting production times, introducing improved layouts, and in creating an atmosphere of co-operation and goodwill between workers and management. Research has shown that it is in the upward flow of information that the greatest shortcomings exist, especially in recent years with the use of management information systems, and the selection and processing of the ‘vital’ information managers need to have. Whereas downwards communications are usually ‘directives’, i.e. they initiate action by subordinates, upward ones are usually ‘non-directive’, i.e. they report results or give information, but are not necessarily intended to prompt action. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-35 Organisational Factors Horizontal Communication Information is also channelled horizontally, both within a department and between departments. We give information to and receive it from colleagues in our own department and we have contacts with our opposite numbers in other departments. These communications are of the greatest value in administration, particularly in effecting co-ordination (see the following figure). Remember that information flow is subject to variation in speed and quantity; activity will vary according to the time of day, the day of the week, and the month or quarter. The characteristic of feedback is vital in effective communications. It should inform the sender of information that his or her message has been understood and acted upon, hopefully in the expected manner, bringing about the planned objective. Internal communications - horizontal 7-36 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Organisational Factors Inward and Outward Communication • Inward Here we see the effect of all the personal face-to-face calls on people at all levels in the organisation: the incoming telephone calls and e-mails from people of all kinds making contact with various members of staff, and postal correspondence arriving daily. • Outward The amount of communication outwards from any organisation is sometimes grossly miscalculated. Outgoing communications are both formal and informal, both explicit and implicit. In this same category we can include the behaviour of responsible members of staff when they are off company premises; their behaviour and expressed attitudes may be seen as reflecting those of their organisation. Outward communications also include the various kinds of advertising and promotional devices the organisation uses. PROCEDURES FOR RESOLVING CONFLICT AND INTRODUCING CHANGE The introduction of change may be accompanied by conflict within an organisation; it is vital that conflicts are resolved to ensure a good working environment and atmosphere. GLOSSARY While tackling the above areas will help to resolve conflict, note that there are two broad approaches to conflict: • Unitary Approach This involves the idea of the common aims of the organisation, i.e. its well-being and how workers and management have the same basic interest in that wellbeing. According to this view, conflicts arise because workers do not fully appreciate where their true interests lie. There is also some blame on management when conflict occurs, because management must have failed to communicate with workers and convince them that their best interests lie in co-operation and not conflict. According to the unitary approach, the best way to tackle conflict at its roots is to generate team spirit, company loyalty, and good working conditions. • Pluralist Approach This recognises that the organisation is made up of various groups whose interests and goals may differ. Conflicting parties will benefit from identifying issues of compatibility. Conflict should be controlled by balancing the various groups. Where strong management works alongside strong trade unions, each side respects the other and does not lightly enter into conflict. The causes of conflict are brought out into the open and hard bargaining takes place, but serious disruption to the work of the organisation is avoided. Generally managers take the unitary approach to conflict and change, while trade unions favour the pluralist approach. ORGANISATIONAL CONFLICT Can be defined as: “any perceived clash of interests between individuals, groups or levels of authority in an organisation”. During periods of change, conflict can occur because of: • Personality clashes: change bringing people of differing personalities into new relationships. • Poor communication: can lead to misunderstandings and confusion which can fuel conflict. • Conflicting interests: change can alter the power relationships within an organisation. • Lack of leadership and control: resulting in a lack of clear direction which can lead to conflict as different people interpret the scenario for change in different ways. REVISION QUESTIONS 8. Outline the differences between formal and informal groups within an organisation. 9. Explain how peer group pressure can influence behaviour at work. (Suggested Answers are at the end.) © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-37 Job Factors KEY INFORMATION • Job factors have a major influence on human error, including: –– Task complexity. –– Patterns of employment, e.g. short-term contracts. –– Payment systems, e.g. piece work. –– Shift work. • Task analysis breaks down the job into individual steps, which can be further analysed. • Ergonomics is the study of adapting the job to the individual. • Poorly designed workstations can increase human error as well as cause ill health. • Physical stressors, e.g. extremes of temperature, fatigue and stress, all have an adverse effect on human reliability. Job factors include such things as: • The equipment, e.g. design and maintenance of displays, controls, etc. • The task itself, e.g. complexity. • Workload. • Procedures or instructions – clarity, completeness. • Disturbances and interruptions. • Working conditions – noise, temperature. EFFECT OF JOB FACTORS ON THE PROBABILITY OF HUMAN ERROR Task Complexity The complexity of the task can have a significant effect on the propensity for human error. Those tasks which involve complex calculations, decisions or diagnoses will present more opportunity for such error. Such tasks should be broken down into simpler units to give greater clarity. Patterns of Employment These days it is accepted practice for workers to be on short-term contracts and this clearly has an effect on individuals seeking job security. Some people in this position may suffer from stress due to the lack of job security, particularly if they have always had a ‘permanent’ job in the past. Other people acknowledge that there are now few ‘jobs for life’, and take short-term contracts in their stride. ‘Permanent’ contracts may lead to complacency in the workforce, in which case the employer needs to ensure that individuals achieve their potential and work towards the company goals. There are many ways of encouraging improved performance, e.g. reward and incentive schemes. The way the work is organised between people can also have a major effect on performance. People working in small teams with some variety to their tasks can help build comradeship and a good working environment. However, where people work alone, work can become a lonely place, and the tasks can become monotonous. Payment Systems The way in which people are paid can have an effect on the way they work. For example, piecemeal workers are paid by performance; abattoir workers are often paid per animal slaughtered, so for them speed is important, because the faster they work the more they get paid. While safety may not be the top priority, they understand that their own safety is paramount because if they injure themselves, they won’t be able to work and then they won’t get paid. So, by default, personal preservation may lead them to work more safely. This is really the same for all self-employed people. On the other hand, employed people who still get paid if they are absent from work may not think about their own safety in these terms, and so may or may not work more safely. Short-term contracts often mean that the employer can choose to retain the best workers. Where there is a good safety culture in place, this will often mean workers who perform well and safely. Where the safety culture is poor, this may mean workers who work the quickest will be kept on. So, the type of organisation will determine how the individual will work in order to ensure that their contract is renewed. On the other hand, where short-term contracts are in place there may be little loyalty from the workforce and so turnover of staff (particularly good performers) may be high. 7-38 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Job Factors Shift Work Shift work has a great effect on an individual’s performance. In addition to fatigue and stress, individuals may find that their social lives and family life are affected. The effects of this will rather depend on the individual and their circumstances, as well as the shift pattern itself. If, however, an individual is unhappy at home, then this will often spill over into their work life and performance may be affected. Shift workers (especially night workers) may experience negative effects on their health: • Gastrointestinal problems are more likely to occur due to eating snack meals during work hours. • Respiratory problems such as asthma tend to be worse at night, as do allergic reactions. • Lung function also declines at night, especially for those people with chronic respiratory problems. Clearly where people’s health is affected, performance may also be affected. Shift work interferes with the body’s natural circadian rhythm (the internal body clock which dictates when the body should be active and when it should rest). Even when working nights, the body still reduces body temperature in the early hours of the morning, reduces blood pressure and stops digestion, which leads to an individual feeling sleepy and less alert. Shift workers need adequate rest between shifts, as well as regular rest days to “recharge their batteries”. The shift pattern itself may also affect individuals. Shift patterns that alter once a week are likely to be more difficult to adjust to, rather than those that change more rapidly or more slowly. APPLICATION OF TASK ANALYSIS Task analysis is a process that identifies and examines tasks performed by humans as they interact with systems. It is a means of breaking down a task into each individual step and is a technique that looks at an activity in detail. The activity in question may be one where a number of people have injured themselves. By breaking the task down into each step, the cause of the injury may become apparent, and a better way of completing the task may be identified. © RRC International For example, consider the school cooks who produce hundreds of hot meals per day. A number of incidents have occurred, which on the surface seem unrelated, e.g. back strain, burns, slips and trips. Looking more closely, however, it seems that all the accidents have occurred while removing or putting items in the oven. After breaking down each step, it becomes apparent that the oven door does not always stay fully open so the cook has to balance the trays of hot food while trying to keep the door open. This sometimes means holding the food in an awkward manner (leading to back strain) or spilling the food (leading to slips and trips) or being burnt by the oven door. In this simple example, it may be possible just to fix the door so it stays open, or to change the procedures, or it may mean someone has to hold the door open while another person removes/replaces the food. By breaking down a task, you can see exactly what happens without making assumptions about some of the steps. ROLE OF ERGONOMICS IN JOB DESIGN Ergonomics is concerned with “fitting the job to the man”, rather than expecting the individual worker to adapt to the job. Influence of Process and Equipment Design on Human Reliability Human beings are unreliable – how unreliable depends on the individual and the work environment. Consider the effect that being in a very hot environment has on your work performance; or, when you have had a large lunch, how your output is affected by a feeling of sleepiness. However, much can be done to minimise such effects by improving the environment and making the task such that errors are minimised. This is achieved by careful design of any controls. Man and machine are each better at some things than the other. Ideally, you want to use the strengths of both to minimise possible weaknesses; together they represent the ‘system’ for meeting the requirements. This can be illustrated diagrammatically as in the following figure. Unit IA – Element IA7: Human Factors v2.1 | 7-39 Job Factors Statement of objectives Separation of functions Allocation of functions (Human) Development of personnel Human-machine interface design (Hardware) Development of equipment System integration System design process Ultimately, every piece of plant can be represented by what is often called the MMI, or ‘man-machine interface’. Ergonomics is the study and design of this interface, such that the operator can perform his or her duties efficiently, in comfort and with minimum error. Grouping of displays and dials next to their controls, and consistency in these displays – for example, all moving the same way for increase – are important in allowing the operator to form a mental picture of what is actually happening in the plant under that person’s control. • Displays should be arranged so they can be scanned with minimum effort. • Display dials should be the appropriate type for the reading (digital v. analogue). Consistency is important in the action of control devices; we expect to turn something on and increase some variable, by turning a knob clockwise. Relative positioning of control devices and displays is important. People expect to see a reaction to an action, even if it is only a light that indicates the action is being acted upon (the lift call-button effect) and, of course, controls should be within easy reach of the operator. Controls should be organised and laid out so as to logically follow the process. They should be clearly marked or labelled. The number of controls should generally be kept to a minimum. Emergency arrangements should be distinctive so that emergency stop controls can be easily located, and any audible warnings should take account of expected background noise levels. • Dials should have identified areas for normal and abnormal readings to make it easier to see if something is starting to wander, e.g. a fuel gauge in a car. • Bulbs and other indicators should be shielded from glare so that their status cannot be confused. 7-40 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Job Factors Possibly the most important aspect is the worker’s immediate working space and environment. Reliable work cannot reasonably be expected from an operator who has a headache or a sore back within an hour of starting work. Factors such as noise, dust, smell, vibration, temperature (and temperature changes), lighting levels (and glare), and humidity all contribute to a worker’s ability to concentrate. Psychological factors such as the degree of concentration necessary, and the ability to mentally rest and ‘coast’ for a short period, are also important; also remember the importance of providing chairs, if appropriate, to avoid fatigue from prolonged standing. The Worker and the Workstation as a System The layout of controls, displays and seating for convenience of operation are often overlooked. Fumes/Gases In ergonomics, the man, the machine, and the working environment may be considered as the elements that together comprise a system. When considering the ergonomic ‘fit’ of the workplace to the worker, there are a number of factors to take into account. ENVIRONMENT Heat/Cold Glare/Darkness Vibration Noise To ensure that the strengths of man and machine are utilised, a Fitts List (named after Paul Fitts, who developed the technique) is produced for the system. MAN Example of Fitts List Activity Machine Human Speed Much superior Lag > 1 second Power Consistent, large, constant, standard and precise forces 2 hp for 10 seconds High Not reliable, must be monitored Consistency 0.6 hp for minutes 0.2 hp over day Reasoning Good deductive Good intuitive Input sensitivity Some outside human range (e.g. X-rays) Wide range, good pattern identification MACHINE Display Bells Switches Dials Buzzers Knobs Counters Hooters Levers Gauges Lights Pedals Ergonomic ‘Fit’ Note that this is given as an example for a system that requires the given ability. Each system will require a Fitts List developed to suit its specific requirements for actions to be performed, although with practice, such a list does not take long to produce. Elementary Physiology and Anthropometry The skills of an ergonomist include: • Anthropometry This is a study of human measurements, such as shape, size, and range of joint movements. A machine must be designed for the person. Since no two people are the same, a design is required which will suit, or can be adapted for, a wide range of sizes of individuals. It is typical to design for a range of two standard deviations from the mean. (Remember that we looked at the statistical terms “standard deviation” and “mean” in an earlier element.) This includes all but the extreme 10% at each end of the measurement scale. Group characteristics must also be considered, for example, the average height of people varies between different populations. The appropriate grouping and display of controls is vital © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-41 Job Factors • Physiology This is a study of the calorific requirements of work (how much energy is needed) and body functions, the reception of stimuli, processing and response. The operator and machine must be complementary. A person must not be expected to do more than the human body is capable of. Some things are best done by a person; other things by a machine. Physiology includes a study of the operation of machines. A person can operate two foot controls when sitting, but only one when standing. An investigation by Cranfield Institute of Technology determined the ideal dimensions of the average operator of a horizontal lathe - ‘Cranfield man’ would need to be 1.35 m tall and have a 2.44 m arm span. The ergonomist should make a contribution at the design stage to try to prevent problems occurring later. Degradation of Human Performance Resulting from Poorly Designed Workstations Many regions of the world produce design standards. The British Standard 3044:1990, Guide to Ergonomics Principles in the Design and Selection of Office Furniture, is one example of the help available to designers in the UK. Though UK-based, the HSE leaflet INDG90(rev3) Ergonomics and human factors at work – A brief guide aims to help employers and managers to understand ergonomics and human factors in the workplace by giving examples of ergonomics problems and simple, effective advice about how to solve them. ERGONOMICALLY-DESIGNED CONTROL SYSTEMS • Production Process Control Panels The operator of a production process control panel must be able to operate the panel from a safe place. For some production processes, this may be from an adjacent area or for more dangerous operations the panel will be located at a safe distance, or even within an enclosed area away from the production area. Noise, dust and fumes must all be considered. The operator must be able to reach all the dials, switches, etc. easily. Emergency controls must be clearly identifiable and easy to operate. The operator must also have a view of the production area so that they can see what is happening and react, as necessary. • Crane Cab Controls A crane driver has to be in absolute control of the load that is being moved, because the slightest slip of the controls may result in damage to buildings, materials or people. For this reason it is vital that the controls in the cab are within easy reach and move in straight lines to permit ease and delicacy of control. The driver must be provided with an adjustable seat (to fit accurately 90% of all possible sizes) so that he/she has a full view of the working area. The driver must also be protected from the ingress of dust, fumes and heat from the external environment. The provision of filtered and refrigerated air, where necessary, ensures cool and comfortable working conditions. Workstations are usually designed for the ‘average’ person. If a doorway was designed just for the average person, then some of the population would have problems getting through. Workstations need to be capable of adjustment. Unsuitable workbench height causes the operator to develop musculoskeletal problems. • If the workbench is too high, the operator has to adopt an unnatural posture, with the elbows away from the body and the shoulders raised. This causes discomfort in the shoulders and neck. • If the work surface is too low the operator will have to lean forward. This causes neck and lower back problems. • Repetitive movements, particularly those requiring the operator to exert force or use an unnatural action, can lead to upper limb disorders. One problem is tenosynovitis, or inflammation of the tendons of the hand and wrist. This is a common problem with keyboard operators. A crane driver must have a full view of the working area 7-42 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Job Factors • Aircraft Cockpit It is vital that a pilot can interface easily with all the controls in the cockpit. The controls/displays must be fitted around the cockpit in a logical way so that the pilot can easily reach/see the more important controls/displays, e.g. speed and altitude dials, while he/she may need to move to reach the less important ones. It is important that safety-critical switches cannot be inadvertently operated. These should be designed so that there has to be a positive action by the operator in order to initiate them. Emergency controls must be clearly identifiable, easy to use and situated in a suitable location. The emergency controls must be accessed quickly to prevent unnecessary delay in stopping the activity that they control. It is also important that the pilot can adjust his/her position to obtain the best field of vision and enable quick responses for movement of the various controls. For this reason, the pilot must be able to alter the height and position of his/her seat to ensure that the controls are in comfortable reach. The temperature, ventilation and lighting in the cockpit must also be adequate, and these must be adjustable to suit the individual. • CNC Lathe The CNC lathe is computer-operated using a key pad or keyboard. It is important, therefore, to ensure that the operator can access the key pad or keyboard easily, and that they can use the keys comfortably. For this reason, the operator must be able to adjust their operating position, i.e. chair height and position, as well as the actual position of the keyboard. MORE… You can find further information on the importance of design on human factors at: www.hse.gov.uk/humanfactors/topics/design.htm © RRC International RELATIONSHIP BETWEEN PHYSICAL STRESSORS AND HUMAN RELIABILITY GLOSSARY STRESS The reaction people have to excessive pressure or other types of demands placed on them. Stress can be caused by a number of factors including physical stressors, such as extremes of heat, humidity, noise, vibration, poor lighting, restricted workspace, etc. The presence of physical stressors has a negative effect on people and means that errors are more likely to occur. Physical stressors affect how comfortable a person is and their ability to concentrate, and may even make them feel unwell. Different people may be affected by varying degrees of the physical stressor. For example, some people are not affected by increased room temperature, while others start to feel uncomfortable and may become restless after a few degrees’ rise. Pregnant women are more likely to be affected before other members of the workforce. However, if the temperature continued to rise, then more and more people would be affected and the likelihood of errors occurring would rise too as concentration levels dropped. In addition to this, people are more likely to lose their tempers or have decreased levels of patience, which again may lead to errors or incidents occurring. Eventually a very warm working environment may result in fainting or heat exhaustion, which could have serious implications in a high-risk environment. Some environments are very warm by their nature, e.g. working in a busy kitchen. Procedures should be in place to ensure that individuals are protected from excessive heat, e.g. regular rest breaks away from the heat, availability of cold drinks, good air circulation, etc. In order to prevent errors, or reduce them as far as possible, you need to ensure that the working environment is as comfortable as possible. Where physical stressors are likely to be a problem, e.g. in a noisy environment, other controls must be in place to prevent them affecting an individual’s ability to work safely. These controls may be in the form of suitable personal protective equipment, limited time within the environment, or regular breaks, for example. Unit IA – Element IA7: Human Factors v2.1 | 7-43 Job Factors EFFECTS OF FATIGUE AND STRESS ON HUMAN RELIABILITY As we have said, stress is the reaction that people have to excessive pressure and occurs when they worry that they can’t cope. Stress can affect performance and an individual’s ability to make decisions and work effectively. Fatigue can be defined as ‘weariness after exertion’, or can occur after repeated periods of stress. Severe fatigue can lead to poorer performance on tasks requiring attention, decision-making, or high levels of skill. Shift work, working at night, or extended hours can all result in fatigue and have an adverse effect upon health. For safety-critical work, such as train driving, the effects of fatigue can give rise to increased risks. Shift work, especially night working, can impact on safety. During the night, job performance may be poor and tasks completed more slowly. The hours between 02.00 and 05.00 are the highest risk for fatigue-related conditions. Sleep loss can lead to lowered levels of alertness. Sleep debt, which is a build-up of sleep loss, leads to reduced levels of productivity and attention. These effects can also affect early morning shift workers and people who are on call. MORE… You can find further information on the effects of fatigue on human performance at: www.hse.gov.uk/humanfactors/topics/fatigue.htm REVISION QUESTIONS 10. What effects might shift work have on an individual’s performance? 11. How might the system of payment or terms of employment at work affect an individual’s performance? 12. Explain the term ‘ergonomics’ and discuss how the poor application of ergonomics might lead to injury and occupational ill health. 13. What features are present in an ergonomicallydesigned crane cab control system? (Suggested Answers are at the end.) 7-44 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Behavioural Change Programmes KEY INFORMATION • Behavioural change programmes aim to change individual behaviour by positively reinforcing desired behaviour and deterring undesired behaviour. • They rely on: –– Observations by supervisors and other workers. –– Providing prompt feedback to improve behaviour. PRINCIPLES OF BEHAVIOURAL CHANGE PROGRAMMES Such a change programme is best illustrated with an example – speeding in a car. Behavioural programmes aim to change individual behaviour using certain techniques including: What are the triggers that may cause somebody to speed? • Observations. • Late for an appointment. • Feedback. • Emergency. • Goal setting. • Road rage. • Team working. • Listening to exhilarating music. The key principle is to positively reinforce the desired behaviour and deter, or even punish the undesired behaviour. • Empty road. These could be: The first step is to identify the desired behaviour. The behaviour should be specific, observable and easily measured. In fact, simply observing behaviour can in itself lead to a positive improvement in the behaviour, but this will only be a temporary effect. Now what about the consequences? These can be either rewards or punishments: • Arrive early/on time – Reward. • Feel good – Reward. • Have an accident – Punishment. • Stopped by police – Punishment. TOPIC FOCUS • Increased wear and tear – Punishment. Steps of a behavioural change programme: A consequence will have a much greater impact if it: Step 1: Identify the specific observable behaviour that needs changing, e.g. increased wearing of hearing protectors in a high noise environment. • Happens sooner rather than later after the behaviour. Step 2: Measure the level of the desired behaviour by observation. Step 3: Identify the cues (or triggers) that cause the behaviour and the consequences (or pay offs) (good and bad) that may result from the behaviour. Step 4: Train workers to observe and record the safety critical behaviour. Step 5: Praise/reward safe behaviour and challenge unsafe behaviour. Step 6: Feedback safe/unsafe behaviour levels regularly to workforce. © RRC International • Is certain to happen rather than unlikely. • Is important to the individual. So, with our driving example, if every time we exceeded the speed limit we were immediately fined, motorists would soon adhere to the required limits. It is important to focus on the safe/unsafe behaviours and not the desired outcome of the programme. So, if the objective of such a programme is to reduce the incident/ accident rate, it should focus on safe behaviours (and reward those) and not on the injury rate. If we rewarded a low injury rate then this would encourage under reporting rather than safe behaviours. Unit IA – Element IA7: Human Factors v2.1 | 7-45 Behavioural Change Programmes Many behavioural change programmes identify a few key behaviours that have, perhaps, led to accidents previously, or gave cause for concern – for example, the failure to wear gloves when handling knives, or to wear a seatbelt while on a forklift truck. The desired behaviours are then identified (such as “when driving the forklift truck the operator wears his seatbelt”) and the observers then observe against this specific behaviour. If the operator is wearing his seatbelt, then positive reinforcement and thanks are given. If the operator is not wearing his seatbelt, then the observer highlights their concern and discusses any barriers to safety that could have resulted in the action. By being observed and given feedback regularly, workers’ behaviour changes, such that the correct behaviours become almost good habits. At this point, a new behaviour may be added to the observation sheet, and the process continues. ORGANISATIONAL CONDITIONS NEEDED FOR SUCCESS IN BEHAVIOURAL CHANGE PROGRAMMES Behavioural programmes should not be viewed as quick fixes and unless they are properly resourced with overt continuing management commitment they are unlikely to succeed. As the behavioural-change process hinges on the ability to give and receive positive and negative feedback, the organisation and its employees must be ready to accept this step. It may seem strange to have someone thanking you for wearing PPE, but this positive feedback is a critical part of the process. Equally, any negative feedback is there for guidance and so should also be received with an open mind, which can be a struggle if the safety culture is not well developed. 7-46 | Unit IA – Element IA7: Human Factors © RRC International v2.1 (accident frequency) Safety performance Behavioural Change Programmes Technological and physical condition approaches Work systems and procedures People centred and cultural approaches Time Actioning behavioural change This graph illustrates that typically organisations first consider the technical issues that affect safety, such as having safe equipment and premises. When these are in place they then turn to ensuring that the systems of work and procedures are satisfactory. Unless these two approaches are in place, a behavioural programme is unlikely to work. A behavioural programme is more likely to be effective if the reward/punishment is: • Likely or even certain. • Important to the individual. EXAMPLE OF TYPICAL BEHAVIOURAL CHANGE PROGRAMME CONTENTS All programmes need behaviour which can be easily observed and assessed. In a factory a process involves loading a pallet with 25kg sacks of cement and then transporting the pallet to a lorry for dispatch. A checklist is then developed to identify the expected behaviour and record the number of safe and unsafe acts. Here is an extract: • Given soon after the safe/unsafe act. Feedback needs to be provided very soon after the safe/ unsafe act so that the safe behaviour is reinforced, not only to the individual, but to all those affected, so that they appreciate the impact of the programme, e.g. collective results published weekly. In one published study, workers were provided with earplugs to protect them from very high noise levels. The initial usage rate was only 35%. After a two month programme in which the wearing of the plugs was rewarded with tokens, the usage rate had increased to 90%. The scheme was finished and it was found that usage had been maintained a further three months later. The initial discomfort often experienced by wearers of hearing protection had worn off and when users removed the ear plugs their heightened awareness of the high noise levels further reinforced the desired behaviour. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-47 Behavioural Change Programmes Task Expected behaviour Loading pallet Transporting pallet by FLT Safe Unsafe • Loader wears safety gloves 3 1 • Loader wears safety shoes 3 2 • Loader adopts safe lifting procedure 2 0 • Loader keeps environment tidy 1 1 • Loader deals with spillages 0 0 • Driver sounds horn when approaching exit doors 4 1 • Driver keeps within speed limit 4 2 • Driver keeps forks lowered 2 0 • Driver is courteous 2 0 21 7 Total % safe Not seen Comment 1 75% For each of the two tasks a list of expected observable behaviours is identified. Observers then regularly visit the workplace and observe the behaviour and record whether it was safe or unsafe or not seen. Observers may include all workers and should not be just those with management or supervisory roles. Following each observation the feedback is given soon afterwards, either individually or as a team, in which safe behaviours are praised and unsafe behaviours discussed. The worker(s) observed are invited to give feedback and to explain, for example, why it was not feasible to wear gloves. The discussion may lead to suggestions as to how to change the task to improve safety. Clearly the discussion will need to be handled carefully and should not create hostility. Following a series of observations, the percentage of unsafe behaviour can be calculated and publicised: Percentage safe behaviour = Sum of safe observations Sum of safe + sum of unsafe behaviours × 100 REVISION QUESTION 14. Outline the steps of a behavioural change programme. (Suggested Answer is at the end.) 7-48 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Summary SUMMARY Human Psychology, Sociology and Behaviour Factors that influence human behaviour include: • Personality - how extrovert or introvert a person is. • Attitude - their beliefs about safety. • Aptitude – ability. • Motivation - what inspires them to work safely. There are a number of theories of human motivation: • F. W. Taylor He summarised scientific management as: –– Design efficient methods for doing work, based on a scientific approach, such as subdivision of labour. –– Set productivity goals. –– Give financial rewards for meeting the goals. –– Train the workers to use the methods. • Mayo (Hawthorne Experiments) The simple fact that workers were the subject of experimental study improved their performance. • Maslow (Hierarchy of Needs) suggested five levels of need: Biological, Safety or Security, Social, Esteem and Self-Actualisation. • McClelland identified three human needs – affiliation, power, and the need to achieve. • Herzberg identified two sets of needs in workers - hygiene factors (e.g. safe working conditions) and motivators (e.g. recognition and reward). • McGregor developed two theories: –– Theory X – people are motivated primarily by money and are reluctant to take on responsibility. –– Theory Y – people perform best with minimal supervision and control. Experience, social background and education/training affect behaviour at work. Rasmussen’s Model of knowledge-, rule- and skill-based behaviour states that: • Skill-based behaviour describes a situation where a person is carrying out an operation without the need for any conscious thought. • Rule-based behaviour is at the next level - a situation where the operator has rules which he can apply to deal with a specific situation. • Knowledge-based behaviour is for situations where there are no tried rules or routines or the necessary skills. Trial and error may be the only method available. Perception of Risk In relation to human sensory receptors: • Each of our senses works in the same way by sending signals to the brain. • We tend to screen out things we are not interested in. • Sensory defects increase with age and ill health. When perceiving danger: • Perceptual set is dangerous because we assume both the danger and the solution without seeing the real issues. • Our perception of hazards can be distorted. • Errors of perception can be caused by physical factors such as fatigue and stress. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-49 Summary • An individual’s perception of a situation is based on two sources of data: –– Information from the senses. –– Expected information. The Hale and Hale model of accident causation includes the idea of perception. Developed from this was the Hale and Glendon model of behaviour in the face of danger. Human Failure Classification HSG48 identifies two types of human failure: errors (accidental) and violations (deliberate). Errors are actions or decisions which were not intended, involved a deviation from an accepted standard, and which led to an undesirable outcome. Errors can be characterised as: slips, lapses and mistakes. There are three types of violation: routine, situational and exceptional. In many major disasters, human error has been shown as a major contributory factor. Improving Individual Human Reliability in the Workplace Motivation may be improved by: • Workplace incentive schemes. • Reward schemes. • Job satisfaction. • Appraisal schemes. • Selection of individuals by: –– –– –– –– Matching skills and aptitudes. Training and competence assessment. Fitness for work schemes and health surveillance if appropriate. Support for ill health and stress-related illness. Organisational Factors Weaknesses in the safety management system increase the probability of human failure. These include failures in: • Policy. • Planning. • Setting of standards. • Information. • Responsibilities. • Monitoring. The safety culture of an organisation influences the behaviour of its individual members. One way is by peer group pressures. Groups, both formal and informal, within an organisation affect the control of risks. Communication mechanisms within an organisation vary in their complexity, reliability and formality. Communication between and within groups is important. It can be: • Horizontal or vertical. • Inward and outward. 7-50 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Summary During periods of change, conflict can occur because of: • Personality clashes: change often brings people of differing personalities into new relationships. • Poor communications: can result in misunderstandings and confusion which can fuel conflict. • Conflicting interests: change can alter the power relationships within an organisation. • Lack of leadership and control: can result in a lack of clear direction, leading to conflict as different people interpret the scenario for change in different ways. Job Factors The way in which work is organised for individuals with respect to shift patterns, means of payment and patterns of employment can have an important effect on the way they carry out their job. Task analysis is a process that identifies and examines tasks performed by humans as they interact with systems. By breaking the task down into each step, the cause of an injury may become apparent, and the analysis may identify a better way of completing the task. The design of the work environment can have an effect on human reliability. The following are some issues to consider: • Displays should be arranged so they can be scanned with minimum effort. • Consistency is important in the action of control devices. • Factors such as noise, dust, smell, vibration, temperature, lighting levels and humidity all contribute to a worker’s ability to concentrate. The ergonomist’s skills include: • Anthropometry - a study of human measurements, such as shape, size, and range of joint movements. • Physiology - a study of the calorific requirements of work (how much energy is needed) and body functions, the reception of stimuli, processing and response. Human performance can deteriorate due to poor design of workstations, such as those that are too low, or too high. Work that involves repetitive movements can lead to upper limb disorders. Physical stressors affect how comfortable a person is and their ability to concentrate, and may even make them feel unwell. These include: extremes of heat, humidity, noise, vibration, poor lighting, restricted workspace, etc. Fatigue can be defined as “weariness after exertion” or can occur after repeated periods of stress. Severe fatigue can lead to poorer performance on tasks requiring attention, decision-making, or high levels of skill. Behavioural Change Programmes Behavioural change programmes endeavour to change individual worker behaviour by positively reinforcing desired behaviour and deterring undesired behaviour. • Specific observable behaviour to be changed is identified and then measured. • The cues that encourage the behaviour and resulting consequences are identified. • Safe behaviour is encouraged/rewarded. • Unsafe behaviour is challenged. Such programmes rely on: • Observations by supervisors and other workers. • Providing prompt feedback to improve behaviour. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-51 Exam Skills QUESTION Here you can have another attempt at a 20 mark, Section B question; this one is on the topic of human error. Remember you would allow yourself 30 minutes to answer this question in the exam. Question Outline the desirable design features of controls AND displays on a control panel for a complex industrial process aimed at reducing the likelihood of human error. SUGGESTED ANSWER OUTLINE Remember that there are 20 marks available so try to mention 22 points in outline to maximise the chance of getting full marks. With this question on ergonomics, you need to focus on features of controls and displays that would reduce the rate of human error, including examples and reasons in your answer. The Examiner would be looking for an answer including points similar to the following: (20) • Displays should indicate normal and abnormal situations. • Environmental concerns - located away from heat, glare or anything else that may detract from recognition of any signal. • Displays should be located an appropriate distance away from operator for ease of reading/correct sized display. • Discussion/consultation with users to obtain feedback on suitable design and operation to avoid confusion. • Controls – keep to a minimum, whilst still ensuring safe operation and control. • Controls should have a positive action. • The user requires immediate feedback. • Stop functions should: –– –– –– –– Be easy to activate. Have clear markings and functions. Be designed to avoid accidental operation. Be positioned away from interference by nonauthorised users. –– Avoid non-intentional restart or shut down. • Controls should be visible and in a logical order such that operators interact with them – up/down buttons not side by side with each other. • Select the correct type of control for the operation desired – levers versus knobs. • Follow colour coding standards: green – on; red – emergency stop, etc. • Controls located adjacent to the displays, so operator can see consequences of their actions. • Clearly labelled. • Language/terminology appropriate for understanding and recognition. • Displays should attract a response when required: flashing, noise, etc. • Correct type of display – analogue versus digital. 7-52 | Unit IA – Element IA7: Human Factors © RRC International v2.1 Exam Skills POSSIBLE ANSWER BY EXAM CANDIDATE For a control panel and controls to be used effectively to manage the process and ensure safety, they need to be designed from the operator’s point of view; this design should focus on the ergonomic layout of the panel and controls, such that they are easy to reach, move and manipulate. The numbers of controls or interactions should be kept to a minimum to prevent mental overload or having too much to monitor/review. Controls that are safety critical, such as emergency stop buttons, should be clearly identified and be easy to operate from any position. The emergency stop function should over-ride all other control functions. Other start and stop controls should be designed differently, with start buttons recessed in order to prevent accidental operation. Controls should be labelled in the correct language for the users, and be designed to accepted cultural norms, e.g. red for stop, green for go, clockwise to increase, etc. It should also be clear to the user that the operation of the control has been recognised by the process by providing feedback to the user. The layout of the panel should be logical and follow the operator’s sequence if possible and the right type of control for operation - dials for rotating things rather than buttons to push. Other things that need to be considered would involve the environmental conditions in which the panel will be sited and operated, light, fumes, indoors/outdoors, etc.; the controls need to be suitable for the environment (buttons fading in sunlight). Alarm signals must be clear and obvious and give operators time to react to the condition as well as being relevant to the emergency, so they don’t become blasé to them going off and just mute them and forget. An alarm to warn of a change of condition should therefore be different to that signalling an emergency situation. You would also need to think about the operator from the point of view of markings for eyesight, too small so unable to read, sticky labels that may fall off and be put on the wrong way round, colours – use of standards. When considering the design of control panel displays it is essential that safety critical information is located in a prominent position where it is not confused with other process information. The display should also be designed using cultural norms and so that the status of the process is clear, e.g. by using green lights to show equipment that is “on” and red to show equipment “off”. The display should follow the process flow sequence so that the operator can relate the information on the control display to the controls that he operates and the process that he understands. The display must be clear and easy to read, e.g. free from flicker, glare and reflections. The use of process diagrams rather than text may also aid understanding. Finally alarm conditions on displays should be clear and prominent – it may be desirable to have a “warning” alarm sequence and also a different “critical” alarm utilising beacons and audible alarms, making it very clear that emergency action must be taken. REASONS FOR POOR MARKS ACHIEVED BY CANDIDATES IN EXAM An exam candidate answering this question would achieve poor marks if they made the mistake of describing the features of a control room or panel, rather than the design features of controls and control panels. © RRC International Unit IA – Element IA7: Human Factors v2.1 | 7-53 v2.1 REGULATING HEALTH AND SAFETY ELEMENT 8 LEARNING OUTCOMES On completion of this element, you should be able to demonstrate understanding of the content through the application of knowledge to familiar and unfamiliar situations and the critical analysis and evaluation of information presented in both quantitative and qualitative forms. In particular you should be able to: Describe comparative governmental and socio-legal, regulatory and corporate models. the role and limitations of the International Explain Labour Organisation in a global health and safety setting. © RRC International Explain the role non-governmental bodies and self regulation has in securing common health and safety standards in a global economy. Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-1 Contents COMPARATIVE GOVERNMENTAL AND SOCIO-LEGAL AND CORPORATE REGULATORY MODELS 8-3 8-3 Role, Function and Limitations of Legislation Nature, Benefits and Limitations of ‘Goal-Setting’ and ‘Prescriptive’ Legal Models 8-4 Loss Events in Terms of Failures in the Duty of Care to Protect Individuals and Compensatory Mechanisms that May be 8-5 Available Mechanisms Used to Enforce Health and Safety Legislation 8-8 Laws of Contract 8-10 Revision Questions 8-11 ROLE AND LIMITATIONS OF THE INTERNATIONAL LABOUR ORGANISATION IN A GLOBAL HEALTH 8-12 AND SAFETY SETTING Role and Status of Ratified Conventions, Recommendations and Codes of Practice in Relation to Health and Safety 8-12 Roles and Responsibilities of ‘National Governments’, ‘Enterprises’ and ‘Workers’: R164 Occupational Safety and Health Recommendation 1981 8-14 Use of International Conventions as a Basis for Setting National Systems of Health and Safety Legislation 8-15 Revision Questions 8-15 ROLE OF NON-GOVERNMENTAL BODIES AND HEALTH AND SAFETY STANDARDS 8-16 Relevant Influential Parties 8-16 Importance of the Media in a Global Economy 8-17 8-18 Benefits of Schemes Which Promote Co-Operation on Health and Safety Between Different Companies Effects on Business of Adverse Stakeholder Reaction to Health and Safety Concerns 8-18 Origins and Meaning of ‘Self-Regulation’ 8-19 Role and Function of Corporate Governance in a System of Self-Regulation 8-20 How Internal Rules and Procedures Regulate Health and Safety Performance 8-21 How Non-Conformity to an Accredited Health and Safety Standard can be Used as a Form of Enforcement Within a Self8-22 Regulatory Model Revision Questions 8-23 SUMMARY 8-24 EXAM SKILLS 8-25 8-2 | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Comparative Governmental and Socio-Legal and Corporate Regulatory Models KEY INFORMATION • Since organisations may not adopt good health and safety standards voluntarily, one way of making sure minimum health and safety standards are met is for the government to introduce legislation (the statutes and other legal instruments that have been enacted by the governing body). • Goal setting legislation sets an objective, but leaves it to the dutyholder to decide on the best way of achieving the defined goal. • Prescriptive legislation defines the standard to be achieved in far more explicit terms. • Federal systems aim to ensure uniform standards and regulation throughout the country, since if each state can set their own standards, this will inevitably lead to inconsistencies. • If a worker has a work-related accident or disease this may result in loss to the individual or dependants. There are a number of mechanisms that allow individuals to seek restitution for damages including no fault or fault liability claims • Mechanisms that may be used to enforce health and safety legislation include criminal action and the use of enforcement notices • Contract law has many implications in respect of occupational health and safety including contracts of employment, and establishing the relationship between producer and vendor, vendor and consumer, and client and contractor. ROLE, FUNCTION AND LIMITATIONS OF LEGISLATION It is not realistic to expect organisations to adopt good health and safety standards voluntarily, not least because the benefits of good (and costly) standards may not be immediately obvious to all employers. One way of making sure minimum standards are met, whether they relate to health and safety or other matters to do with the regulation of society, is for the government to introduce legislation. GLOSSARY LEGISLATION May be defined as the statutes and other legal instruments (documents) that have been enacted by the governing body. Examples of legislation relating to occupational health and safety include: • Health and Safety at Work, etc. Act 1974 (United Kingdom). • Occupational Safety and Health Act 1970 (USA). • Work Environment Act 1977 (Sweden). By defining minimum acceptable standards, legislation at least partly forces organisations to adopt good practice, when otherwise they might be unlikely to do so voluntarily. © RRC International Legislation may be introduced that leads to criminal and/or civil consequences. A crime is an offence against the state and the consequence of a criminal action is the prosecution of the offender, which may lead to punishment, perhaps a fine or a prison sentence. What behaviour constitutes a criminal offence is largely dependent on the government and can therefore be influenced by political concerns. In contrast, a civil action is concerned with an individual who has suffered some loss, such as being injured following a workplace accident. The aim is for the claimant (the one who has suffered the loss) to seek (usually) financial compensation from the defendant as a result of the wrongdoing. There are, however, limitations to the legislative approach. The first is that there is little incentive for organisations to go beyond the minimum legal requirements; they will comply with what the law says, but not with its spirit. In fact, since good standards often cost a lot of time and money, an organisation which embraces such high standards may be at a competitive disadvantage. If a government introduces legislation then there is a requirement for the legislation to be enforced. This requires a means of identifying those who do not comply with the law. Accordingly, enforcement officers who have defined powers of inspection and investigation (so that breaches of the law can be identified) must be employed and trained. There must also be procedures for the prosecution and punishment of organisations and individuals who fail to meet the required standards, i.e. an effective court system. The governments of some countries do not appear to be able to enforce health and safety provisions. Even in wealthy countries with extensive resources, the enforcement of health and safety has to compete with other government priorities. Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-3 Comparative Governmental and Socio-Legal and Corporate Regulatory Models NATURE, BENEFITS AND LIMITATIONS OF ‘GOAL-SETTING’ AND ‘PRESCRIPTIVE’ LEGAL MODELS Nature In practice legislation should not be thought of as being entirely goal setting or entirely prescriptive - it more often has the characteristics of both models. One example is Regulation 8 of the Provision and Use of Work Equipment Regulations 1998 (see above). Legislation is sometimes described as being ‘goal setting’ or ‘prescriptive’. Goal setting legislation sets an objective but leaves it to the dutyholder to decide on the best way of achieving the defined goal. (Note that a dutyholder is the person on whom the legal duty is placed, e.g. the employer in the case of most health and safety duties.) This states: You can see a good example of goal-setting legislation in the United Kingdom system. The principal Act of Parliament governing health and safety is the Health and Safety at Work, etc. Act 1974. The key duty imposed on employers is: This requires that employers provide adequate information for users of work equipment - it has an element of prescription in that there is a duty to provide information; however, what constitutes “adequate” needs to be decided by the employer, which effectively sets a goal. “It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees.” The goal to be achieved is to ensure (so far as is reasonably practicable) health and safety, but the Act does not define how this should be done. It is up to the employer to identify and evaluate different ways of meeting this requirement and then to choose what is appropriate in the given circumstances. (Note that the phrase “so far as is reasonably practicable” is not only a feature of UK legislation, but also of other regions. It generally means that when deciding whether you need to take any action to control a risk, you must compare the risk against the effort, time and money that would be required to bring it under control. So, some judgment is needed.) In contrast, prescriptive legislation, as the name suggests, defines the standard to be achieved in far more explicit terms. One example, again from the UK, is in the Provision and Use of Work Equipment Regulations 1998. Regulation 26 is concerned with the provision of information and instruction to users of equipment for use at work preventing mobile work equipment (e.g. fork lift trucks) from rolling over. This regulation applies only to such equipment and makes explicit what a dutyholder should do to comply. Regulation 26, Rolling over of mobile work equipment: (1) Every employer shall ensure that where there is a risk to an employee riding on mobile work equipment from its rolling over, it is minimised by: (a) stabilising the work equipment; (b) a structure which ensures that the work equipment does no more than fall on its side; (c) a structure giving sufficient clearance to anyone being carried if it overturns further than that; or (d) a device giving comparable protection. 8-4 (1) Every employer shall ensure that all persons who use work equipment have available to them adequate health and safety information and, where appropriate, written instructions pertaining to the use of the work equipment. Benefits and Limitations TOPIC FOCUS Prescriptive legislation has clearly defined requirements which are more easily understood by the dutyholder and enforced by the regulator. It does not need a higher level of expertise to understand what action is required, and provides a uniform standard to be met by all dutyholders. Limitations - it is inflexible and so depending on the circumstances may lead to an excessively high or low standard. Also it does not take account of the circumstances of the dutyholder and may require frequent revision to allow for advances in knowledge and technology. Goal-setting legislation allows more flexibility in compliance because it is related to the actual risk present in the individual workplace. It is less likely to need frequent revision and can apply to a much wider range of workplaces. Limitations – it is more difficult to enforce because what is “adequate” or “reasonably practicable” are much more subjective and so open to argument, possibly requiring the intervention of a court to provide a judicial interpretation. Dutyholders will also need a higher level of competence in order to interpret such requirements. | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Comparative Governmental and Socio-Legal and Corporate Regulatory Models Legal Hierarchy of State and Federal Laws GLOSSARY FEDERAL LAW Law created by the federal government of a nation. FEDERAL GOVERNMENT Formed when a group of political units, such as states or provinces, merge together in a federation, surrendering their individual sovereignty and many powers to the central government while retaining or reserving other limited powers. Examples: United States of America, Canada, Australia and India. One of the difficulties in federal systems is to ensure uniform standards and regulation throughout the country. If each state can set their own standards, there will inevitably be inconsistencies. In the USA, the Occupational Safety and Health Act 1970 was enacted at federal, rather than state level and so the USA does not have significant problems with harmonisation of standards. However, although the Act applies to all states, its enforcement is delegated to the individual states, which leads to inconsistencies in enforcement standards. There have been many attempts to harmonise occupational health and safety standards in Australia. The Ministers of Labour Advisory Committee, which comprises state, territory and Commonwealth labour ministers, agreed in 1990 that “as far as practicable, any standards endorsed by the National Occupational Health and Safety Commission (NOHSC) will be accepted as minimum standards and implemented in the state/territory jurisdiction as soon as possible after endorsement”. In 1991 the NOHSC set up a task force to develop a strategy for harmonisation and by 1996 a number of priority areas had been identified (e.g. hazardous substances) and adopted by the states and territories. More recently, states and territories agreed to work with the Commonwealth to implement a model Occupational Health and Safety Act. Within Europe there have been moves to harmonise standards in different countries. This started with the creation of the European Economic Community (EEC) (or the Common Market) which was established by the Treaty of Rome in 1957. This initially applied to six states, i.e. France, West Germany, Italy, Belgium, the Netherlands and Luxembourg. The Common Market then grew substantially and became the European Union in 1993. There are currently 27 member states. In terms of health and safety integration, the Framework Directive of 1989 (89/391/ EEC) established measures to encourage improvements in the safety and health of workers at work. On joining the Union member states become subject to European Union law and, where applicable, European law supersedes any existing contrary domestic law. © RRC International However it is recognised that there are a number of different legal systems within the EU. The EU issues directives which are “binding as to the result achieved upon each member state to which it is addressed, but shall leave to the national authorities the choice of form and methods”. This allows each member state to introduce its own legislation as long as it achieves the broad objectives contained within the directive. For example, within the UK regulations are made under the enabling Health and Safety at Work, etc. Act 1974. LOSS EVENTS IN TERMS OF FAILURES IN THE DUTY OF CARE TO PROTECT INDIVIDUALS AND COMPENSATORY MECHANISMS THAT MAY BE AVAILABLE If a worker has a work-related accident or contracts a disease as a result of their work, this may result in loss that may include pain and suffering, as well as loss of future income. The accident or ill health may lead to death, which may result in the worker’s dependants suffering major financial loss. There are a number of mechanisms that have evolved to provide compensation to the injured worker, or to his or her dependants. Some require the person making the claim to prove that their accident or ill health was a result of the fault of another, such as their employer. This invariably means having to resort to litigation in the courts. Others do not require proof of fault (no fault liability). Compensatory Schemes These can be conveniently divided into those schemes where it is not necessary to prove that the employer was at fault, and those in which the claimant (the injured person) has to prove that the defendant was at fault, e.g. negligence. No-Fault Compensation Schemes Although there is no need to prove fault, it is necessary to establish that the harm was caused as a result of the person’s employment. Most no-fault workers’ compensation schemes fall into one of two main categories: • Employers provide the benefits; they pay premiums to insurance companies, who in turn pay compensation to the injured worker. • The government or a government agency provides the benefits. The system consists of social insurance operated by the government or an agency of the government. Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-5 Comparative Governmental and Socio-Legal and Corporate Regulatory Models Under both models the worker is required to report the injury or ill health to their respective employer. Most countries require the claim to be made within a specified time, although this is often extended in cases of occupational disease, when the time between exposure to the hazard and the onset of the disease may be considerable. • Employers’ Schemes Here the obligation to provide benefits is imposed on employers. The scheme is operated by insurance companies who are paid premiums by employers, and in many jurisdictions this is compulsory. The insurance companies are subject to regulation, usually by an agency of the government. It is usual for all workers in that industry to be covered by the scheme and in some jurisdictions this includes the self-employed. When a claim has been made by the worker or dependants, the initial response is usually made by the insurance company or sometimes by the employer. The decision may be to accept or to reject the worker’s claim, although it is common for there to be some negotiation by the two parties concerned. Such schemes are found in the USA and Australia. • Social Insurance Schemes These schemes are administered by government and funded by compulsory contributions made by employers, workers or both, with possible further contributions made from general taxation. These contributions may be at a fixed rate or may be earnings-related. The scheme invariably requires medical examinations to establish the nature of the loss and whether any recovery is likely. Following the decision by the administering government department, the claimant can accept the decision or challenge it. The employer usually has little interest, if any, in the process. If the disability is permanent (e.g. hearing loss), then a pension is usually paid, rather than a lump sum. The UK operates an Industrial Injuries Disablement Benefit Scheme. This is funded by National Insurance contributions which are paid by employees and employers and from taxation. The benefit is paid to someone who has suffered a loss of faculty because of an accident at work, or has a prescribed industrial disease associated with the person’s occupation. It is paid only to employees and not to the self-employed. An “accident” is an incident or series of identifiable incidents which has resulted in personal injury; a “prescribed disease” is one from a defined list of about 70 diseases. 8-6 The claimant completes a claim form that is evaluated to establish whether the injury was an accident, or in the case of an occupational disease, to check that the claimant has worked in the prescribed occupation. If this is established, a medical examination is required to identify the loss of faculty and the level of disablement. Normally a person’s disablement has to be 14% or more to receive benefit, except for certain respiratory diseases, which require a 1% assessment and occupational deafness, which requires a 20% assessment. Fault Compensation Scheme - Employers’ Liability Most jurisdictions (including the USA, Australia and the UK) have legislation that makes an employer liable for injury or illness to a worker as a result of their occupation. This requires the injured worker (or dependants following a fatal outcome) to bring a civil action against the employer and the need to establish fault on the part of the employer, or one of his or her workers. The claimant usually has to prove that the harm or illness was caused by the negligence of the employer or one of his employees or that there has been a breach of health and safety legislation. In the UK, the basis of the employer’s duty towards his employees stems from the existence of a contract of employment. However, virtually all cases are brought under the law of tort (civil wrongs), in particular the tort of negligence and the tort of breach of statutory duty. The liability of the employer may come about in two ways: • The employer is responsible for his or her own acts of negligence - often called primary liability. • The employer may be vicariously liable for the negligent acts of his or her workers that are committed in the course of their employment. In an action for breach of statutory duty the claimant has to prove: • The statute places the obligation on the defendant. • The statutory duty was owed to that claimant (i.e. the claimant must show he is within the class of persons whom the statute was intended to protect). • The injury was of a type contemplated by the statute. • The defendant was in breach of that duty. • The breach of statutory duty caused the injury. | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Comparative Governmental and Socio-Legal and Corporate Regulatory Models In an action for negligence the claimant must prove: • The defendant owed the claimant a duty of care; it is well established that an employer owes a duty of care to their workers and so if the defendant is an employer this element is unlikely to be contested. • The defendant was in breach of that duty - most negligence cases hinge on this point. The important point to note is that the standard required of the defendant is an objective one, i.e. it depends on the standard of care which would have been adopted by the reasonable man in the circumstances. • The claimant suffered damage as a result of the breach. • The harm was foreseeable. A claim will often be presented under both headings (negligence and breach of statutory duty) at the same time, although success under both results in only one award of compensation. One of the key features of employers’ liability is the extent of the compensation (often called damages) awarded in a successful action. The compensation awarded is meant to put the person back into the same position they were in before they suffered the loss. This can amount to considerable sums of money. Damages Damages may be classified as economic or noneconomic. Economic damages represent actual monetary loss, whereas non-economic damages are those which represent pain, suffering, and loss of companionship or amenity. Damages may also be categorised as compensatory and punitive. As the name suggests, compensatory damages compensate the claimant, whereas punitive damages are meant to punish the wrongdoer. © RRC International TOPIC FOCUS Compensatory Damages The amount of compensatory damages is meant to reflect the losses the claimant has suffered. The level of award is determined by the court having received evidence as to the extent of the losses. Such damages can be classified as special damages and general damages. • Special Damages The key feature of special damages is that they can be relatively easily quantified because they relate to known expenditure up until the trial, such as: –– Loss of earnings due to the accident or ill health before the trial. –– Legal costs. –– Medical costs to date. –– Building costs, if property has had to be adapted to meet the needs of the injured person. –– Necessary travel costs associated with the case. The feature here is that invoices and receipts can be presented to the court. • General Damages These include future expenditure and issues which cannot be precisely quantified, such as: –– Loss of future earnings as a result of the incapacity. –– Future medical costs. –– Pain and suffering before and after the trial. –– Loss of quality of life, e.g. loss of mobility, inability to engage in sports which had been pursued before the loss. –– Loss of future opportunity, e.g. reduced likelihood of being able to secure suitable employment. Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-7 Comparative Governmental and Socio-Legal and Corporate Regulatory Models Punitive Damages Punitive damages are awarded to punish, to signify disapproval, and to deter the defendant and others from carrying out similar conduct to that which harmed the claimant in the future. It is recognised that in certain circumstances, punitive damages (or exemplary damages in the UK) may be awarded where the compensatory damages are considered to be inadequate and are awarded by reference to the defendant’s behaviour. Since they usually compensate the claimant’s losses beyond provable losses, they are usually only awarded when the conduct of the defendant was particularly oppressive, or where the defendant made a profit from the behaviour. In the USA, punitive damages are a matter for state law and so there is no consistent application across the country. In some states they are based on statute and in others on case law. MECHANISMS USED TO ENFORCE HEALTH AND SAFETY LEGISLATION Typical Role and Function of Enforcement Agencies As with all criminal law it is necessary to have a government body that is responsible for regulating health and safety at work. In the UK this task falls to the government agency known as the Health and Safety Executive (HSE). The HSE state that “their job is to protect people against risks to health or safety arising out of work activities”. They also “conduct and sponsor research, promote training, provide an information and advisory service and submit proposals for new or revised regulations and approved codes of practice”. In the USA the enforcing body is the Occupational Safety and Health Administration (OSHA) whose purpose is “to reduce workplace fatalities, injuries, and illnesses by promoting workplace safety and health”. In Australia the UK model for enforcement was followed, with most of the state Occupational Health and Safety inspectorates now unified. We will use the UK system to illustrate a typical model for the enforcement of health and safety legislation. 8-8 TOPIC FOCUS A Model for the Enforcement of Health and Safety Legislation - Inspection and Investigation Inspectors visit premises, often without an appointment, for the following reasons: • To conduct an inspection. • To check that appropriate action has been taken as a result of a previous visit. • To investigate an accident, dangerous occurrence or a case of occupational ill health. • To investigate a complaint. • At the request of the employer, union representative, worker or member of the public. Inspectors have extensive powers to carry out their duties, including a right: • Of entry into the premises at any reasonable time. • To take a policeman with them if there is reasonable cause to believe that there might be obstruction resulting in a breach of the peace. • To carry out any investigations and examinations as necessary (e.g. investigation of an accident or a complaint). • To direct that the premises are left undisturbed for as long as is necessary to complete the investigation so that evidence is preserved. • To take measurements, photographs and record information as necessary for the investigation. • To take samples of any articles and substances. • To cause an article to be dismantled and tested or a substance to be analysed. • To require any person whom the inspector believes to have relevant information to give a statement. • To inspect and take copies of any entry in any relevant book or document (e.g. accident book). Inspectors have a number of ways of encouraging dutyholders to comply with legal requirements. The most widely used approach is that of providing advice on what changes need to be introduced and how these may be achieved. Inspectors often refer to the vast amount of guidance literature that has been published by the HSE and other bodies. This advice is often confirmed in writing. | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Comparative Governmental and Socio-Legal and Corporate Regulatory Models Criminal Action The ultimate sanction that the UK enforcement agencies can impose is to prosecute. Since most duties under health and safety law are imposed on employers, it is not surprising that most prosecutions are brought against employers. However, health and safety law also imposes duties on workers, importers and manufacturers, etc. Apart from there being evidence of a breach of statutory duty, inspectors take account of the nature of the breach, any resulting harm, past health and safety performance and whether prosecution would be in the public interest before deciding to prosecute. TOPIC FOCUS Enforcement Notices Inspectors can exert more pressure by issuing enforcement notices, which are in two categories. Improvement Notices Issued by an inspector if he is of the opinion that a person: • Is contravening one or more relevant statutory provisions; or Following a successful prosecution the usual penalty is a fine, or in some circumstances (e.g. non-compliance with an enforcement notice), the possibility of imprisonment. Imprisonment is not an option for a company, because it has a separate legal status to that of anyone who works for it. • Has contravened one of the provisions and it is likely that the contravention will continue or be repeated. Fines are a limited form of penalty for several reasons. In the UK, fines are usually relatively small compared to the turnover and profitability of the company and so some companies may take the chance of being prosecuted rather than invest in health and safety. There is also no evidence indicating that fines lead to improved standards in health and safety. The following alternative penalties are therefore also available. • Specify the contravention; The notice must: • State the inspector is of that opinion; • Give reasons as to why the opinion has been formed; and • The requirement for the contravention to be remedied within a period of no less than 21 days. The decision to issue a notice is therefore based entirely on the inspector’s opinion. The 21 days is to allow the person to appeal against the notice (see below). If the person decides to appeal then the notice is suspended until the appeal is heard. Prohibition Notices Issued by an inspector if he is of the opinion that activities are being carried out, or are likely to be carried out, that involve a risk of serious personal injury. There is no requirement to identify a specific breach of law. The notice must: • State the inspector is of that opinion; • Specify the matters which give rise to the risk of serious personal injury; and • Direct that the activities to which the notice relates shall be stopped under the control of the person on whom the notice is served, unless the risk of serious personal injury has been removed. The notice will indicate if it is to take effect immediately, or after a specified time. As with improvement notices, the person on whom the notice is served may appeal against the notice. However, a prohibition notice is not suspended pending the outcome of the appeal. © RRC International Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-9 Comparative Governmental and Socio-Legal and Corporate Regulatory Models Appeals Against Notices The person on whom the notice is served has the opportunity of appealing against it to an employment tribunal. In the UK, such tribunals have the same status as courts, but deal solely with issues to do with employment. The tribunal will then decide, on the basis of the evidence presented to it, to affirm, modify, or cancel the notice. Appeals are usually held in public and either side may be represented by a lawyer. Corporate Probation This is a feature of the USA and Canadian jurisdictions, but is a relatively new provision in the UK. Corporate probation is a supervision order imposed by the court on a company that has been convicted of a criminal offence. The order requires the directors and senior managers to alter the way occupational health and safety is managed, so that the likelihood of similar accidents or ill health occurring is reduced. This might, for example, require the company to introduce new procedures or ensure workers are fully trained. The court might decide to suspend part of the fine so that if the company met the requirements of the order, that part would not have to be paid. However, if the company fails to comply with the terms of the order, not only could the suspended sentence be invoked, but further penalties could also be imposed. This might include disqualifying one or more directors from their roles. The key benefit of this type of punishment is that it gives the court the power to set a penalty that is matched to the particular company and would hopefully achieve a positive change in the way in which the company operates. In the USA, corporate probation can be imposed on corporations that have been found guilty of criminal offences. The main objective in the USA is to force convicted companies to pay compensation and prevent them from hiding assets. Adverse Publicity Orders These are a feature of a number of jurisdictions including the USA, Australia and more recently the UK. They require the convicted organisation to publicise at their own expense the wrongdoing that led to the conviction. It is effectively “naming and shaming”. Established companies invariably seek to promote themselves as being well managed organisations that take health and safety seriously. Establishing a good reputation is important if they are to successfully compete with other organisations by securing investment from shareholders and financial institutions. Bad publicity will have a negative effect on the image of the organisation and may have serious financial implications for its future. 8-10 The use of adverse publicity orders was introduced in the Corporate Manslaughter and Corporate Homicide Act 2007 which became UK law in April 2008. Following a conviction for corporate manslaughter, the court has the choice of imposing an adverse publicity order. A court before which an organisation is convicted of corporate manslaughter or corporate homicide may make an order (a “publicity order”) requiring the organisation to publicise in a specified manner: • The fact that it has been convicted of the offence. • Specified particulars of the offence. • The amount of any fine imposed. • The terms of any remedial order made. LAWS OF CONTRACT Contract law is a feature of many jurisdictions including the UK, Australia and America. Contract law has many implications in respect of occupational health and safety. The relationship between an employer and employee or contractors is based on a contract of employment. Similarly, contracts are established between those who manufacture articles or substances and those who buy them. TOPIC FOCUS Contract In the legal context, a contract is an exchange of promises, i.e. an agreement between two or more parties which is enforceable in a court of law. There must be a valid offer from one party, and a valid acceptance before the contract is established. The offer must be communicated by one party to another and may be in writing, verbal or by conduct. Business contracts are usually communicated and accepted in writing because it is much easier to prove that it has been created. When we purchase an item in a shop we enter into a contract with the vendor or seller. The receipt would be proof of the existence of the contract. The terms of a contract can be express or implied: • Express terms are stated by the parties during negotiation, or written into a contractual document so it is clear what is required of each party. • Implied terms are not explicitly stated in the contract, but are implied by custom, statute or by the courts. For example, in the sale of goods an implied term is that the seller has the right to sell the goods and that in business sales the goods are of satisfactory quality and are fit for purpose. | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Comparative Governmental and Socio-Legal and Corporate Regulatory Models Principles of Typical Laws of Contract If a contract is formed, then the parties who formed the contract are legally bound by the terms of the contract - the binding nature of a contract. If, subsequently, one of the parties defaults on the contract then this would constitute a breach of contract. It is not possible to bring a legal action against somebody for breach of contract who was not part of the contract. This is called privity of contract. If the person who has caused the breach does not provide a remedy then the person who has suffered a loss as a result of the breach can bring a court action. When an employer engages an employee, a contract of employment is established. Employer↔ Employee One of the implied terms of such a contract is that the employer will take reasonable care to ensure the health and safety of the employee. Similarly, the employee is required to carry out his or her work with reasonable care and skill. A breach of contract, such as not adhering to the safety rules may constitute a breach of contract resulting in the employer dismissing the employee. If the contract is breached and there is personal injury then in the UK it is usual to bring a civil action under the common law tort of negligence or breach of statutory duty, rather than for breach of contract. When articles and substances are manufactured there may be a series of contracts established between the producer (or manufacturer) and the consumer (or end user). Producer ↔ Vendor ↔ Consumer For example, if a person purchases a machine of a particular make and model for use at work and the vendor sells a machine that does not meet this specification, then the consumer would be entitled to have the machine replaced with the one ordered, or alternatively receive a full refund of the moneys paid. Similarly, it is common place for employers to engage contractors for short-term work, particularly in the construction industry. Employer ↔ Contractor ↔ Subcontractor The contract chain may be very short or, in the case of articles and substances manufactured in another country, the chain can involve importers and be much longer. Each member engages in contracts with those above and below in the chain. If a contract fails for such matters as failure to supply the correct goods, poor quality work or not completing the work within the time specified by the contract, etc. a civil action for breach of contract may follow. Remember, though, that personal injury cases usually result in civil actions for negligence and breach of statutory duty rather than for breach of contract. REVISION QUESTIONS 1. What are the limitations of using legislation as a means of ensuring acceptable occupational health and safety standards? 2. Describe the benefits and limitations of prescriptive and goal-setting legislation. 3. Identify and outline the two main no-fault compensation schemes. 4. Describe the two categories of compensatory damages. 5. What are meant by punitive damages? 6. Explain the term “corporate probation”. (Suggested Answers are at the end.) © RRC International Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-11 Role and Limitations of the International Labour Organisation in a Global Health and Safety Setting KEY INFORMATION • The adoption of a convention by the International Labour Conference (ILO) allows governments to ratify it and for it to become a treaty in international law. All adopted ILO conventions are considered international labour standards. • Recommendations are non-binding guidelines, are not ratified by member countries, and do not have the binding force of conventions. • ILO codes of practice contain practical recommendations intended for all those with a responsibility for occupational safety and health but are not legally binding instruments and are not intended to replace the provisions of national laws or regulations, or accepted standards. • Occupational Safety and Health Recommendation 1981 (R164) sets out the roles and responsibilities of governments, enterprises and workers. • International conventions can be used as a basis for setting national systems of health and safety legislation. ROLE AND STATUS OF RATIFIED CONVENTIONS, RECOMMENDATIONS AND CODES OF PRACTICE IN RELATION TO HEALTH AND SAFETY ILO Role and International Labour Conference The International Labour Organisation (ILO) is an agency of the United Nations (UN) that is devoted to advancing opportunities for women and men to obtain decent and productive work in conditions of freedom, equity, security and human dignity. The ILO was created in 1919, as part of the Treaty of Versailles that ended World War I. Its main aims are to promote rights at work, encourage decent employment opportunities, enhance social protection and strengthen dialogue in handling work-related issues. The ILO is the only “tripartite” United Nations agency in that it brings together representatives of governments, employers and workers to jointly shape policies and programmes. The member states of the ILO meet at the International Labour Conference, held every year in June in Geneva, Switzerland. Each member state is represented by a delegation consisting of two government delegates, an employer delegate, a worker delegate, and their respective advisers. Every delegate has the same rights, and all can express themselves freely and vote as they wish; worker and employer delegates may vote against their government’s representatives, or against each other. However, this diversity of viewpoints does not prevent decisions being adopted by very large majorities, or in some cases even unanimously. Many of the government representatives are cabinet ministers responsible for labour affairs in their own countries. Heads of state and prime ministers also take the floor at the conference. International organisations, both governmental and others, attend as observers. The conference allows for the creation of conventions and recommendations - a two-thirds majority is required before they can be adopted. The ILO is the global body responsible for drawing up and overseeing international labour standards. Working with its 181 member states, the ILO seeks to ensure that labour standards are respected in practice, as well as principle. Since its early days, the ILO has sought to define and guarantee labour rights and improve conditions for working people by building a system of international labour standards expressed in the form of conventions, recommendations and codes of practice. The ILO has adopted more than 180 ILO conventions and 190 recommendations covering all aspects of the world of work. Nearly half of all ILO standards are concerned with health and safety matters. 8-12 | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Role and Limitations of the International Labour Organisation in a Global Health and Safety Setting TOPIC FOCUS ILO Conventions The adoption of a convention by the International Labour Conference allows governments to ratify it, and when a specified number of governments have done so, the convention becomes a treaty in international law. All adopted ILO conventions are considered international labour standards, irrespective of how many governments have ratified them. Ratification of a convention imposes a legal obligation to apply its provisions. However, it is voluntary for a country to ratify a convention. If a convention has not been ratified by member states, it has the same legal force as recommendations. Each government is required to submit a report detailing their compliance with the obligations of the conventions they have ratified. Each year the International Labour Conference’s Committee on the Application of Standards examines a number of alleged breaches of international labour standards. An example of a convention is the Occupational Safety and Health Convention 1981 and its protocol of 2002. This provides for the adoption of a coherent national occupational safety and health policy as well as action to be taken by governments to improve working conditions. International Labour Conference Provisional Record 20A Convention Concerning the Promotional Framework for Occupational Safety and Health, ILO, Geneva, 2006 Article 4 sets out the following provisions in respect of a national system. “1. Each Member shall establish, maintain, progressively develop and periodically review a national system for occupational safety and health, in consultation with the most representative organisations of employers and workers. 2. The national system for occupational safety and health shall include among others: (a) laws and regulations, collective agreements where appropriate, and any other relevant instruments on occupational safety and health; (b) an authority or body, or authorities or bodies, responsible for occupational safety and health, designated in accordance with national law and practice; © RRC International 3. (c) mechanisms for ensuring compliance with national laws and regulations, including systems of inspection; and (d) arrangements to promote, at the level of the undertaking, co-operation between management, workers and their representatives as an essential element of workplace-related prevention measures. The national system for occupational safety and health shall include, where appropriate: (a) a national tripartite advisory body, or bodies, addressing occupational safety and health issues; (b) information and advisory services on occupational safety and health; (c) the provision of occupational safety and health training; (d) occupational health services in accordance with national law and practice; (e) research on occupational safety and health; (f) a mechanism for the collection and analysis of data on occupational injuries and diseases, taking into account relevant ILO instruments; (g) provisions for collaboration with relevant insurance or social security schemes covering occupational injuries and diseases; and (h) support mechanisms for a progressive improvement of occupational safety and health conditions in micro-enterprises, in small and medium-sized enterprises and in the informal economy.” Copyright © International Labour Organisation 2006 Following the adoption of the above convention in 2006, each member of the ILO is required to introduce measures to implement its requirements within their own legislative system. TOPIC FOCUS ILO Recommendations Recommendations are non-binding guidelines so are not ratified by member countries and do not have the binding force of conventions. Along with conventions, recommendations are drawn up by representatives of governments, employers and workers, and are adopted at the ILO’s annual International Labour Conference. An example is the Occupational Safety and Health Recommendation R164 1981 which we look at below. Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-13 Role and Limitations of the International Labour Organisation in a Global Health and Safety Setting TOPIC FOCUS (e) ILO Codes of Practice ILO codes of practice contain practical recommendations intended for all those with a responsibility for occupational safety and health in both the public and private sectors. Codes of practice are not legally binding instruments and are not intended to replace the provisions of national laws or regulations, or accepted standards. They aim to serve as practical guides for public authorities and services, employers and workers concerned, specialised protection and prevention bodies, enterprises and safety and health committees. Each code is first prepared by the Office (of the ILO) and finalised at a tripartite meeting composed of experts nominated by the Governing Body (of the ILO) in their personal capacity. Codes of practice are submitted to the Governing Body for approval of publication. An example is the Code of Practice on Safety and Health in the Iron and Steel Industry (2005). ROLES AND RESPONSIBILITIES OF ‘NATIONAL GOVERNMENTS’, ‘ENTERPRISES’ AND ‘WORKERS’: R164 OCCUPATIONAL SAFETY AND HEALTH RECOMMENDATION 1981 Occupational Safety and Health Recommendation 1981 (R164) sets out the roles and responsibilities of governments, enterprises and workers. The key provisions are as follows. National governments should: “(a) issue or approve regulations, codes of practice ........ on occupational safety and health and the working environment, account being taken of the links ... between safety and health, ... and hours of work and rest breaks ...; (b) ....... review legislative enactments concerning occupational safety and health and the working environment, ... in the light of experience and advances in science and technology; (c) undertake or promote studies and research to identify hazards and find means of overcoming them; (d) provide information and advice, in an appropriate manner, to employers and workers and promote or facilitate co-operation between them and their organisations, with a view to eliminating hazards or reducing them as far as practicable; where appropriate, a special training programme for migrant workers in their mother tongue should be provided; 8-14 (f) (g) provide specific measures to prevent catastrophes, and to co-ordinate and make coherent the actions to be taken at different levels, particularly in industrial zones where undertakings with high potential risks for workers and the surrounding population are situated; secure good liaison with the International Labour Occupational Safety and Health Hazard Alert System set up within the framework of the International Labour Organisation; provide appropriate measures for handicapped workers.” Enterprises: “(a) to provide and maintain workplaces, machinery and equipment, and use work methods, which are as safe and without risk to health as is reasonably practicable; (b) to give necessary instructions and training, taking account of the functions and capacities of different categories of workers; (c) to provide adequate supervision of work, of work practices and of application and use of occupational safety and health measures; (d) to institute organisational arrangements regarding occupational safety and health and the working environment adapted to the size of the undertaking and the nature of its activities; (e) to provide, without any cost to the worker, adequate personal protective clothing and equipment which are reasonably necessary when hazards cannot be otherwise prevented or controlled; (f) to ensure that work organisation, particularly with respect to hours of work and rest breaks, does not adversely affect occupational safety and health; (g) to take all reasonably practicable measures with a view to eliminating excessive physical and mental fatigue; (h) to undertake studies and research or otherwise keep abreast of the scientific and technical knowledge necessary to comply with the foregoing clauses. Copyright © International Labour Organisation 1981 | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Role and Limitations of the International Labour Organisation in a Global Health and Safety Setting The measures taken to facilitate the co-operation referred to in Article 20 of the Convention should include, where appropriate, the appointment of workers’ safety delegates or representatives of workers’ safety and health committees, and/or of joint safety and health committees. In joint safety and health committees, workers should have at least equal representation with employers’ representatives. Delegates and committees should: “(a) be given adequate information on safety and health matters, enabled to examine factors affecting safety and health, and encouraged to propose measures on the subject; (b) be consulted when major new safety and health measures are envisaged and before they are carried out, and seek to obtain the support of the workers for such measures; (c) be consulted in planning alterations of work processes, work content or organisation of work, which may have safety or health implications for the workers; (d) be given protection from dismissal and other measures prejudicial to them while exercising their functions in the field of occupational safety and health as workers’ representatives or as members of safety and health committees; (e) be able to contribute to the decision-making process at the level of the undertaking regarding matters of safety and health; (f) have access to all parts of the workplace and be able to communicate with the workers on safety and health matters during working hours at the workplace; (g) be free to contact labour inspectors; (h) be able to contribute to negotiations in the undertaking on occupational safety and health matters; (i) have reasonable time during paid working hours to exercise their safety and health functions and to receive training related to these functions; (j) have recourse to specialists to advise on particular safety and health problems.” Workers should: “(a) take reasonable care for their own safety and that of other persons who may be affected by their acts or omissions at work; (b) comply with instructions given for their own safety and health and those of others and with safety and health procedures; (c) use safety devices and protective equipment correctly and do not render them inoperative; (d) report forthwith to their immediate supervisor any situation which they have reason to believe could present a hazard and which they cannot themselves correct; (e) report any accident or injury to health which arises in the course of or in connection with work.” Copyright © International Labour Organisation 1981 USE OF INTERNATIONAL CONVENTIONS AS A BASIS FOR SETTING NATIONAL SYSTEMS OF HEALTH AND SAFETY LEGISLATION In the UK the body responsible for establishing and enforcing health and safety standards is the Health and Safety Executive. It is committed to bringing conventions and recommendations before Parliament within a year, or exceptionally 18 months, of adoption. The procedural tool for achieving this is through a White Paper produced by the Department for Work and Pensions (DWP). A proposed new law is called a Bill. Bills must be agreed by both Houses of Parliament and receive Royal Assent from the Queen before they can become an Act of Parliament and law. REVISION QUESTIONS 7. Explain the role of the International Labour Organisation in respect of health and safety at work. 8. Explain the difference between an ILO convention and a recommendation. 9. What is an ILO code of practice? 10. What duties are imposed on national governments by R164 Occupational Safety and Health Recommendation 1981? 11. What duties are imposed on enterprises by R164 Occupational Safety and Health Recommendation 1981? 12. What duties are imposed on workers by R164 Occupational Safety and Health Recommendation 1981? (Suggested Answers are at the end.) © RRC International Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-15 Role of Non-Governmental Bodies and Health and Safety Standards KEY INFORMATION • The following influential parties have a key role in regulating health and safety performance: –– Employer bodies. –– Trade associations. –– Trade unions. –– Professional groups. –– Pressure groups. –– The general public. • The media play an important role in communicating health and safety issues and can influence changes in attitudes to health and safety. • There are benefits to be had in schemes which promote co-operation on health and safety between different companies. • Following any adverse health and safety incident there will be financial implications for the organisation. Some of the losses can be quantified, but there will be a range of indirect costs whose effect cannot easily be determined. • Self-regulation is the process whereby an organisation monitors its own adherence to health and safety standards, rather than having an outside agency, such as a governmental body, monitoring and enforcing them. • Corporate governance is the system by which organisations are directed and controlled by their board of directors who make strategic decisions that affect the direction of the organisation. Their area of control should include occupational health and safety as well as other corporate objectives such as being competitive and making a profit. • For an organisation to effectively manage occupational health and safety it must devise and implement rules and procedures that enable workers to adhere to safe working practices. • Non-conformity to an accredited health and safety standard can be used as a form of enforcement on a selfregulatory model since all safety management models include the capacity for monitoring, audit and feedback which leads to continuous improvement. RELEVANT INFLUENTIAL PARTIES Employer Bodies These represent the interests of employers. In the UK the main body is the Confederation of British Industry (CBI). The CBI helps create and sustain the conditions in which businesses in the United Kingdom can compete and prosper for the benefit of all. The CBI is the main lobbying organisation for UK business on national and international issues. It works with the UK government, international legislators and policymakers to help UK businesses compete more effectively. Another well-known active employer organisation is the Chamber of Commerce. You will find branches operating in many countries throughout the world. Trade Associations Trade associations are formed from a membership of companies who operate in a particular area of commerce and exist for their benefit. They can promote common interests and improvements in quality, health, safety, environmental and technical standards through various appropriate means, e.g. the publication of guidelines, information notes, codes of practice, and regular briefing notes on technical issues and regulatory developments. Sharing of good practice can be facilitated together with provision of news and events appropriate to their members’ areas of activity. Meetings, workshops and seminars can be arranged depending on an association’s membership, both internationally and at a national/regional level, to enable networking and the exchange of information and ideas, e.g. on technical and safety issues. Safety is of prime importance in any industry and there is usually a system for publicising and circulating safety messages to members on a regular basis. Membership of a trade association is generally available to companies and organisations active in the relevant industry. 8-16 | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Role of Non-Governmental Bodies and Health and Safety Standards Trade Unions General Public A trades union is an organisation of workers who have formed together to achieve common goals in key areas, such as wages, hours and working conditions. The trade union negotiates with the employer on behalf of its members. This may include the negotiation of wages, work rules, complaint procedures, rules governing hiring, firing and promotion of workers, benefits, workplace safety and policies. The agreements negotiated by the union leaders are binding on the rank and file members and the employer, and in some cases on other nonmember workers. In the UK, unions may appoint safety representatives from amongst the workers who may investigate accidents, conduct inspections and sit on a safety committee. Individual members of the public can have little influence on the regulation of health and safety unless they can influence others and so form a body of opinion (e.g. a pressure group) that cannot be ignored. Professional Groups A professional group is an organisation of individuals who work in a particular profession and have achieved a defined level of competence. Members typically pay a subscription to join the group and receive a range of benefits. In the UK, the Institution of Occupational Safety and Health (IOSH) is the largest body for health and safety professionals, with over 30,000 members worldwide, including more than 10,000 Chartered Safety and Health Practitioners. It is an independent, not-for-profit organisation that sets professional standards, supports and develops members, and provides authoritative advice and guidance on health and safety issues. IOSH has increased its international presence in more recent years. It has local branches not only in the UK, but also in the Middle East, Hong Kong and the Caribbean. IOSH is formally recognised by the ILO as an international non-governmental organisation. Pressure Groups A pressure group can be described as an organised group of people who have a common interest but, unlike a political party, do not put up candidates for election. However, they seek to influence government policy or legislation. They can also be described as ‘interest groups’, ‘lobby groups’ or ‘protest groups’. They carry out research, lobby politicians and so aim to influence public and ultimately, government opinion. One example in the UK is the Centre for Corporate Accountability. This is concerned with the promotion of worker and public safety. Its focus is on the role of state bodies in enforcing health and safety law and investigating work-related deaths and injuries. It was formed following a number of high profile workrelated accidents that led to a large number of deaths, and the perception that the companies concerned were not taking safety seriously and that the penalties imposed by the courts were inadequate. © RRC International IMPORTANCE OF THE MEDIA IN A GLOBAL ECONOMY The media play an important role in communicating health and safety issues and can influence changes in attitudes to health and safety. The media includes print media (e.g. newspapers, books and journals), broadcast media (e.g. radio and television) and of increasing importance Internet-based media, such as the World Wide Web. No country can successfully compete in a global economy without the use of media as a communication tool. In terms of occupational health and safety the following points indicate some of the ways the media is used: • Making health and safety guidance easily accessible with minimal cost. Agencies such as OSHA (USA) and the HSE (UK) produce guidance for all categories of dutyholders in all types of employment. This is available in hard copy and more commonly in electronic format that can be downloaded. This allows dutyholders who have limited expertise to access relevant information and so comply with legal requirements. • Publicising good and bad health and safety performance, e.g. TV and radio may publicise major accidents, prosecutions and public inquiries. Major disasters may be publicly discussed not only in the country in which they occurred, but internationally, e.g. the Chernobyl disaster. Incidents with lesser consequences may be publicised within the area in which they occurred. Such publicity increases the awareness of occupational health and safety issues and reminds dutyholders of the possible consequences of failing to pay attention to these issues. • Assisting in educating members of the professional body and promoting good health and safety standards by publishing professional journals (e.g. Institution of Occupational Safety and Health (UK)). • Enabling anyone with an Internet connection access to a huge range of information (good and bad) which would otherwise be much less accessible. Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-17 Role of Non-Governmental Bodies and Health and Safety Standards • Enforcement bodies making information on good health and safety practice easily accessible to dutyholders. Supplier auditing is the process by which an organisation establishes that its existing and new suppliers meet their requirements. In the context of health and safety, this would include ensuring that the quality of the products and services it supplies meets legal requirements and other standards. For example, this may include the company sending an auditor to a manufacturer of machines to ensure that it has adopted safe working practices and that the machines are constructed from suitable materials and meet designated safety standards. • Companies publicising good health and safety performance to promote their services and to secure a competitive advantage by being seen as good employers. EFFECTS ON BUSINESS OF ADVERSE STAKEHOLDER REACTION TO HEALTH AND SAFETY CONCERNS The media can be used to help change attitudes to occupational health and safety; examples of this include: • Making the public, and in particular dutyholders, aware of enforcement action such as prosecutions, convictions and civil actions, through the newspapers, TV/radio and the Internet. • Adverse publicity orders (see earlier) are a sanction that the courts may impose against organisations that fail to comply with legal requirements. They will have an adverse effect on the perceived reputation of the organisation. BENEFITS OF SCHEMES WHICH PROMOTE CO-OPERATION ON HEALTH AND SAFETY BETWEEN DIFFERENT COMPANIES Explicit co-operation between companies is not usual because in a free market, companies compete with each other for customers and so may be reluctant to share good practices for fear of giving their competitors an advantage. However there are many schemes that have been established that promote co-operation between different companies. Depending on the benefits received by the participants, these may last for a short period, or carry on indefinitely. The establishment of such schemes may be facilitated and encouraged by government bodies, or they may be set up informally. An example of such schemes is the so called good neighbour schemes. In the UK a number of schemes have been established to encourage larger organisations to help smaller businesses and contractors with health and safety expertise. Small businesses do not have access to the same health and safety expertise, so if a large organisation can provide advice to a smaller one, then the smaller business will benefit and the larger organisation will be able to demonstrate its public responsibility. Following any adverse health and safety incident, such as an accident or case of occupational ill health, there will be financial implications for the organisation. Even a small incident in which a worker has to receive first aid will invariably cost money, including lost production from the injured person and from those who give first aid and manage the incident. Personal injury cases may involve a claim for damages by the injured person which will again have a financial impact on the organisation. There may be a loss of morale amongst workers in the organisation in the belief that the organisation does not care about their health and safety. This may then lead to key personnel seeking employment elsewhere, even though they may have not suffered any direct loss. Some of the losses already mentioned, e.g. loss of production, can be relatively easily quantified, but there will be a range of indirect costs whose effect cannot easily be determined. One such effect is on the stakeholders of an organisation. These are individuals who have an interest in the organisation and include: • Workers who rely on the organisation for employment. • Other businesses, including suppliers and contractors who trade with the organisation. • Businesses that benefit indirectly from the presence of an organisation, e.g. local shops. • Shareholders who own the organisation and wish to see their investment yield a satisfactory financial return. We will consider the effects on stakeholders by considering two incidents. Schemes have also been established between organisations of similar size. They might involve sharing expertise and equipment such as a noise meter. It is much less costly to share such resources and all members of the scheme will benefit. 8-18 | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Role of Non-Governmental Bodies and Health and Safety Standards Perrier Mineral Water Incident, 1990 Piper Alpha Disaster, 1988 Perrier is a French company that produces and bottles mineral water. In early 1990, very small quantities of benzene (an industrial solvent and a known carcinogen) were discovered in bottles of the water in the USA. As a result, the company had to withdraw from sale every bottle of its water, which cost an estimated 200 million US dollars. The actual concentration of benzene, although above the limit specified by the US Food and Drug Administration (FDA), was well below that which might endanger health. Unlike the Perrier water incident, the Piper Alpha disaster had a huge impact on all involved and remains the world’s worst offshore disaster. The initial explosion was caused by a failure to manage a maintenance operation. However, failings in design, communication and a lack of emergency preparedness caused the small explosion to escalate into much larger gas explosions that led to the loss of 167 lives and the rig. When the problem was first realised, some 70 million bottles were withdrawn from shops in the USA and without actually knowing the source of the contamination, it was declared that it was due to a bottle of cleaning fluid and was limited to the US. A few days later the real cause was shown to be failure to replace charcoal filters that were used to remove impurities. A subsequent press conference declared that Perrier water “naturally contains several gases, including benzene. Those have to be filtered out.” This declaration proved disastrous. Mineral water such as Perrier has a reputation based on purity and as consumers would have difficulty in distinguishing one brand of mineral water form another, the image of the product is crucial. It was the misinformation provided by the company in the early days of the incident that led to the image that the water was unsafe. As the water was not available, consumers for a few weeks turned to other brands and found that there was little difference in the product. By the time the product was relaunched into the market, confidence had fallen which was reflected in significantly reduced sales and a fall in the share price. Although not a major incident in terms of its effect on human health, the inconsistency in the messages provided by the company had a significant financial impact on the business. The effect on the company was huge and included: • Compensation claims for death and personal injury. • Loss of production. • Loss of cash flow. • Loss of the rig. • Damage to the image of the organisation worldwide. This led to the owners of the rig, Occidental Petroleum, withdrawing their interests from the North Sea. The offshore industry’s image in general was damaged and resulted in the UK economy losing revenue. ORIGINS AND MEANING OF ‘SELFREGULATION’ GLOSSARY SELF-REGULATION The process whereby an organisation monitors its own adherence to health and safety standards, rather than having an outside agency, such as a governmental body, monitoring and enforcing standards. The benefit to the organisation of self-regulation is that it can set and maintain its own standards without external interference. Accordingly if problems arise, it can more easily keep its own internal affairs private. It also avoids the significant national expense of establishing an enforcement agency. In contrast, attempts to self-regulate may fail because individual organisations may believe there is little advantage in establishing good standards if similar organisations choose to ignore them. Workers in a selfregulated organisation may experience poor standards with an increased frequency of accidents and ill health. Self-regulation of health and safety within a legal framework was one of the recommendations of the Robens Committee, which was established in 1970 in the UK to “review the provision made for the safety and health of persons in the course of their employment and to consider whether any changes are needed”. © RRC International Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-19 Role of Non-Governmental Bodies and Health and Safety Standards The Robens report identified that the existing system relied too much on regulation by external government bodies with too little reliance on organisations establishing their own standards. A key recommendation in the report was that those who create the risks of occupational accidents and ill health should be responsible for regulating them. Future legislation should establish conditions for creating more effective self-regulation, rather than relying on more negative regulation by enforcement bodies. The UK agency the Health and Safety Executive defined self-regulation as “the purposeful creation and maintenance of standards of health and safety and the accordance of priorities commensurate with the risks generated by the activities of the organisation”. We mentioned the UK’s Health and Safety at Work, etc. Act 1974 earlier in this element as an example of goalsetting legislation. The Act encourages self-regulation. Section 2 of the Act states: “It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees”. The Act sets out a broad objective, but does not prescribe how it will be achieved. It is for the dutyholder (in this case the employer) to decide what is reasonably practicable. This requires an assessment of the magnitude of the risk associated with the hazard in question and the cost of either eliminating or reducing the risk to a level that is at least “tolerable” (but preferably “acceptable”). Accordingly, the onus is shifted towards the employer to assess risks and to identify and implement appropriate control measures. To achieve self-regulation the Robens Committee recognised the importance of securing worker participation in the implementation and monitoring of health and safety arrangements. In many countries, including the UK, this is achieved through representatives of workplace safety (trade unionised or otherwise) and/or safety committees (which include worker representation). ROLE AND FUNCTION OF CORPORATE GOVERNANCE IN A SYSTEM OF SELFREGULATION Aside from external legislation which may dictate the conduct of the company, an organisation is to a certain extent self-regulating; it sets many of its own objectives and standards and determines how it will achieve them. GLOSSARY CORPORATE GOVERNANCE The system by which organisations are directed and controlled by their board of directors and includes the making of broad strategic decisions that affect the direction of the organisation. It is on a higher level than management, which relates to the regular decisions and subsequent actions needed to effectively run the business. The board of an organisation, that comprises its directors, provides this corporate governance which aims to create a successful organisation. Their area of control includes occupational health and safety as well as other corporate objectives, such as being competitive and making a profit. To ensure good health and safety performance, the board of the organisation generally has to be satisfied that the following matters are dealt with throughout the organisation. • A demonstration of commitment by senior management to occupational health and safety and an appreciation that it is as important as other business objectives. • Ensuring that health and safety is reviewed at board level. • Those in the organisation at all levels have access to, and receive competent advice. • All staff, including board members, are trained and competent in their health and safety responsibilities. • Ensuring that the workforce, and in particular health and safety representatives, are adequately consulted and that their concerns reach the right level within the organisation including, where necessary, the board. • Systems are in place to ensure that health and safety risks are assessed and suitable control measures introduced and maintained. • An awareness of what activities take place in the organisation, including those of contractors. • Ensuring regular information is received regarding matters such as accident reports and cases of workrelated ill health. 8-20 | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Role of Non-Governmental Bodies and Health and Safety Standards • The setting of targets which allow the organisation to improve standards and to benchmark the organisation’s performance against others within the same business sector. • Ensuring that changes in working arrangements that have significant implications are brought to the attention of the board. A report from EU-OSHA, Leadership and Occupational Safety and Health (OSH) – An Expert Analysis, looks at corporate leadership factors on which success depends and identifies the following five broad guiding principles: 1. Leaders must take seriously their responsibility for the establishment of a positive prevention culture and employ leadership styles which take account of the cultural context in different groups or nations. 2. Leaders should be seen to prioritise OSH policies above other corporate objectives, and apply them consistently across the organisation and over time. 3. High-level management must be directly involved in implementing OSH policies which have the unequivocal commitment of an organisation’s board and senior management. 4. Leaders should set out to cultivate an open atmosphere in which all can express their experience, views and ideas about OSH and which encourages collaboration between stakeholders, both internal and external, around delivery of a shared OSH vision. 5. Leaders should show they value their employees, and promote active worker participation in the development and implementation of OSH measures. MORE… The EU-OSHA report, Leadership and Occupational Safety and Health (OSH) – An Expert Analysis, looks at corporate leadership factors and analyses the results of 16 case studies from companies across the EU, identifying success factors and examples of good OSH leadership. The report is available at: HOW INTERNAL RULES AND PROCEDURES REGULATE HEALTH AND SAFETY PERFORMANCE For an organisation to effectively manage occupational health and safety it must devise and implement procedures that enable workers to adhere to safe working practices. This will inevitably include defining rules, and procedures that must be reasonably complied with. Merely stipulating rules is not enough. The worker must clearly understand and appreciate the need for the rules as well as have the competence to comply with them. The working conditions must encourage compliance. For example, a worker required to use a machinery guard in a manufacturing process is less likely to adhere to the rule if the rate at which he can do the work is significantly impaired when the guard is used. Also, of course, if there is a poor safety culture in the workplace and few existing workers comply with the rules, then it cannot be reasonable to expect a new worker to comply. For a rule to be effective it has to be enforced by the organisation. This requires monitoring by supervisors and managers who must have the necessary authority to enforce the rules. This may include routine day-to-day monitoring, formal inspections and random spot checks. Failure to comply with internal rules may lead to sanctions imposed by the employer which may include: • Informal verbal warnings. • Formal verbal and written warnings. • Temporary suspension from work. • Demotion. • Dismissal. Such sanctions have to be imposed fairly and must not constitute bullying. They must also comply with the national employment law. Suitable and fairly enforced safety rules will reduce the likelihood of workers violating them, which will create an environment in which safe working becomes the norm. This will accordingly reduce the likelihood of accidents and ill health. https://osha.europa.eu/en/publications/literature_ reviews/leadership-and-occupational-safety-andhealth-osh-an-expert-analysis/view © RRC International Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-21 Role of Non-Governmental Bodies and Health and Safety Standards HOW NON-CONFORMITY TO AN ACCREDITED HEALTH AND SAFETY STANDARD CAN BE USED AS A FORM OF ENFORCEMENT WITHIN A SELFREGULATORY MODEL In Element IA1 we discussed two safety management systems (SMSs) - the ILO guidelines ILO-OSH-2001 Guidelines on Occupational Health and Safety Management Systems and the OHSAS 18001 Occupational Health and Management Systems 2007. These can be used as a means of internal enforcement. All safety management models include the capacity for monitoring, audit and feedback, which leads to continuous improvement. Active monitoring and auditing should identify deficiencies in the system, that should be corrected. If the SMS is certified by an independent external body, then the organisation may lose its certification for repeated non-compliances and non-conformances revealed during an audit. An organisation needs to demonstrate a plan of continuous improvement that addresses such deficiencies. The threat of loss of certification will be a significant motivator in itself. To effectively implement such a system the following would need to be included: • Education and training of both workers and managers. • Documenting and monitoring of activities. • Procedures for investigations and deciding on corrective actions. • Good communication procedures. • Keeping up to date on legislation and other regulatory requirements. • Keeping a register of accidents and ill health. If a system is established that responds quickly to failures, there will be substantial improvements in standards. It is also necessary to include monitoring and auditing by trained personnel who may be internal or external to the organisation. Monitoring should in particular involve line managers who on a day-to-day basis deal with health and safety issues. 8-22 TOPIC FOCUS Non-conformity to an accredited health and safety standard can be used as a means of internal enforcement in the following ways: • Stakeholders may require conformity with an accredited health and safety standard and will expect significant change within the organisation if it fails to maintain the standard, and clients and business partners may not do business with the organisation unless the accreditation is maintained. • Insurance companies may require demonstration of a standard of performance in line with the requirements of the standard in order to provide cover and may withdraw cover of statutory insurance if there is non-compliance. • Third party audits will identify areas of noncompliance and require solutions to be put in place to maintain accreditation. • Threat of removal of accreditation and associated loss of business may help to improve standards. • Loss of reputation as a result of non-compliance may damage the image of the organisation. • Possibility of expulsion from associations or trade bodies as a result of the loss of accreditation will motivate compliance. • Non-compliance with a recognised system and the lack of credibility that may arise from this may serve to encourage compliance, particularly if business is affected. • Accrediting bodies have actions at their disposal, such as informal notification of failures, formal notification of non-conformance and even the withdrawal of accreditation, which can provide a strong inducement to comply with the standard. | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Role of Non-Governmental Bodies and Health and Safety Standards REVISION QUESTIONS 13. How do employers’ bodies influence health and safety practices and standards? 14. How do trade unions influence health and safety practices and standards? 15. Explain the ways in which the media, e.g. TV, Internet, etc. can influence health and safety. 16. What is meant by a “good neighbour scheme”? 17. Explain the meaning of the term “selfregulation”. 18. List the functions of the board of an organisation for the effective governance of health and safety. (Suggested Answers are at the end.) © RRC International Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-23 Summary SUMMARY This element has dealt with a range of topics related to the regulation of health and safety. Comparative Governmental and Socio-Legal and Corporate Regulatory Models In particular we have: • Explained the role of legislation as a means of promoting positive health and safety outcomes. • Examined the differences between ‘goal-setting’ and ‘prescriptive’ legal models. • Considered loss events as failures in the duty of care to protect individuals and examined the compensatory mechanisms that may be available to them, including no fault liability and fault liability claims. • Described the different mechanisms that may be used to enforce health and safety legislation. • Examined the laws of contract. Role and Limitations of the International Labour Organisation in a Global Health and Safety Setting We have: • Examined the role and status of ILO conventions, recommendations and codes of practice in relation to health and safety. • Noted Occupational Safety and Health Recommendation 1981 (R164) which sets out the roles and responsibilities of governments, enterprises and workers. • Noted how international conventions can be used as a basis for setting national systems of health and safety legislation. Role of Non-Governmental Bodies and Health and Safety Standards We have: • Considered influential parties, such as employer bodies, trade associations, trade unions, professional groups, pressure groups and the public who have a role in regulating health and safety performance. • Noted how the media can play an important role in communicating health and safety issues and can influence changes in attitudes to health and safety. • Considered the benefits of schemes which promote co-operation on health and safety between different companies. • Explained, with reference to actual examples, the possible effects on business of adverse stakeholder reaction to health or safety concerns. • Examined the origins and meaning of ‘self-regulation’. • Described the role and function of corporate governance in a system of self-regulation. • Considered how internal rules and procedures regulate health and safety performance. • Examined how non-conformity to an accredited health and safety standard can be used as a form of enforcement on a self-regulatory model. 8-24 | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Exam Skills QUESTION We will now move on to look at a law question. Questions relating to the legal aspects of health and safety can be off-putting because it is a topic that health and safety practitioners are least familiar with. However, if you plan your answer, you shouldn’t find it difficult to get good marks. Question Companies are subjected to many influences in health and safety. (a) In contract law, state what is meant by express terms. (2) (b) Outline how influential parties can affect health and safety performance in a company. (8) (c) Outline how non-conformity to an accredited health and safety standard such as BS OHSAS 18001 can be used as a form of enforcement in a self-regulatory model. APPROACHING THE QUESTION This is a long question but is reasonably well subdivided so it gives you a clear idea where the marks have been allocated. Part (a) asks you to simply state what is meant by “express terms”. Part (b) requires more detail and relates to section IA8.3 of the syllabus and the relevant influential parties that can affect health and safety performance. Part (c) examines another section of IA8.3 that is concerned with how non-conformity to an accredited health and safety standard can be used as a form of enforcement on a self-regulatory model. If you are familiar with this material from your course notes and the syllabus then the answer to the question should be straightforward. SUGGESTED ANSWER OUTLINE For part (a) the examiner expects a concise summary such as: Express terms are those specifically mentioned and agreed by all parties at the time the contract is made. They may take account of unusual circumstances but should not include unfair terms. For part (b) the parties that should be considered include: • Employer bodies - who may set performance standards for member organisations. • Trade associations - who may also set performance standards for members and may require self-regulation and compliance with accredited management systems. • Trade unions – whose representatives check workplace conditions and provide advice and guidance. • Professional groups – such as IOSH, who set professional standards of performance and provide advice and guidance. • Pressure groups – who can organise campaigns to generate bad publicity if necessary. © RRC International (10) • The public – who, as customers, can influence the success of an organisation by boycotting goods and services. • The ILO – who publish advice and guidance and enforce standards in conventions and recommendations. • Insurance companies – who can stipulate specific performance standards for insurance cover and may remove statutory cover for non-compliance. • The media – who may publicise incidents affecting the health and safety of workers and others. For part (c) the examiner is looking for an outline of how non-conformity with an accredited health and safety standard may be used as a form of enforcement in a selfregulatory model and candidates are expected to provide examples such as: • Stakeholders may require conformity with an accredited health and safety standard and will expect significant change within the organisation if it fails to maintain the standard. Also clients and business partners may not do business with the organisation, unless the accreditation is maintained. • Insurance companies may require demonstration of performance in line with the requirements of the standard as a condition of providing cover and may withdraw cover of statutory insurance if there is noncompliance. • Third party audits will identify areas of non-compliance and require solutions to be put in place to maintain accreditation. • Threat of removal of accreditation and associated loss of business may help to improve standards. • Loss of reputation as a result of non-compliance may damage the image of the organisation. Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-25 Exam Skills • Possibility of expulsion from associations or trade bodies as a result of the loss of accreditation will motivate compliance. • Non-compliance with a recognised system and the lack of credibility that may arise from this may serve to encourage compliance, particularly if business is affected. • Accrediting bodies have actions at their disposal, such as informal notification of failures, formal notification of non-conformance and even the withdrawal of accreditation which can provide a strong inducement to comply with the standard. 8-26 | Unit IA – Element IA8: Regulating Health and Safety © RRC International v2.1 Exam Skills POSSIBLE ANSWER BY EXAM CANDIDATE (a) Express terms in contract law refer to the specific details mentioned and agreed in the contract. They cover unusual circumstances, but shouldn’t include unfair terms. (b) Different groups can affect the H&S performance of a company; these can be by employers’ bodies, who can set standards to follow for its members, trade unions who influence their members and provide H&S advice, insurance companies who impose conditions of operation, design and management on companies, ILO who publish advice and guidance and enforcement of standards as well as the media who will publish information of company ethics and conditions to the local or national community. (c) Non-conformity can be used as a form of enforcement in a self-regulatory model by stakeholders who expect you to be accredited to a set scheme and may look at management sanctions against the management team for noncompliance. Loss of accreditation may mean loss of business as companies may require this to work with you; you may lose your licence to operate your business as non-compliance may mean the licence is revoked by the awarding authority, as well as the bad PR this can bring the company from the local and possibly national community. REASONS FOR POOR MARKS ACHIEVED BY CANDIDATES IN EXAM • Failing to provide a comprehensive list of influential parties. • Listing influential parties but not outlining how each of the parties is able to affect health and safety performance. • Not appreciating that non-conformity with an accredited health and safety standard and the threat of loss of accreditation will have an effect on business performance through the influences of some of the parties considered in part (b). © RRC International Unit IA – Element IA8: Regulating Health and Safety v2.1 | 8-27 v2.1 REVISION AND EXAMINATION THE LAST HURDLE Now that you have worked your way through the course material, this section will help you prepare for your NEBOSH examination. This guide contains useful advice on how to approach your revision and the exam itself. © RRC International Revision and Examination v2.1 |1 International Diploma Revision and Examination YOUR NEBOSH EXAMINATION You will need to successfully complete a three-hour examination for each of Units IA, IB and IC, as well as completing Unit ID, a workplace-based assignment, before you achieve the International Diploma. Your examination will consist of one exam paper which consists of two parts: • Section A has six 10-mark compulsory questions, designed to test your breadth of knowledge across the full range of elements in the syllabus. • Section B has five 20-mark questions, from which you must answer three. These are designed to test your depth of knowledge across the full range of elements in the syllabus. You are allowed three hours in which to complete the exam and are given ten minutes reading time before the exam begins. As a guide, you will need to achieve a minimum of 45% to pass the Unit IA, IB and IC exams, and 50% in the workplace-based assignment (Unit ID). When you have passed Unit IA you will then be issued with a Unit Certificate, showing a pass grade. REVISION TIPS Using the RRC Course Material You should read through all of your course materials once before beginning your revision in earnest. This first read through should be done slowly and carefully. Having completed this first revision reading of the course materials consider briefly reviewing all of it again to check that you understand all of the elements and the important principles that they contain. At this stage you are not trying to memorise information, but simply checking your understanding of the concepts. Make sure that you resolve any outstanding queries with your personal tutor. Remember that understanding the information and being able to remember and recall it are two different things. As you read the course material you should understand it; in the exam you have to be able to remember and recall it. To do this successfully most people have to go back over the material repeatedly. Re-read the course materials and make notes that summarise important information from each element. You could use index cards and create a portable, quick and easy revision aid. Once you have been awarded a Unit Certificate for all four Units (Units IA, IB, IC and ID), you will receive an overall grade as follows: Pass 185 to 239 marks Credit 240 to 279 marks Distinction 280 marks or more The overall mark is calculated by adding together your two Unit Percentage scores. Remember that your overall grade includes Unit ID, the workplace-based assignment. Although at this stage of your studies you are quite a way off being ready to attempt the assignment, be aware that you will need to apply what you have learned throughout your Unit studies when you write your assignment. 2 | Unit IA – Revision and Examination © RRC International v2.1 International Diploma Revision and Examination Using the Syllabus Guide We recommend that you purchase a copy of the Guide to the NEBOSH International Diploma in Occupational Health and Safety, which contains the syllabus for your course. If a topic is in the syllabus then it is possible that there will be an examination question on that topic. Map your level of knowledge and recall against the syllabus guide. Look at the Content listed for each Unit element in the syllabus guide. Ask yourself the following question: “If there is a question in the exam about that topic, could I answer it?” You can even score your current level of knowledge for each topic in each Element of the syllabus guide and then use your scores as an indication of your personal strengths and weaknesses. For example, if you scored yourself as 5 out of 5 for a specific topic in Element 1, then obviously you don’t have much work to do on that subject as you approach the exam. But if you scored yourself at 2 out of 5 for a topic in Element 3 then you have identified an area of weakness. Having identified your strengths and weaknesses in this way you can use this information to decide on the topic areas that you need to concentrate on as you revise for the exam. Another way of using the syllabus guide is as an active revision aid: • Pick a topic at random from any of the International Diploma elements. • Write down as many facts and ideas that you can recall that are relevant to that particular topic. © RRC International • Go back to your course materials and see what you missed, and fill in the missing areas. Your revision aim is to achieve a comprehensive understanding of the syllabus. Once you have this, you are in a position to say something on each of the topic areas and attempt any question set on the syllabus content. EXAM HINTS Success in the exam depends on averaging half marks, or more for each question. Marks are awarded for setting down ideas that are relevant to the question asked and demonstrating that you understand what you are talking about. If you have studied your course material thoroughly then this should not be a problem. One common mistake in answering questions is to go into too much detail on specific topics and fail to deal with the wider issues. If you only cover half the relevant issues, you can only achieve half the available marks. Try to give as wide an answer as you can, without stepping outside the subject matter of the question altogether. Make sure that you cover each issue in appropriate detail in order to demonstrate that you have the relevant knowledge. Giving relevant examples is a good way of doing this. We mentioned earlier the value of using the syllabus to plan your revision. Another useful way of combining syllabus study with examination practice is to create your own exam questions by adding one of the words you might find at the beginning of an exam question (such as ‘explain’ or ‘identify’ or ‘outline’) in front of the syllabus topic areas. In this way, you can produce a whole range of questions similar to those used in the exam. Unit IA – Revision and Examination v2.1 |3 International Diploma Revision and Examination BEFORE THE EXAM DURING THE EXAM You should: • Know where the exam is to take place. • Arrive in good time. • Bring your examination entry voucher, which includes your candidate number, photographic proof of identity, pens, pencils, ruler, etc. (Remember, these must be in a clear plastic bag or wallet.) • Bring water to drink and sweets to suck, if you want to. • Read through the whole exam paper before starting work, if that will help settle your nerves. Start with the question of your choice. • Manage your time. The exam is two hours long. You should attempt to answer all 11 questions in the two hours. To do this, you might spend: –– 25-30 minutes answering Question 1 (worth 20 marks), and then –– 8-9 minutes on each of the ten remaining 8-mark questions. Check the clock regularly as you write your answers. You should always know exactly where you are, with regard to time. • As you start each question read the question carefully. Pay particular attention to the wording of the question to make sure you understand what the examiner is looking for. Note the verbs (command words), such as ‘describe’, ‘explain’, ‘identify’, or ‘outline’ that are used in the question. These indicate the amount of depth and detail required in your answer. As a general guide: –– ‘Explain’ and ‘describe’ mean give an understanding of/a detailed account of something. –– ‘Outline’ means give the key features of something. –– ‘Identify’ means give a reference to something (could be name or title). • Pay close attention to the number of marks available for each question, or part of a question – this usually indicates how many key pieces of information the examiner expects to see in your answer. • Give examples wherever possible, based either on your own personal experience, or things you have read about. An example can be used to illustrate an idea and demonstrate that you understand what you are saying. • If you start to run out of time, write your answers in bullet-point or checklist style, rather than failing to answer a question at all. • Keep your handwriting under control; if the examiner cannot read what you have written, then he or she cannot mark it. • You will not be penalised for poor grammar or spelling, as long as your answers are clear and can be understood. However, you may lose marks if the examiner cannot make sense of the sentence that you have written. 4 | Unit IA – Revision and Examination © RRC International v2.1 SUGGESTED ANSWERS NO PEEKING! Once you have worked your way through the revision questions in this book, use the suggested answers on the following pages to find out where you went wrong (and what you got right), and as a resource to improve your knowledge and question-answering technique. © RRC International Unit IA – Suggested Answers v2.1 |1 Element IA1: Principles of Health and Safety Management Question 1 Question 4 Any five from the following list of uninsured costs: The health and safety policy usually comprises: • Product and material damage. • A statement of intent that sets out the aims and objectives of the organisation regarding health and safety. • Lost production time. • Legal costs in defending civil claims, prosecutions or enforcement action. • Overtime and other temporary labour costs to replace the injured worker. • An organisational structure that details the people with health and safety responsibilities and their duties. • Time spent investigating the accident and other administration costs (including supervisor’s time). • The systems and procedures in place to manage risks. Effective health and safety policies contribute to business performance by: • Fines from criminal prosecutions. • Supporting human resource development. • Loss of highly trained and/or experienced staff. • Minimising the financial losses which arise from avoidable unplanned events. • Effects on employee morale and the resulting reduction in productivity. • Bad publicity leading to loss of contracts and/or orders. Question 2 • Ensuring a systematic approach to the identification of risks and the allocation of resources to control them. • Supporting quality initiatives aimed at continuous improvement. Corporate social responsibility encompasses those voluntary actions that the business can take, over and above compliance with minimum legal requirements, to address both its own competitive interests and the interests of wider society. Businesses should consider their economic, social and environmental impacts, and act to address the key sustainable development challenges based on their core competencies wherever they operate. Question 3 (a) ILO–OSH-2001: • Policy. • Organising. • Planning and implementation. • Evaluation. • Action for improvement. (b) OHSAS 18001: • OH&S policy. • Planning. • Implementation and operation. • Checking and corrective action. • Management review. 2| Unit IA – Suggested Answers © RRC International v2.1 Element IA1: Principles of Health and Safety Management Question 5 Question 6 Arguments for integration: It may be necessary to liaise externally with: • Cost-effective. • Local officials. • Career opportunities for specialists. • Consultants/contractors. • Objectives and processes of management systems are the same. • Fire service. • Avoidance of duplication. • Enforcing authorities. • Should reduce the possibility of resolving problems at the expense of creating new difficulties in other disciplines. Question 7 • Momentum in one element of an IMS may drive forward other elements that might otherwise stagnate. • Owe a loyalty to the workforce, the community they serve and the environment they affect. • Positive culture in one discipline may be carried over to others. Arguments against integration: • Abide by relevant legal requirements. • Existing systems may work well already. • Not undertake tasks they do not believe themselves to be competent to carry out. • Specialists continue to concentrate on the area of their core expertise and further specialist training may not be needed. • Uncertainties regarding key terms may be made worse in an IMS. • System requirements may vary across topics covered. • Health, safety and environmental performance are underpinned by legislation and standards, but quality management system requirements are largely determined by customer specification. • Regulators and single-topic auditors may have difficulty evaluating their part of the IMS when it is interwoven with other parts of no concern to the evaluator. • A powerful, integrated team may reduce the ownership of the topics by line management. • Negative culture in one topic may unwittingly be carried over to others. • Insurance companies. Any five of the following: • Give honest opinions. • Maintain their competence. • Accept professional responsibility for their work. • Make those who ignore their professional advice aware of the consequences. • Not bring the professional body into disrepute. • Not recklessly or maliciously injure the professional reputation or business of another. • Not behave in a way which may be considered inappropriate. • Not improperly use their position within the organisation for commercial or personal gain. • Avoid conflicts of interest. • Not improperly disclose information. • Make information which they hold necessary to safeguard the health and safety of others available on request. • Comply with data protection principles and relevant legislation. • Maintain financial propriety with clients and employers and where appropriate be covered by professional indemnity insurance. © RRC International Unit IA – Suggested Answers v2.1 |3 Element IA2: Loss Causation and Incident Investigation Question 1 Question 6 The five factors of Heinrich’s accident sequence are: The basic requirements of P155 are that national governments should ensure that employers: • Ancestry and social environment - character traits. • Fault of person - inherited or acquired faults. • Unsafe act and/or mechanical or physical hazard. • Accident - event causing injury. • Injury - effect of accident. Question 2 Bird and Loftus extended Heinrich’s theory to include the influence of management in the cause and effect of accidents. They suggested a modified sequence of events: • Lack of control by management; • Permitting basic causes (i.e. personal and job factors); • Leading to immediate causes (such as substandard practices, conditions or errors); • Which are the direct cause of the accident; • Which result in loss (which may be categorised as negligible, minor, serious or catastrophic). Question 3 Latent failures are failures in the organisation or environment which remain dormant and are often either unrecognised or not appreciated until they lead to an active failure and a loss event. An example would be a lack of adequate training for a particular task. Only when a worker who undertakes the task commits an error due to the lack of training, does the failing become apparent. Question 4 Accident triangles show there is a ratio between unsafe acts, minor incidents and more serious ones. If employers aim to reduce the frequency of unsafe acts this will lead to a reduction in more serious outcomes. Question 5 Accident frequency rate: Number of work-related injuries × 100,000 Total number of man-hours worked Number of man-hours worked = 20 x 38 x 47 h = 35720h. Accident frequency rate = 8 x 100,000 = 22.4 35720 • Record and notify occupational accidents, suspected cases of occupational disease, dangerous occurrences and commuting accidents. The minimum notification data should comprise: –– Enterprise, establishment, employer. –– Person injured and nature of injury/disease. –– Workplace, circumstances (accident/dangerous occurrence/disease). • Inform employees about the recording system and notifications. • Maintain records and use them to help prevent recurrence. Question 7 Notifiable diseases to be reported should at least include the prescribed diseases listed under ILO Convention C121. The schedule to C121 contains a list of diseases prescribed in relation to an activity, for which injury benefit should be payable. Examples include: • Conditions due to physical agents and the physical demands of work, e.g. due to ionising radiation, vibration, noise. • Infectious or parasitic diseases (in health, vet work, etc.). • Conditions due to substances, e.g. silicosis, asbestosis; arsenic, chromium, lead poisoning; lung cancer and mesothelioma caused by asbestos. Question 8 Accident records should be used as a tool to help control the accidents that are causing the injuries and damage. Detailed and thorough study of the records as part of the normal on-going accident prevention programme should give the following useful information: • Relative importance of the various injury and damage sources. • Conditions, processes, machines and activities that cause the injuries/damage. • Extent of repetition of each type of injury or accident in each operation. • Accident repeaters, i.e. those workers who tend to be repeatedly injured or are involved in more accidents. • How to prevent similar accidents in the future. 4| Unit IA – Suggested Answers © RRC International v2.1 Element IA2: Loss Causation and Incident Investigation Question 9 There will always be an immediate cause for an accident, but we are also interested in finding the underlying and root causes, which is why we need to consider the chain of events leading up to an accident. The domino effect of Heinrich’s theory is a good example. Obviously any remedy which starts at the earliest stages will not only prevent this accident, but a lot of others which have the same root cause. Often, accident reports tend to concentrate on ‘cause of injury’, when the safety practitioner is more interested in ‘cause of accident’. In the case of a multiple cause accident, we do at the very least need to consider if it involves an unsafe act, an unsafe condition and an unsafe person, and how these interact. Question 10 There are a number of items which will be required for an investigation, including the following: • Photographic equipment. • Portable lights which may be necessary as electricity may be switched off, or the accident scene may be in a poorly lit area in a confined space, such as a manhole. • Sketchpad, pencils and measuring equipment. • Record-keeping equipment, which should include a notebook and possibly recording equipment. • Sample collection equipment, such as jars or other containers that can be sealed to prevent loss, evaporation or contamination. Paper bags, plastic bags, envelopes and cartons may also be required. • Tools for cleaning debris or spillages. • Where explosive or flammable vapours and gases are liable to be involved, some sort of portable gas/vapour detection equipment should be available. Similarly, where poisonous or radioactive materials may be involved, the appropriate detection equipment should be provided. Question 11 Following the UK’s HSG245, accident investigation can follow four complementary steps: • Step 1: Gathering the information. • Step 2: Analysing the information. • Step 3: Identifying risk control measures. • Step 4: The action plan and its implementation. © RRC International Unit IA – Suggested Answers v2.1 |5 Element IA3: Measuring and Reviewing Health and Safety Performance Question 1 Question 6 Any three from the following: Benchmarking is the process of comparing your own practices and performance measures with organisations that display excellence and whom you might wish to emulate. • To assess the effectiveness and appropriateness of health and safety objectives and arrangements in terms of: –– Hardware (plant, premises, substances). –– Software (people, procedures, systems). • To measure and reward success (not to penalise failure). Question 7 The two sources of information that the review process uses are routine monitoring data and audit data. • To use the results as a basis for making recommendations for a review of current management systems. • To maintain and improve health and safety performance. Question 2 Active measures include inspection reports, safety tour reports, audit data. Reactive measures include accident and ill-health data, complaints, near misses. Objective measures include number of prosecutions over the last five years, number of risk assessments completed/ reviewed during last year, number of individuals trained in a specific safety-related course. Subjective measures include effectiveness of safety communication, presence of a good safety culture. Question 3 Limitations of accident and ill-health data: • Numbers tend to be small and so variations year to year may not be significant. • Data, especially relating to ill health, may reflect working conditions from at least several years previously. • Under-reporting - incidents to which the consequences may not be immediately obvious may not get reported, or reporting may be implicitly discouraged to demonstrate an apparent good performance. Question 4 The main measurement techniques available for measuring health and safety performance in the workplace are: audits, inspections, safety tours, safety sampling and safety surveys. Question 5 An internal audit is conducted by personnel who work for the organisation; an external audit is carried out by a person(s), independent of the organisation, who has no vested interest in the outcome and can therefore be seen to be more objective. 6| Unit IA – Suggested Answers © RRC International v2.1 Element IA4: Identifying Hazards, Assessing and Evaluating Risks Question 1 Question 5 Accident and ill-health data may be used to: Characteristics of a “suitable and sufficient” risk assessment: • Classify industries according to risk. • It should identify the significant risks arising from or in connection with the work. • Classify workplaces. • Classify occupations. • Consider accident trends. • Consider parts of the body injured - use of protective clothing. • Determine hazards in a workplace by using ‘cause of injury’. • Consider where the fault lies. • Measure the effect of preventative/control measures. Question 2 Useful internal information sources when assessing risk include: • Accident and ill-health reports. • The detail in the assessment should be proportionate to the risk. • Whenever specialist advisers are used, employers should ensure that the advisers have sufficient understanding of the particular work activity they are advising on; this will often require the effective involvement of everyone concerned. • Risk assessments should consider all those who might be affected by the activities, whether they are workers or others, such as members of the public. • The risk assessment should indicate the period of time for which it is likely to be valid. Question 6 • Absence records. • Maintenance records, which usually show damage incidents. Question 3 A “tolerable risk” means that we, as a society, are prepared to endure it because of the benefits and that further risk reduction is grossly out of proportion in terms of time, cost, etc. Incidence indicates the number of new cases in a population in relation to the number at risk, whereas prevalence indicates the proportion of persons in a given population who have a defined (usually ill health) condition. Question 4 The “4Ps” include: • Premises, including: –– Access/escape. –– Housekeeping. –– Working environment. • Plant and substances, including: –– Machinery guarding. –– Local exhaust ventilation. –– Use/storage/separation of materials/chemicals. • Procedures, including: –– Permits-to-work. –– Use of personal protective equipment. –– Procedures followed. • People, including: –– Health surveillance. –– People’s behaviour. –– Appropriate authorised person. © RRC International Unit IA – Suggested Answers v2.1 |7 Element IA4: Identifying Hazards, Assessing and Evaluating Risks Question 7 The starting point is to logically construct an event tree which begins with pipework failure (f = 0.01/year). It should look something like this (notice how it is possible to simplify the figure by ‘pruning’ branches that would not change the outcome): Following the failure of the pipework there are two possibilities which will result in an explosion. Firstly, the released gas will immediately ignite (probability, p = 0.05) resulting in a jet flame on site. The frequency of this occurrence is calculated simply: 0.01/year x 0.05 = 0.0005/year. Alternatively this can be expressed as one event in 2000 years (calculated from 1/0.0005). This gives the answer to the first part of the question. Notice that for this option (ignition on site), the factors of the wind and the industrial estate have no impact; they will not change the result. So, there is no point in further branching of this branch (see figure). The other option is that the gas does not immediately ignite but drifts off site. If the probability of immediate ignition is 0.05, then the probability of non-ignition and drifting off site must be 0.95 (remember the probability at each node adds up to 1). In most cases the gas disperses safely but there is a one in ten chance (p = 0.1) that it will drift to a nearby industrial estate. Finally, having drifted onto the industrial estate, there is an even chance (p = 0.5) that a source of ignition will cause a vapour cloud explosion or flash fire. Following through this event path on the figure, the frequency of this event occurring is calculated as: 0.01/year x 0.95 x 0.1 x 0.5 = 0.000475/year. This can, alternatively, be expressed as one event every 2105 years (approximately). 8| Question 8 Hazard and operability studies are designed for dealing with complex systems, e.g. a large chemical plant. They are carried out by a multidisciplinary team that makes a critical examination of a process to discover any potential hazards and operability problems. A series of guide words are applied to each part of the system to identify the possible consequences of a failure. Question 9 A fault tree identifies the sub-events that are necessary to cause a specified undesired event such as an accident. Logic gates are used to show how the sub-events combine together to cause the undesired event. An event tree is used to identify the possible outcomes following an undesired event. Both techniques may be used qualitatively and, if suitable data is available, quantitatively. Unit IA – Suggested Answers © RRC International v2.1 Element IA5: Risk Control Question 1 The main risk management strategies are: • Avoidance or elimination. • Reduction. • Risk retention – with or without knowledge. • Risk transfer. • Risk sharing. Question 2 The factors to be taken into account when choosing control measures are: • Long/short term. • Applicability. • Costs. • Effectiveness. • Legal requirements/standards. • Competence and training requirements. Question 3 Three reasons why cost-benefit analysis is not as simple as adding up all the benefits of a health and safety programme and subtracting the costs are: • Not all costs and benefits can be accurately estimated. • Benefits may not be seen immediately. • Some costs and benefits are one-off and others are recurring. Question 4 Risk assessment may be used to develop a safe system of work through: • Analysing the task – identifying the hazards and assessing the risks. • Introducing controls and formulating procedures. • Instructing and training people in the operation of the system. • Monitoring and reviewing the system. Question 5 A permit to work is a formal written document of authority to undertake a specific procedure and is designed to protect personnel working in hazardous areas or activities. © RRC International Unit IA – Suggested Answers v2.1 |9 Element IA6: Organisational Factors Question 1 Question 5 Internal influences include financial status, production targets, trades unions, and organisational goals and safety culture. There are two main economic implications: Question 2 External influences include the bodies that are involved in framing legislation and those agencies responsible for its enforcement. Other organisations that may exert an influence on health and safety in the workplace include the courts through their decisions, trade unions by promoting the health and safety of their members, insurance companies by influencing company control measures, professional organisations and various pressure and campaign groups. Public opinion also has a significant influence. • Accidents resulting from poor health and safety management result in huge financial losses to everyone concerned. Poor health and safety management is often itself caused by a lack of economic resources available for health and safety purposes both at national and workplace levels. • It is not difficult to compare the costs of preventing accidents with the costs arising from them (compensation, lost production, increased insurance premiums, overtime, legal fees, fines, etc.). Prevention of accidents and ill-health is an investment which attracts enormous dividends both for the individual employer and the national economy as a whole. Question 3 Question 6 The formal structure is represented by the company organisation chart, the distribution of legitimate authority, written management rules and procedures, job descriptions, etc. The informal structure is represented by individual and group behaviour. The main role of representatives on health and safety is to work actively to prevent worker exposure to occupational hazards. Typical activities include: • Workplace observations and inspections. • Examination of records. Question 4 • Listening to complaints. The legal reasons for ensuring that third parties are covered by health and safety management systems are that ILO Occupational Safety and Health Convention C155 (Article 17) and accompanying Recommendation R164 (Article 11) state: • Reading information. “Whenever two or more undertakings engage in activities simultaneously at one workplace, they should collaborate in applying the provisions regarding occupational safety and health and the working environment, without prejudice to the responsibility of each undertaking for the health and safety of its employees. In appropriate cases, the competent authority or authorities should prescribe general procedures for this collaboration.” Copyright © International Labour Organisation 1981 So, both of these imply that account is taken of third parties who happen to be working on the same premises. This invariably will involve the exchange of information (on hazards, etc.) as well as the co-ordination of emergency arrangements and sharing of procedures. • Asking those that they represent what their views are. Question 7 Typical activities of these committees would include: • Promoting health and safety in the workplace (including providing training). • Monitoring the workplace for hazards and legal compliance (including inspections). • Agreeing the health and safety policy and its implementation. • Working with management to resolve health and safety problems/complaints. • Involvement in planning proposed changes that may impact on health and safety. • Keeping union members informed about planned actions. Question 8 A safety circle is a small group of workers - not safety representatives or members of safety committees - who meet informally to discuss safety problems in their immediate working environment. The idea is based on the ‘quality circles’ concept and allows the sharing of ideas and the suggestion of solutions. Any insurmountable problem would be referred to the safety representative or safety committee. 10 | Unit IA – Suggested Answers © RRC International v2.1 Element IA6: Organisational Factors Question 9 Question 14 Positive consultation involves the willingness on both sides - employer and worker - to consider problems together, to make use of each other’s knowledge and expertise, and to apply that collective wisdom to the problem in hand. The most common way to assess safety climate is by using a tool which includes a questionnaire survey asking workers the extent to which they agree or disagree with a number of statements which reflect the management of health and safety. Question 10 Question 15 • Workers. Management commitment can be demonstrated by (three from): • Temporary workers. • Contractors. • Managers being seen and involved with the work and correcting health and safety deficiencies. • Customers. • Suppliers. • Providing resources to carry out jobs safely. • Enforcement authorities. • Ensuring that all personnel are competent. • Employment agencies. • Members of the public. • Enforcing the company safety rules, and complying with them personally. Question 11 • Managers matching their actions to their words. External sources of health and safety information include: Question 16 • Legislation, codes of practice and guidance. A positive health and safety culture is characterised by: • National and international Standards. • Management commitment and leadership. • Manufacturers’ instructions. • High business profile to health and safety. • Guidance from safety and professional bodies, e.g. ILO, WHO, IOSH. • Provision of information. • Guidance from industrial bodies. • Involvement and consultation. • Training. Question 12 • Promotion of ownership. Internal sources of health and safety information include: • Setting and meeting targets. • Health and safety policy document. Question 17 • Compliance data. The following are needed to effect cultural change: • Cost data. • Good planning and communication. • Risk assessments. • Monitoring results – noise, dust, lighting, atmospheric, etc. • Job descriptions. • Strong leadership. • A step-by-step approach. • Action to promote change. • Strong worker engagement. • Job safety analyses. • Ownership at all levels. • Results of inspections/audits. • Training and performance measurements. • Accident and ill-health reports/statistics. • Feedback. • Training records. • Management system performance data. Question 13 A definition should centre on a description of the attitudes, values and beliefs which members of an organisation hold in relation to health and safety, and which, when taken together, produce an organisational culture that can be positive or negative. © RRC International Unit IA – Suggested Answers v2.1 | 11 Element IA7: Human Factors Question 1 • Psychology - a study of the human personality. • Sociology - a study of the history and nature of human society. Question 2 Maslow’s hierarchy of needs Question 3 Question 5 The three levels of behaviour in Rasmussen’s model are: Perceptual set: sometimes called a ‘mindset’. We have a problem and immediately we perceive not only the problem, but the answer. We then set about solving the problem as we have perceived it. Further evidence may become available, which shows that our original perception was faulty, but we fail to see alternative causes and solutions. This is a basic cause or factor in many accidents and disasters. • Skill-based - the person carries out the operation in automatic mode. Errors occur if there are problems such as machine variation or environmental changes. • Rule-based - the operator is multi-skilled and has a wide selection of well-tried routines which can be used. Errors occur if the wrong alternative is selected or if there is some error in remembering or performing a routine. • Knowledge-based - a person copes with an unknown situation where there are no tried rules or routines. Trial and error is the only method. Question 4 Human sensory receptors react to danger in the following ways: • Sight - observation of a warning sign. • Hearing - sound of an audible alarm. • Taste - recognition of a toxic substance in food. • Smell - identification of a hazardous gas release. • Touch - identification of a hot surface. Perceptual distortion: the perception of a hazard may be faulty because it gets distorted. Things which are to our advantage always tend to seem more right than those which are to our disadvantage. Management generally tend to have a different perception of hazard from that of workers, and when it affects work rates, physical effort or bonus payments, the worker also suffers from perceptual distortion. Question 6 Human error which contributed to the incident included: • Operators under considerable stress – they had incorrectly diagnosed the problem and stuck to their course of action although the evidence was apparently to the contrary. • Operator training was inadequate. 12 | Unit IA – Suggested Answers © RRC International v2.1 Element IA7: Human Factors Question 7 Question 10 Ways that employees could be motivated: Shift work can be very demanding on an individual and can affect their performance in the following ways: • Workplace incentive schemes: encourage employees to work harder in order to receive a payment or benefit. • Reward schemes: offer a reward for improvement or reaching a target in a particular area. • Job satisfaction: some people only require job satisfaction to be motivated. Job satisfaction is very individual to each person. • Appraisal schemes: a formal means of placing value on achievement or effort. It is generally carried out on an annual basis and the results may be used to determine the level of a pay rise or a promotion. Question 8 Formal groups are established to achieve set goals, aims and objectives. They have clearly defined rules, structures and channels of communication. Informal groups superimpose on the organisation an informal structure of communication links and functional working groups. These cross all the barriers of management status and can be based on family relationships, out-of-work activities, experience or expertise. Question 9 Peer group pressure can influence behaviour at work in the following ways: • Group formation - people tend to join groups with those of a similar outlook. A lot of work situations involve group work or committees and discussion groups. • Group reaction - the group tends to create its own rules and arrangements, particularly in large groups, which may be dominated by a few members. In smaller groups people tend to be more able to have an input into the group’s actions. • Group development - groups develop ‘pecking orders’ in terms of the amount of speech and influence permitted. Dominant individuals struggle for status and an order develops. • Fatigue and stress - poorer performance on tasks requiring attention, decision-making or high levels of skill. • Sleep loss and sleep debt - lower levels of alertness, and reduced levels of productivity and attention. • Health problems - asthma, allergic reactions and respiratory problems tend to be worse at night, and so it is likely that performance will be affected where an individual’s health is affected. • Social life/family life - work performance may be affected if the individual is unhappy at home due to the constraints of shift work. • Natural circadian rhythm - when working nights, the body still reduces body temperature in the early hours of the morning, reduces blood pressure and stops digestion which can lead to an individual feeling sleepy and less alert. Question 11 There are various methods of payment for work and terms of employment, and these may all affect performance in different ways: • Piecemeal workers - need to work quickly because they are paid by the amount of work they do; speed is important, but safety is also an issue, because if they injure themselves they won’t be able to work and will not get paid. • Permanent contract employees - get paid whether they are at work or sick (in general), so safety or performance may not be an incentive for them. There may, however, be incentive schemes in place which reward good performance, safe working and/or good attendance, and these may affect an individual’s performance. • Short-term contract workers - generally need to perform well in order for their contract to be renewed (unless there is a shortage of workers). This means that there is pressure on the individual to perform to their best ability. • Group control - the group will establish standards of acceptable behaviour or group ‘norms’, detect deviations from this standard and have the power to demand conformity. © RRC International Unit IA – Suggested Answers v2.1 | 13 Element IA7: Human Factors Question 12 Ergonomics is the study of the relationship between workers and their environment, ensuring a good ‘fit’ between people and the things they use. Essentially it involves “fitting the task to the man” rather than “fitting the man to the task”. The order of operations and work practices can be modified so that each person is working to full efficiency. Poorly designed work equipment and unsafe practices may result in injury and occupational illhealth. These may include: • Equipment not suited to body size. • Operator not able to readily see and hear all that they need to. • Lack of understanding of the information that is presented to the employee. • Equipment or system causing discomfort if used for any length of time. Question 13 The following features are present in an ergonomicallydesigned crane cab control system: • The controls are within easy reach of the driver and are moved in a straight line to allow ease and delicacy of control. • The seat is adjustable so that the driver has a good view of the operations. • The environment of the cab protects the driver from dust and fumes, etc. Question 14 The steps of a behavioural change programme relating to safety are: Step 1: Identify the specific observable behaviour that needs changing, e.g. to increase the wearing of hearing protectors in a high noise environment. Step 2: Measure the level of the desired behaviour by observation. Step 3: Identify the cues (or triggers) that cause the behaviour and the consequences (or pay offs) (good and bad) that may result from the behaviour. Step 4: Train workers to observe and record the safety critical behaviour. Step 5: Praise/reward safe behaviour and challenge unsafe behaviour. Step 6: Feedback safe/unsafe behaviour levels regularly to workforce. 14 | Unit IA – Suggested Answers © RRC International v2.1 Element IA8: Regulating Health and Safety Question 1 Question 4 There is little incentive to go beyond minimum legal requirements. The government has to employ enforcement officers and introduce sanctions which may be imposed by the courts. The two categories are special and general damages. Question 2 • Loss of earnings due to the accident or ill health before the trial. Prescriptive legislation has clearly defined requirements which are more easily understood by the dutyholder and enforced by the regulator. It does not need a higher level of expertise to understand what action is required, and provides a uniform standard to be met by all dutyholders. However, it is inflexible and so depending on the circumstances may lead to an excessively high or low standard. In addition, it does not take account of the circumstances of the dutyholder and may require frequent revision to allow for advances in knowledge and technology. Goal-setting legislation allows more flexibility in compliance because it is related to the actual risk present in the individual workplace. It is less likely to need frequent revision and can apply to a much wider range of workplaces. It is, however, much more difficult to enforce because what is “adequate” or “reasonably practicable” are much more subjective and so open to argument, possibly requiring the intervention of a court to provide a judicial interpretation. Dutyholders will also need a higher level of competence in order to interpret such requirements. Question 3 Employers’ and government schemes. In employer schemes, employers pay premiums to insurance companies who pay compensation to the injured worker. In government schemes the government or a government agency provides the benefits. © RRC International Special damages can be relatively easily quantified because they relate to known expenditure up until the trial. They include: • Legal costs. • Medical costs to date. • Building costs, if property has had to be adapted to meet the needs of the injured person. • Necessary travel costs associated with the case. General damages include future expenditure and issues which cannot be precisely quantified. They include: • Loss of future earnings as a result of the incapacity. • Future medical costs. • Pain and suffering before and after the trial. • Loss of quality of life, e.g. loss of mobility, inability to engage in sports which had been pursued before the loss. • Loss of future opportunity, e.g. reduced likelihood of being able to secure suitable employment. Question 5 Punitive damages are awarded to punish and deter the defendant and other similar persons from such conduct that harmed the claimant. They are awarded by reference to the defendant’s behaviour and aim to deter similar conduct in the future and to signify disapproval. Question 6 Corporate probation is a supervision order imposed by the court on a company that has been convicted of a criminal offence. The order requires the directors and senior managers to alter the way occupational health and safety is managed so that the likelihood of similar accidents or ill-health occurring is reduced. This might, for example, require the company to introduce new procedures or ensure workers are fully trained. The court might decide to suspend part of the fine so that if the company met the requirements of the order then that part would not have to be paid. However, if the company fails to comply with the terms of the order, not only could the suspended sentence be invoked but further penalties could also be imposed. Unit IA – Suggested Answers v2.1 | 15 Element IA8: Regulating Health and Safety Question 7 Question 11 Its main aims are to promote rights at work, encourage decent employment opportunities including good health and safety standards, enhance social protection and strengthen dialogue in handling work-related issues. Roles and responsibilities of enterprises: Question 8 A convention is an agreement in international law which has to be ratified by member countries. A recommendation, as the name suggests, does not require ratification by member states. Question 9 ILO codes of practice contain practical recommendations intended for all those with a responsibility for occupational safety and health in both the public and private sectors. Codes of practice are not legally binding instruments and are not intended to replace the provisions of national laws or regulations, or accepted standards. Question 10 Roles and responsibilities of national governments: “(a) issue or approve regulations, codes of practice..... on occupational safety and health and the working environment, account being taken of the links ... between safety and health, ... and hours of work and rest breaks ...; (b) .... review legislative enactments concerning occupational safety and health and the working environment,... in the light of experience and advances in science and technology; (c) undertake or promote studies and research to identify hazards and find means of overcoming them; (d) provide information and advice, in an appropriate manner, to employers and workers and promote or facilitate co-operation between them and their organisations, with a view to eliminating hazards or reducing them as far as practicable; where appropriate, a special training programme for migrant workers in their mother tongue should be provided; (e) provide specific measures to prevent catastrophes, and to co-ordinate and make coherent the actions to be taken at different levels, particularly in industrial zones where undertakings with high potential risks for workers and the surrounding population are situated; (f) secure good liaison with the International Labour Occupational Safety and Health Hazard Alert System set up within the framework of the International Labour Organisation; (g) provide appropriate measures for handicapped workers.” “(a) to provide and maintain workplaces, machinery and equipment, and use work methods, which are as safe and without risk to health as is reasonably practicable; (b) to give necessary instructions and training, taking account of the functions and capacities of different categories of workers; (c) to provide adequate supervision of work, of work practices and of application and use of occupational safety and health measures; (d) to institute organisational arrangements regarding occupational safety and health and the working environment adapted to the size of the undertaking and the nature of its activities; (e) to provide, without any cost to the worker, adequate personal protective clothing and equipment which are reasonably necessary when hazards cannot be otherwise prevented or controlled; (f) to ensure that work organisation, particularly with respect to hours of work and rest breaks, does not adversely affect occupational safety and health; (g) to take all reasonably practicable measures with a view to eliminating excessive physical and mental fatigue; (h) to undertake studies and research or otherwise keep abreast of the scientific and technical knowledge necessary to comply with the foregoing clauses.” Copyright © International Labour Organisation 1981 Copyright © International Labour Organisation 1981 16 | Unit IA – Suggested Answers © RRC International v2.1 Element IA8: Regulating Health and Safety Question 12 Question 15 Roles and responsibilities of workers: The media can influence health and safety by: “(a) take reasonable care for their own safety and that of other persons who may be affected by their acts or omissions at work; (b) comply with instructions given for their own safety and health and those of others and with safety and health procedures; (c) use safety devices and protective equipment correctly and do not render them inoperative; (d) report forthwith to their immediate supervisor any situation which they have reason to believe could present a hazard and which they cannot themselves correct; (e) report any accident or injury to health which arises in the course of or in connection with work. Copyright © International Labour Organisation 1981 Question 13 These bodies represent the interests of employers. In the UK the main body is the Confederation of British Industry (CBI). The CBI helps create and sustain the conditions in which businesses in the United Kingdom can compete and prosper for the benefit of all. The CBI is the main lobbying organisation for UK business on national and international issues, including health and safety practices and standards. Question 14 A trades union is an organisation of workers who have formed together to achieve common goals in key areas such as wages, hours, and working conditions. The trade union negotiates with the employer on behalf of its members. This may include the negotiation of workplace safety and health issues and policies. In the UK, unions may appoint safety representatives from amongst the workers who may investigate accidents, conduct inspections and sit on a safety committee. • Making health and safety guidance easily accessible with minimal cost. Agencies such as OSHA (USA) and the HSE (UK) produce guidance for all categories of dutyholders in all types of employment. This is available in hard copy and more commonly in electronic format that can be downloaded. This allows dutyholders who have limited expertise to access relevant information and so comply with legal requirements. • Publicising good and bad health and safety performance, e.g. TV and radio may publicise major accidents, prosecutions and public inquiries. Major disasters may be publicly discussed not only in the country in which they occurred but internationally, e.g. the Chernobyl disaster. Incidents with lesser consequences may be publicised within the area in which they occurred. Such publicity increases the awareness of occupational health and safety issues and reminds dutyholders of the possible consequences of failing to pay attention to these issues. • Assisting in educating members of the professional body and promoting good health and safety standards by publishing professional journals (e.g. Institution of Occupational Safety and Health (UK)). • Enabling anyone with an Internet connection access to a huge range of information (good and bad) which would otherwise be much less accessible. Question 16 In the UK a number of good neighbour schemes have been established to encourage larger organisations to help smaller businesses and contractors with health and safety expertise. Small businesses do not have access to the same health and safety expertise, so if a large organisation can provide advice to a smaller one, then the smaller business will benefit and the larger organisation will be able to demonstrate its public responsibility. Schemes have also been established between organisations of similar size. They might involve sharing expertise and equipment such as a noise meter. It is much less costly to share such resources and all members of the scheme will benefit. © RRC International Unit IA – Suggested Answers v2.1 | 17 Element IA8: Regulating Health and Safety Question 17 Self regulation is the process whereby an organisation monitors its own adherence to health and safety standards, rather than having an outside agency, such as a governmental body, monitoring and enforcing them. The benefit to the organisation is that it can set and maintain its own standards without external interference. Accordingly if problems arise, it can more easily keep its own internal affairs private. It also avoids the significant national expense of establishing an enforcement agency. Self regulation of health and safety within a legal framework was one of the recommendations of the Robens Committee which was established in 1970 in the UK to “review the provision made for the safety and health of persons in the course of their employment and to consider whether any changes are needed”. Question 18 The functions of the board of an organisation which ensure the effective governance of health and safety include: • A demonstration of commitment to occupational health and safety and an appreciation that it is as important as other business objectives. • Ensuring that health and safety is reviewed at board level. • Those in the organisation at all levels have access to and receive competent advice. • All staff including board members are trained and competent in their health and safety responsibilities. • Ensuring that the workforce, and in particular health and safety representatives, are adequately consulted and that their concerns reach the right level within the organisation including, where necessary, the board. • Systems are in place to ensure that health and safety risks are assessed and suitable control measures introduced and maintained. • An awareness of what activities take place in the organisation, including those of contractors. • Ensuring that regular information is received regarding matters such as accident reports and cases of workrelated ill health. • The setting of targets which allow the organisation to improve standards and to benchmark the organisation’s performance against others within the same business sector. • Ensuring that changes in working arrangements that have significant implications are brought to the attention of the board. 18 | Unit IA – Suggested Answers © RRC International v2.1