WATER UTILITIES CORPORATION
STRATEGY DOCUMENT ON THE IMPLEMENTATION OF
SAFETY HEALTH AND ENVIRONMENT IN THE
WATER UTILITIES CORPORATION
________________________________________________
TABLE OF CONTENTS:
Table of Contents
2
List of Tables
3
List of Figures
3
Appendices
3
1.0
Introduction
4
2.0
Background
5
3.0
Existing Policies and Implementation Tools
3.1 WUC’s Policy on SHE
3.1.2 PPS on SHE
3.1.3 Staff Regulations on Occupational SHE
3.1.4 Standards and Safe Working Procedures
3.1.5 NOSA integrated Five Star System
3.1.6 Work Place Risk Assessment
3.1.7 Strategy on Disaster Preparedness and Management
3.1.8 PPS on PPE
3.1.9 Dams Safety Inspections
4.0
5.0
7
7
7
7
8
8
9
11
11
11
3.2
WUC’s Policy on Environmental Management
3.2.1 Environmental Impact Assessment (EIA)
3.2.2 Water Conservation
3.2.3 Amenity Development of Dams
3.2.4 Environmental Protection and Pollution Control
3.2.5 Sludge Management
3.2.6 Dams Management Master Plan
11
11
11
12
12
13
13
3.3
Legislation and Policies on Occupational Health, Safety, and Environment
3.3.1 Factories Act 1979
3.3.2 Public Health Act
3.3.3 Occupational Health and Safety Act
3.3.4 Smoking Control Act
3.3.5 National Conservation Act
3.3.6 Waste management Act
13
13
14
14
14
14
16
SHE Implementation Structures
16
4.1
4.2
4.3
16
18
18
18
18
18
SHE Structures
Legal Appointments
SHE Committees
4.3.1 Executive SHE Committee
4.3.2 Area SHE Committees
4.3.3 Dam Amenities Committee
Review of the SHE Implementation Process
18
5.1
5.2
5.3
5.4
5.5
18
19
20
23
25
Positive Trends
Negative Trends/Challenges
Publicity Strategy
SHE Implementation Training Requirements
Revised SHE Structures
LIST OF TABLES
Table 1:
Table 2:
Table 3:
Awareness Campaign Action plan
Training Plan
SHE Action Plan
22
23
24
2
LIST OF FIGURES
Figure 1:
Figure 2:
Figure 3:
WUC SHE Organisation
Executive SHE Committee
Area SHE Committees
26
27
28
APPENDICES
Appendix 1
Appendix 2
Appendix 3
Appendix 4
Appendix 5
Workplace Risk Assessment
Disaster Management Strategy
SHE Policy and Procedure Statement
PPE Policy and Procedure Statement
Dams Management Master Plan
3
1.0
INTRODUCTION
The Water Utilities Corporation’s interest in the area of occupational health, safety an
environment has grown and developed over the years. The growing importance of
issues of occupational health, safety and environment has indeed prompted the
Corporation to embrace the challenges of implementing occupational health, safety
and environmental protection programmes.
The Safety, Health and Environment (SHE) concept is relatively a recent phenomenon
in Botswana’s industrial organisations and as such the Corporation’s as well as
employee interest in safety, health and environment in the context of the SHE initiative
is expected to grow subject to efforts to sensitise and educate same. Water Utilities
Corporation like other few companies in Botswana has accepted the challenge of
implementing SHE programmes in the workplace, as well as the sustainable
environmental management of its resources.
In the recognition of the need to keep abreast of changes in the issues regarding SHE,
processes, technology and legislation that may in one way or the other affect
employee welfare and the environment, the Water Utilities Corporation has committed
itself to;
(i)
providing a safe and comfortable workplace for all its employees in accordance
with the established Occupational Health and Safety standards
(ii)
cultivate a culture of appreciation for and compliance with the said standards,
through organised educational campaigns
(iii)
promote efficiency and reduce losses by continuously improving employee
awareness of their health and safety to promote productivity
(iv)
environmental conservation and sustainable development of water resources,
and shall demonstrate such commitment by developing and implementing a
sound environmental management programme
Although a comprehensive policy and procedure statement, which was first formulated in
1997, has yet to be finalised, an abridged version of the Safety, Health and Environment
Policy, which makes a declaration of Management’s commitment and calls for personal duty
responsibility to the safety of employees, protection and conservation of the environment, and
the elimination of all occupational health hazards, is in force.
The success of this endeavour is expected to result in improved efficiency, high productivity,
improved employee welfare, low labour disputes, low staff turnover and absenteeism, and
reduced compensation costs, high eco-efficiency and sustainable development of resources,
to mention just but a few.
Through the Occupational Health and Safety Act (OHSAct) of South Africa, the National
Occupational Safety Association (NOSA) has provided guidelines for companies and
4
organisations to formulate rules, regulations, policies and procedures governing them on
occupational health, safety and environmental management. As a result of affiliation to
NOSA, most companies such as WUC have had to adopt and change along the binding
clause of this foreign act for compliance with the requirements of this independent and global
association.
As earlier indicated the Water Utilities Corporation has committed resources to in pursuant of
meeting the challenges of sustaining high standards for safety in the workplace and
environmental protection.
In this regard, Safety, Health and Environment (SHE) Committees were established to coordinate safety and environmental upkeep in all the WUC areas of operation. These
committees constitute of safety representatives, union and management representatives and
a fair representation of all sections and or departments, in accordance with the NOSA
requirements.
Furthermore, following the first NOSA audit, it was recommended that a committee, now
referred to as the Executive SHE Committee be established to oversee, co-ordinate the
implementation of the SHE programme, and the upkeep of standard procedures in all areas
of operation for the whole Corporation on behalf of management as required by NOSA
element 5.13.
Recently management realised that the co-ordination of implementation of SHE through a
committee was not ideal, and as such decided to establish a section to deal with this aspect
whilst the Executive Committee’s role remains that of formulating and administering policies
and advising on the implementation of a standardised programme.
Of recent the NOSA Five Star System was upgraded to the new NOSA Integrated Five Star
System, which will provide a generic world class Occupational Safety, Health and
Environment risk management. As a result of this and in addition to the resuscitation of the
almost defunct SHE establishment, which resulted in audits not being conducted in the past
three years or so, the Corporation decided to forego this year's audit and schedule it for next
year.
The NOSA audits are an annual event. Other milestones include the formulation of SHE
incentives, which never really got off the ground, and the enhancement of the spirit of interarea competitions through such initiatives such as Safety Days, in order to encourage
employees’ involvement and commitment to the SHE programme. However these initiatives
have to be resuscitated if any impact of educational campaigns has to be realised.
2.0
BACKGROUND
The Water Utilities Corporation first adopted the concept of and undertook to
implement SHE in the early 90’s. The primary object was not only that of meeting the
growing legislative requirements, but to enhance the spirit of occupational health and
safety on employees in general. In this regard the pioneers of this initiative was the
then Operations Department and notably not the Human Resources Department.
5
Safety awareness teams were established around 1992 to come up with a systematic
and structured method of implementation and monitoring
The Corporation subsequently affiliated to the National Occupational Safety
Association, an independent body based in South Africa. A baseline audit was carried
out in 1995 followed by the first NOSA five star audit in 1996, under the circumstances
the results attained were relatively good and a sign of an overall above average work
done on the implementation of the NOSA Five Star System. Of notable achievement
were the training programme, whose target was 5 per cent per annum, establishment
of committees, documentation of and training on some key safety hazards such as
chlorine, fire etc.
Amongst the things that contributed to the shortcomings in the implementation of the
NOSA Five star system that the audits identified, are the lack of proper documentation
and the apparent failure of adequate participation by management on the
implementation of the NOSA Five star System.
Management’s commitment to the implementation of a comprehensive SHE
programme has however been inadequate right from the onset. This is demonstrated
by its failure to establish an institution responsible for ensuring the implementation of
the SHE programme, but instead depended on the services of a Safety Co-ordinator
through out this process.
It will be noted further that some pro-safety initiatives such as safety incentives, water
quality medical examinations, accreditation to ISO 9000, disaster preparedness
initiative have either never really got off the ground or failed to be sustained, possibly
due to institutional problems or just a mere lack of commitment by those responsible
for spear heading them.
Following this relatively successful NOSA audit in 1996, a resolution was made by the
then SHE Committee to restructure the safety organisation within the Corporation in
order to address the following issues, to name just but a few;
(i)
conformity with the NOSA requirements
(ii)
inclusion of staff representatives through union representatives and JCC/ACC
(iii)
inclusion of other WUC departments and sections which were not participating
in the SHE initiative implementation committees
The above-mentioned committee invited some Section Heads and Union and JCC staff
representatives to a meeting as observers to assist in these deliberations. A number of
resolutions were made including the formation of the Executive SHE Committee with reforms
such as involvement of more corporate management in the committee, the formulation of
SHE policies and standards etc.
Area SHE committees were also re-organised and appointments made in accordance with
Section 16 (20) of the OHSAct. It will be noted that an oversight has always been made of not
making the Section 16(1) appointment of the Chief Executive Officer responsible for
employee health and safety in the workplace.
6
Terms of Reference for the Executive SHE Committee were formulated in 1997 and were
later used to formulate the draft policy and procedure statement on Safety Health and
Environment, which is still outstanding to date.
Recently management gained momentum on the implementation of the SHE initiative,
possibly due to internal, external or other mandated forces. A notable development and a
remarkable one at that is the recent decision by management to institutionalise the section
responsible for ensuring the implementation of the SHE programme, which resulted in a
positive increase in skilled manpower in this respect.
It has also become apparent during the recent years when safety had “collapsed” that for a
successful implementation and management of strategies it is imperative that safety does not
become the domain of the person responsible i.e. SHE Manager, officer, or line Manager, but
that the onus for a safe working environment is upon each an every individual. As a
fundamental part of any business process and a core business function of any operation, the
pertinence of occupational health and safety, and environmental conservation cannot be
overemphasised.
Several internal audits have been conducted in the recent past, whose scope covered the
Corporation’s complete premises, installations, dams, and major transfer schemes such as
the North South Water Carrier Project. Occupational hygiene surveys and a couple of more
internal audits, this time using the new NOSA Integrated Five Star System, are scheduled for
the near future and incorporated in the action plan below.
3.0
EXISTING POLICIES AND IMPLEMENTATION TOOLS
3.1
WUC’s Policy on SHE
3.1.2 Policy and Procedure Statement on SHE
The Corporation attaches the greatest importance to the health and safety of its
employees. It is the duty of management and equally the personal duty of every
employee to do everything possible to prevent and avoid injury to self and the others
and to minimise any other forms of loss, the elimination of all occupational heath
hazards and the protection and conservation of the environment. To this end, any
contravention of safety procedures shall be treated as a serious offence which shall
constitute grounds for appropriate disciplinary action.
Some of the salient aspects of the draft SHE policy should inter alia;
(i)
emphasise Management’s commitment to Occupational Health and Safety in
the work place.
(ii)
reflect the emphasis the Corporation places on efficient operations, with
minimum incidents and losses.
(iii)
reflect the intention to integrate SHE into all operations, including compliance
with applicable standards.
7
(iv)
emphasis the necessity for active leadership, direct participation and
enthusiastic support of the entire organisation.
(v)
The second part of the policy should talk about “Organisation” (people and their
duties) and should also demonstrate how accountabilities are determined, and
how policy implementation is to be monitored.
(vi)
The third part of the policy should talk about “Arrangements” (System and
Procedures). This part should detail the practical arrangements in force to
assist in the overall policy implementation. These include SHE training, SHE
Audits/Inspections, Incidents Reporting, and Investigation, Safe Work
Procedures, Access/Permit to work systems, Risk and Impact Assessments,
Corporate Standards, SHE Objectives and Targets, SHE plan and SHE system
review.
3.1.3 Staff Regulations on Occupational SHE
Under the Staff Regulations and Conditions of Service Occupational SHE is mentioned
under the Code of Conduct 15.5.16 and it reads thus:“The Corporation attaches the greatest importance to the health and safety of its
employees. It is the duty of management and equally the personal duty of every
employee to do and others and to minimise any other forms of loss, the elimination of
all occupational health hazards and the protection and conservation of safety
procedures shall constitute grounds for disciplinary action.”
3.1.4 Standards and Safe Working Procedures
A few standards, which seriously fall short of covering the entire SHE system, have
been formulated albeit not completely.
According to the new NOSA Integrated Five Star system there will be a complete
booklet on standards. It is intended that this facility be used to review our existing
standards, which to date have not been fully implemented.
Since 1997 the Corporation has been training people annually on Job Safety Analysis,
in order that they are able to conduct job analysis, identify hazards and high risk tasks
and come up with safe work procedures.
To this end some sections have managed to carry out Job Safety Analysis in its
entirety as outlined above. However even these sections do not quite adhere to these
procedures at all times. This calls for the need for departments to embark on job
safety analysis of their entire job, produce safe working procedures and ensure that
they are implemented.
4.1.5 NOSA Integrated Five Star System
The new NOSA integrated Five Star system is a risk management program, whose
primary objective is to provide world class occupational safety, health and
environmental risk management on international standard.
8
This system covers areas like occupational health, occupational hygiene, risk
management, safety management and environmental risk management. Its criteria
include hazards identification and risk assessment, standards and procedures
development, compliance with procedures, standards and national legislation
compliance.
The Corporation’s affiliation to NOSA is of great importance in the light of the global
trends on occupational safety, health and environmental management program. The
affiliation will help the Corporation to cope with the up impending legislation, policies
and the impact of globalisation in the SHE area. For example, International Labour
Organisation convention 155, recommends that each member State formulates
policies and legislation on occupational safety, and environment, and Botswana has
ratified that convention, and SADC member States are currently pursuing a standard
SHE policy and legislation. NOSA as an organisation with global experience will help
the Corporation to absorb these kind of challenges.
To this end, WUC is a member of the Co-ordinating Committee on the Formulation of
the National Occupational Health and Safety Policy, and as such must be exemplary in
the development and implementation of a SHE program.
The new system implementation procedures are based on the following:
(i)
Risk assessment.
(ii)
Adherence to corporate policies and standards
(iii)
SHE policy formulation.
(iv)
Adherence to Corporate policies and standards
(v)
Determination of realistic and achievable SHE objectives and targets.
(vi)
She plan to meet objectives and targets
(vii)
SHE system review by top management
3.1.6 Workplace Risk Assessment
Workplace risk assessment is a set of ongoing management and engineering activities
of a business, aimed at ensuring that the safety, health and environmental risks of a
business are effectively identified, understood and minimised to a reasonably
achievable and tolerable level.
There are three types of workplace risk assessment, namely, “Baseline risk
assessment” “Issue based risk assessment”, and “Continuous risk assessment”.
These are inter-related, and should form an integral part of any risk management
system.
9
i)
Baseline risk assessment
Baseline risk assessment is the process of determining the current risk profile of the
place of work in order to determine the main focus areas of the risk assessment
programme.
During this type of risk assessment the following should as a minimum be considered:




ii)
Legal requirements
Processes in any given areas
Activities in the geographical area
Tasks making up the processes or activities
Issue based risk assessment
The purpose of an issue based risk assessment is to conduct a detailed assessment
study of the activities, occupations, tasks, and general operation of equipment
identified during the baseline risk assessment as posing a significant risk e.g.
occurrences of incidents, new equipment and processes.
iii)
Continuous risk assessment
This is a continuous process of monitoring risks identified and their recommended
controls. It involves activities such as:




Planned inspections
Planned maintenance systems
SHE audits
Planned tasks observations
The assessment covers Safety (injuries, fire, machinery, buildings, damages), Health
(occupational diseases, exposures, medical surveillance,) and Environment (waste
management, environmental impact assessment, conservation, ground, air, and
environmental protection and water pollution control). These must be carried out in
collaboration with the national authorities on the protection of employee health and
safety, and the protection, conservation and development of natural resources.
iv)
Compliance with SHE System
SHE program implementation strategy must be documented. This is the program that
shows how the organization implements and monitors its SHE program. The strategy
must show how senior management is involved in the SHE strategy implementation,
how the general employees are informed about the SHE program and standard, and
what can be done through SHE talks and kept as records of proof. Internal audits and
external audits must be carried to test the program implement.
10
3.1.7 Strategy on Disaster Preparedness and Management
Water Utilities Corporation has for a long time maintained a Disaster Strategic Failure
Scenario, which was mostly concerned with operational problems. Since 1999 the
Corporation has been one of the leading role players in the National Disaster
Management Initiative.
The Corporation is currently working at incorporating all other possible eventualities
and emergencies into a comprehensive strategic plan in collaboration with the
Government’s Directorate on Disaster Management.
3.1.8 Policy and Procedure Statement on Protective Clothing
The Corporation attaches the greatest importance to the safety
3.1.9 Dams Safety Inspections
The Corporation subjects its dams as a matter of policy to a rigorous safety inspection
and evaluation on an annual bases, which makes recommendations for monitoring
and remedial works as found necessary.
3.2
WUC’s Policy on Environmental Management
The Corporation has since carried out a research to assess existing situations at
Water Utilities Corporation with regard to environmental issues in the areas of:
Conservation, Pollution Control, Amenity Development of Dams, Waste Management,
Existing Policies and Standards (at national level), Chemicals in use, and Health and
Safety.
To this end specific policies and procedures have been developed for each area and
are been administered at varying degrees of completion and success. However, it is It
is imperative that a holistic environmental policy is adopted in terms of ISO 14001
guidance, within whose purview these policies can be properly administered and
environmental management plans developed and implemented. The policy will
guarantee management commitment, which is a critical aspect of environmental
management systems, and set a conducive stage for ISO certification in future.
The PPSs are follows;
3.2.1 Environmental Impact Assessment (EIA)
The need for consideration of possible impacts on the environment has become more
than just a requirement set by our financiers. The Corporation recognises the
importance of environmental impact assessments and these have as an obligatory
requirement been carried out on all our recent major projects.
3.2.2 Water Conservation
It is necessary to intensify our water conservation campaign, and to be proactive in
sensitising customers to the benefits of reducing water usage and recycling practices.
11
However it should be borne in mind that the more successful our save water campaign
is, the less water we will sell. Similarly, the more it rains, the dirtier the water becomes
and ultimately, the more expensive the water becomes to treat. These are just some
of the paradoxes that any water provider must confront.
3.2.3 Amenity Development of Dams
In the light of the recent recommendations made in the environmental impact
assessment (EIA) studies of the recently constructed dams, as well as the growing
public interest in the development of dams for various amenity uses, the Corporation
has since accepted that the use of its dams can be diversified to cater for recreational
and other related activities, which are of a socio-economic benefit to both the public
and the Corporation, while at the same time not compromising the quality of the water
environment.
To this end, the Corporation has established the Dam Amenities Committee (DAC),
comprising of internal and external members from stakeholder Governmental sectors,
to give technical advice and policy guidance on matters relating to amenity
development of dams and their environs.
The Corporation is currently in the process of reviewing the Dam Amenities
Development Master Plan (DAMP), upon which the Corporation gave tenders for the
amenity development of its dams in 1997, with the view to developing the Dams
Management Master Plan. This has been necessitated by the past experience
regarding the management of concession areas leased out for amenity developments
as well as the high influx of applications for various development proposals, including
tourism and boating activities for recreational purposes.
Close monitoring of the already awarded developments in its dams is to be carried out
by the Corporation. The Corporation is confident that the safeguards built into our
agreements with the developers will assist in ameliorating any negative impacts that
may arise in the dams' environs.
3.2.4 Environmental Protection and Pollution Control
One of the aims of the water quality monitoring programme is to detect any pollution of
our water sources at the earliest stages and ensure that the quality of water supplied,
as represented by the results of routine monitoring comply with both international and
WUC internal standards.
The basis for the development of the internal standards was the World Health
Organisation Guidelines of 1993.
It is intended that the water quality-monitoring programme for the Corporation's water
sources be, in conjunction with the Department of Water Affairs, extended to cover the
entire catchment areas.
12
3.2.5 Sludge Management
Sludge constitutes one of the areas of concern in the Corporation’s business. It is
therefore the intention of the Corporation to implement controls to minimise water
losses through sludge disposal and where feasible promote and optimise the water
reclamation operations.
The Corporation also undertakes to monitor and record the impact of its sludge
disposal on the environment and implement mitigation measures where the impact is
deemed negative.
This endeavour shall be implemented through a comprehensive Sludge Management
Programme that shall be appropriately designed in accordance with the provisions of
the Waste Management Act.
3.2.6 Dams Management Master Plan (DMMP)
The Corporation has developed the DMMP through the means of integrating
environmental issues i.e. social, bio-physical and socio-economic, into zoning, landuse management and development planning, a process known as Strategic
Environmental Assessment (SEA). This strategy is aimed at determining the
development opportunities the WUC dams offer and the constraints presented by the
environment.
The main objectives for the DMMP study were:
3.3
i)
To provide a sound and sustainable environmental management and planning
tool where the Corporation dams can be used for various purposes.
ii)
To review the DAMP and the proceedings of the “Stakeholders Workshop on
the secondary use of Dams and Eco-Tourism”, develop and make
recommendations for implementation of the DMMP and to peruse other relevant
literature and examples with a view to producing a working document on the
secondary use of dams and their applicability to the Botswana situation.
iii)
To assess and use as reference the regional experiences, evaluate and
document their success and failures.
Legislation and Policies on Occupational Health, Safety, and Environment
3.3.1 Factories Act, 1979
The Act makes provision for the regulation of the conditions in the factories and other
workplaces as regards safety, health and welfare of employees
The Act requires certain equipment to be tested and inspected periodically to minimise
risks, and the employer to provide safe working environment to employees and
provide adequate personal protection to the workers. It requires adequate first aid
facilities. All dangerous occurrences must be reported to the Chief Inspector of
Factories within stipulated time.
13
3.3.2 Public Health Act, 1971
The Act implores Employers to conduct medical surveillance of its employees, and
ensure the protection of public health by protecting the Environment.
WUC is currently a member of the Reference Group co-ordinating the formulation of
the National Occupational Health and Safety Policy, which will govern the protection
and medical surveillance of workers, in three ways depending on the type of hazards.
These are pre-employment, periodic, specific medical surveillances of workers health
through the Occupational Health and Safety Act.
3.3.3 Occupational Health and Safety Act (OSHAct), 1993
Although NOSA emphasises compliance with national legislation and policies, where
such legislation and policies do not exist this South African Act is used as a reference.
In the case of Botswana, where national policies in this regard are either inadequate or
still being promulgated, reference is made to the above Act for proper implementation
of the SHE program.
The Act requires a SHE policy to be developed and that an abridged policy is
displayed in a conspicuous place in languages that can be read by all employees.
Under the Act, SHE committees must be established, and duties be clearly outlined.
SHE officers (Inspectors) responsibilities must be clearly outlined particularly in case
of imminent danger and violation of the provisions of the Act and provided standards. It
will be noted that this act has several regulations or clauses that have similar
requirements as those of the Factories Act.
3.3.4 Smoking Control Act 1992
The Act controls the smoking of tobacco and tobacco products. It also requires that
companies formulate workplace smoking control policies in consultation with
employees, and designate smoking and non-smoking areas.
3.3.5 National Conservation ACT 1990
Botswana does not have an omnibus environmental legislation as yet.
An examination of the foreign legislation shows that Botswana’s environmental law
incompletely uncoordinated, and the country does not have a general Act on the
environment and environmental impact assessment (EIA).
In view of the above the Government of Botswana has recently taken positive steps
towards the enhancement of sustainable development and environmental
management policy, thus providing an enabling environment for such sectors as the
WUC who have an environmental obligation to realise their objectives.
The Government has so far expressed its commitment towards environmental
conservation and sustainable utilisation of natural resources by approving the 'National
Policy on Natural Resources Conservation and Development in 1990'.
14
It was in the context of this policy that the Government undertook to co-ordinate the
activities related to natural resources and carried out by different sectors, hence the
establishment of the multi-sectoral National Conservation Strategy (NCS) Advisory
Board under the MLGLH, and the NCS Co-ordinating Agency, a structure set up to
implement the strategy.
To this end, the Government has in recent years submitted a Bill to the National
Assembly, “The NCS Act" which includes amongst other things;
(i)
The requirement that all sectoral Ministries, Departments, Local Authorities,
Parastatals, etc., shall, in the course off their work, show due regard for the
conservation and enhancement of the environment in the interests of achieving
sustainable development.
(ii)
The need for same sectors to work closely with the NCS Co-ordinating Agency in
discharging their environmental responsibilities.
While The National Development Plan (NDP8) continues to place more emphasis on
the need to guarantee the sustainable management of the environment, it is envisaged
that the proposed EIA Legislation will be developed to cover amongst other things,
“the necessity for new development projects to be accompanied by professionally
prepared EIA reports” as a legally binding fundamental requirement.
Progress made to date at the national level includes the discussion on the following to
name just but a few;
(a)
EIA Legislation consultative process,
(b)
The NCS Act, 1990
(c)
The Waste Management Act, 1998
(d)
Revision of the Water Act of 1968, which inter alia, lobbies for more statutory powers
in environmental management,
(e)
National Water Conservation Campaigns, and most importantly
(f)
The formation of the Ministry of the Environment.
Notwithstanding the absence of a comprehensive environmental legislation, it has
been possible to protect the water resources by means of, in addition to the above, the
Water Act, Water Works Act etc. and regulations. However as water demands
continue to increase rapidly so do conflicts for use and potential pollution problems.
However in many instances water conservation and pollution control measures have
been effective due to good co-operation between various organisations and individuals
rather than due to statutory powers or supporting regulations
15
For example, even though the Water Act makes the pollution of water sources an
offence, developers are not required by law to bring their wastewater disposal plans to
the Water Apportionment Board for approval prior to construction. For example some
industries and agricultural activities were found to be discharging tremendous amounts
of effluent with unacceptable quality into the dam catchments, particularly Gaborone
dam. Even though there is no sound legal backing, these matters are being amicably
resolved through the Water Apportionment Board, Local Authorities and the Town and
Country Planning Board.
It is hoped that the revised Water Act, which was reviewed during the first stage of the
National Water Master Plan would, if enacted, amongst other things;

establish a framework for the licensing of hydraulic structures in watercourses and
on other lands

allow for the declaration of the protected areas where certain activities might be
prohibited by order of the Minister; where the discharge of certain wastes might be
prohibited; and where the existing water needs to be protected or otherwise
restricted;

establish much more serious penalties for pollution and enable the Government to
recover the costs of major environmental damage from the polluters in a more
meaningful way.
With regard to the first bullet above, a study was commissioned due to the serious
concerns about the impact of the continued construction of small dams in major
watercourses; e.g. there are over 200 small dams in the catchment area of Gaborone
Dam with notable impact on the dam.
With regard to the second bullet a study was completed on the development of
Protection Zones and Guidelines of Major Wellfields, Aquifers and Dams in Botswana,
which provide regulations for the protection of water sources without necessarily
impeding on the much needed economic and societal developments.
Enacting of the new Water Act would provide for the much needed and necessary
statutory powers to make these protection zones and guidelines legally binding.
3.3.6 Waste Management Act
This act requires companies to formulate waste management policy stipulating how
they are going to manage the waste they generate, and prevent environmental
pollution.
4.0
SHE IMPLEMENTATION STRUCTURES
4.1
Safety, Health and Environment Structures
The Corporation has over the past years established and reviewed its SHE institutional
establishment as well as both area and the Executive SHE Committees, in pursuant of
16
workable and effective structures as well as compliance with the established
standards.
The recent reforms in the SHE implementation have culminated in the establishment
of a Section, which is responsible to the Deputy Chief Executive, comprises of a
Section Head, the Safety and Environment Manager, a Senior Safety Officer, two
Safety Co-ordinators for South and North respectively and an Environmental Officer
The section’s vision, mission and key objectives are as follows;
VISION
To be a leading provider of occupational safety, health and environmental
management within WUC operational areas.
MISSION
To provide and maintain global standard on occupational safety, heath and
environment within WUC.
OBJECTIVES
(i)
To manage the implementation and enforcement of occupational health safety
and environment programme appropriately designed to maintain a safe and
healthy working environment.
(ii)
To develop, plan, manage and ensure the implementation of an environmental
management programme and sustainable development of water resources to
safeguard the continuous supply of a quality water service
(iii)
To conduct work place risk assessment and subsequently implement its
outcomes and recommendations
(iv)
To formulate and implement corporate SHE standards
(v)
To formulate SHE policy that is based on risk management principles
(vi)
To conduct two internal and one external audits
(vii)
To maintain a sustainable environmental planning program so as to ensure a
sustainable diversification of use of the Corporation water resources
(viii)
To promote efficiency and reduce losses by continuously raising awareness
among employees about the SHE program and procedures.
(ix)
To conduct training on SHE program, and equip SHE representatives with
adequate skill to carry out SHE activities
17
4.2
Legal Appointments:
The 16(1) appointment of the Chief Executive as well as the rest of the 16(2)
appointments of the line managers' responsibilities for occupational safety, health and
environment have all by and large been done.
4.3
SHE Committees
4.3.1 Executive SHE Committee
The Executive SHE committee comprises mainly of 16(2) appointees. The role of
committee members is to co-ordinate SHE implementation within WUC operational
areas and report on quarterly basis on progress of their respective areas.
4.3.2 Area SHE Committees.
Area SHE committees are established in all operational areas to facilitate the
implementation of the SHE programme. The composition of these committees is
management and staff representatives in a ratio determined by the legislation.
4.3.2 Dam Amenities Committee (DAC)
The Dam Amenities Committee is a multi-sectoral technical committee instituted to give
policy guidance and technical advice to the Corporation on matters relating to the secondary
use of eco-tourism in the Corporation dams and their environs.
5.0
REVIEW OF THE SHE IMPLEMENTATION PROCESS
A SWOT analysis of the Corporation’s status as regards the SHE implementation and
sustainable management indicates that whilst the current situation is generally
conducive for a workable program, there are some major challenges that have to be
addressed in order to implement a comprehensive and sustainable SHE program.
Amongst other things the SHE section, plays the role of assigning, assessing and
monitoring the functions and actions of SHE personnel and SHE related activities in
the Corporation and is construed as a major breakthrough in this endeavour.
Some of the salient achievements to date include the commitment and ability by the
Corporation to undertake a rigorous training programme which has resulted in a fair to
good understanding of the system and its requirements by employees and a good
knowledge of the benefits of implementing the SHE programme.
5.1
POSITIVE TRENDS
Below are some of the factors that are expected to provide an enabling environment
for the development and implementation a comprehensive SHE program;
(i)
The Corporation’s affiliation to NOSA will help a great deal to address global
SHE issues, and attainment of international standards.
18
5.2
(ii)
The Internet provides instant global information on new technologies, strategies
and techniques to employ on SHE issues.
(iii)
Active participation and membership of the Corporation in a number of intersectoral associations and committees dealing with the various aspects of
environmental management, and safety and health issues.
(iv)
The National Disaster Preparedness initiative is an opportunity for Water
Utilities Corporation to work hand in hand with other organisations and
government departments.
NEGATIVE TRENDS/CHALLENGES
On the other hand some of the challenges that have to be overcome include but are
not limited to the following;
(i)
The culture of complacency and non-compliance to sets standards and
procedures that prevails within Water Utilities Corporation.
(ii)
Failure to conduct initial Risk Assessment from the onset has resulted in efforts
not being risk based, hence duplication of efforts and or failure to address other
risks.
(iii)
Lack of a complete and working comprehensive SHE policy.
(iv)
Inadequate commitment and drive from senior management team.
(v)
Failure to integrate SHE into all operations, including compliance with
applicable standards.
(vi)
The government is currently in conjunction with other stakeholders working on
formulating a National Policy on Occupation Safety. Health and the working
environment. The completion of the policy will lead to the formation of an Act
on Occupational SHE.
(vii)
The Corporation has in the past till now failed to run a comprehensive
Occupational Health programme. Hence it is likely to find that most of existing
employees have contracted occupational diseases, which have not been found
before and that might escalate compensation claims thereby affecting our
workman’s compensation premiums. Some may have been employed with
unnoticed disabilities.
(viii)
The Globalisation factor might bring us into competition with other organisations
getting into Water Treatment and Supply business. The Corporation is also
likely to deal with organisations that demand that it attains international
standards such as IS0 9000 for quality assurance and IS0 14000 for
environmental management.
(x)
There are International Labour Organisation Conventions and recommendations,
which Botswana is about to ratify. For example, Convention No. 155
19
concerning Occupational safety, Health and the working Environment – which
gives staff plenty of rights and privileges on organisational SHE management.
(xi)
5.3
Unions
are
currently
working
on
standardising
international standards on conditions of employment.
or
demanding
Publicity Strategy
The Publicity strategy is a continuous process of raising awareness, informing and
evaluation of the SHE implementation program or the impact of the program
implementation.
This process can be carried out through visual aids, short lectures
(SHE talks), articles publication in the quarterly magazine, and through competitions,
drama on designated day by the Corporation or set as a commemoration day for SHE.
The impact of the publicity can be evaluated through inspections and audits scheduled
by the Corporation.
The publicity can be carried out using the following strategies:
(i) Display of SHE posters

SHE section shall provide departments and sections with SHE posters to be
displayed in different offices.

SHE representatives shall be responsible to display the posters in their respective
sections or departments.

Section and unit heads shall be responsible to ensure that posters talks are held
and understood

Posters shall be rotated between sections at monthly basis.

Posters used shall be relevant to each section line of operation.

All those who saw and understood the poster shall write their names and sign for
acknowledgement.
ii) SHE video shows

The SHE section shall maintain a pool of SHE videos to be used to promote
awareness. These videos shall be used to address issues identified as posing
significant risks to specific departments, sections, groups or categories of staff.

SHE videos shall be used in SHE training as training aids.

Video shows shall be shown to different departments at three months intervals.
20

Records of video show attendance shall be recorded.
(iii) SHE toolbox talks

SHE talks shall be used as a tool to address work preparations, tools, equipment
and personal protective equipment awareness.

SHE talks shall be held by each and every section supervisors to raise awareness
about a job at hand equipment needed and used personal protective equipment
and written safe work procedures.

Supervisors shall be required to hold SHE talks on daily basis.

On monthly basis the SHE section shall address each and every section on
problem issues particular to the section.

All monthly SHE talks shall be recorded.
(iv) Submission of SHE articles to SEDIBENG newsletter.

Sedibeng newsletter shall be used by the SHE section to express certain views or
publications pertaining to SHE management.

The SHE section shall submit articles on quarterly basis to the Sedibeng magazine
on issues such as incidents, SHE structures, SHE policy, SHE risk profile, SHE
problem areas etc.
(v) SHE reference library

A SHE reference library shall be maintained to help promote awareness and
provide information on SHE programme requirements, issues and possible
solutions.

The reference library shall keep articles such as SHE policy, SHE corporate
standards, written safe work procedures, presentations from the NOSHCON
conference, SHE magazines such as safety management, workers life, African
newsletter on occupational health and safety.

The reference library shall be used as a source of information to address issues
such as Topics of the month, incidents etc.

The library shall be open to all departments, sections and individuals interested in
gaining or gathering information on SHE management.
(vi)

She Publicity Day
A SHE publicity day shall be commemorated by each and every area
21

SHE publicity day shall be a designated day by the Corporation which shall be
observed by all sectors of the Corporation and the day shall be reserved for Safety,
Health and Environment activities.

The activities shall be characterised by activities such as PPE usage, drama
sessions, job observations, emergency procedures, incident investigations, fire
fighting drills etc

The day shall be promoted by offering staff with T-shirts printed with the theme of
the day.
TABLE 1.0: Publicity and Awareness Campaign Action Plan
Activity
Desired result
/objective
Responsibility
Duration &
frequency
Target
Cost
Evaluation
SHE video
shows
To raise
awareness
among
employees on
SHE specific
procedures or
hazards
SHE section,
SHE Reps,
Area
committees
30minutes,
once a week
WUC
employees
as required
by the risk
existing in the
line of
operation
P2000.00
To rent
VCR, TV
and
purchase
new videos
Inspections
& audits
SHE talks
To raise
awareness to
address a
specific SHE
problem that is of
concern
SHE section,
area
committees
30 minutes
once a week
on Mondays
employees
SHE
posters
To raise
awareness
among
employees and
the public
SHE section,
area
committees
Posters to
be rotated
or changed
on monthly
basis
Employees,
the public
Articles
To submit SHE
articles to
Sedibeng
magazine to
update
employees on the
SHE
implementation
progress
SHE section
quarterly
employees
SHE
publicity
day
To raise
awareness and
inform employees
about SHE
activities
SHE section
Once a year
employees
22
Inspection
& audits
P5000.00
Purchase
new
posters
Inspection,
& audits
Inspection
& audits
P15000.00
Print Tshirts and
develop
posters
with a
theme for
the activity
Inspection
& audits
5.4
SHE Implementation Training Requirements

The initial step in the system implementation is to conduct hazard identification and
risk assessment. The key role players must be trained by September 2002.

The SHE internal auditors must be trained before the first internal audit scheduled
for April 2003.

SHE management to be trained in safety management training course (SAMTRAC)
before the external audit scheduled for March 2004.

Incident investigators must be trained before the internal audit scheduled for April
2003. Other key role players such as first aiders, and fire team must be trained
before the external audit.
TABLE 2.0: Training Plan
COURSE
OBJECTIVE
TARGET
DATE
DURATION
& VENUE
PARTICIPANTS
COST
WORK PLACE
RISK
ASSESSMENT
To equip key role
players with the skill
and knowledge of
conducting hazard
assessment
September,
2002
3 days,
Pretoria
5
P18700.00
Auditors course
To equip internal
auditors with the skill
and knowledge of
auditing new NOSA
integrated system
March/April
2003
5 days ,
Pretoria
4
P20900.00
SAMTRAC
To equip SHE section
management with
knowledge of
implementing the
new NOSA system
June, 2003
10 days,
Pretoria
2
P18000.00
Incident
investigation
To enable our
investigators to
investigate incidents
as required by NOSA
system
May 2003
3 days ,
WUC
training
centre
20
P16000.00
First aid course
To have qualified first
aiders in all WUC
work areas
September,
2003
3 days
20
P2800.00
P76400.00
TOTAL
COST
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TABLE 3.0: SHE Implementation Action Plan
Issue / Item
Desired Result
Action By
Target Completion Date
SHE
Strategy
Document
A strategic working document on SHE
implementation
SHE SECTION
July 2001
Hazard
assessment
Complete document of hazards status
within WUC
SHE SECTION
March 2002
NOSA integrated
systems kit
To have a new NOSA systems kit and
launched the system
SHE SECTION
/ALL
June, 2002
NOSA
kit
implementation
To conduct a workshop on NOSA
system implementation
SHE SECTION
June, 2002
SHE appointments
To appoint all key role players in the
SHE program implementation
DCE/
SHE
SECTION
October, 2002
Risk assessment
proposal
Submit complete
proposal
SHE SECTION
October, 2002
SHE restructuring
Revised
structures
DCE/
SHE
SECTION
October,2002
SHE
strategic
document
Submit
complete
document
SHE SECTION
October, 2002
Disaster
Management
Strategic
Document
A strategic working document on
disaster
preparedness
and
management
SHE
corporate
standards
formulation
WUC
corporate
standards
are
developed. launched and implemented
SHE SECTION
October, 2002
Risk assessment
Conduct risk assessment in all WUC
AREAS
SHE SECTION
May, 2003
Risk profile
To develop profile of all risk identified
based on their impact
SHE SECTION
May, 2003
Incident
investigation
To have comprehensive incident
investigation and recording procedures
ALL
May 2003
External audit
(north & south)
To be graded based on new NOSA
integrated system
ALL
March, 2004
WUC
audits
south
To conduct self internal SHE audits in
preparation for external audit
SHE SECTION
April & October 2003
internal
(north &
SHE
risk
assessment
implementation
SHE
strategy
24
Dec. 2002
DCE / SEM
Environmental
Management
To
develop
a
comprehensive
Environmental Policy stating the
Corporations aims and objectives
SEM/EO
March 2002
Dams
Management
Master Plan
A
sound
and
sustainable
environmental management plan of
WUC Dams
SEM/EO
December 2001
Environmental
Education
and
Awareness
Campaigns
Increased environmental awareness
amongst staff.
EO/PRM
March 2002
Water
Conservation
Campaign
Water Savings
EO/PRM
March 2002
Compliance by WUC to national
standards on environment, water
quality and waste water
SEM
Development
Environmental
Standards
of
June 2002
Catchment audits
and
Biological
Water
Quality
Assessments
Database on all developments in the
dams catchment and constant analysis
of pollution indicators
EO
August 2002
Biological Water
Quality
Assessment
Database
A comprehensive database on algae
and establishment of trends
EO
March 2002
25
5.5
Revised SHE Structures
WUC SHE STRUCTURE
Figure 1
CHIEF EXECUTIVE OFFICER
HRD 16(2)
DCCSD 16(2)
TSD 16(2)
DCE/SMD 16(2)
CS 16(2)
FD 16(2)
IAM 16(2)
PM, IRM, PMSM, TDM
DM(S)(N), CSM(S)(N), PRM
ARM(N)(S)
SE(D)(P), WQM, ISM, SSM
SEM, SM, MM, TIM
CSM, LMM
FM, MA
SIA
AREA COMMITTEE
REP.
AREA COMMITTEE
REP.
AREA COMMITTEE
REP.
AREA COMMITTEE
REP.
AREA COMMITTEE
REP.
AREA COMMITTEE
REP.
AREA COMMITTEE
REP.
SHE SECTION
EXECUTIVE SHE COMMITTEE
CHAIRMAN DCE/SMD16(1)
Figure 2
UNION REPX2
PE/DE16(2)
MM 16(2)
MA/FM 16(2)
SM16(2)
DM16(2)
WQM16(2)
SECRETARIAT
SHE SECTION
27
LMM16(2)
CSM16(2)
PRM16(2)
PM/IRM16(2)
CCSM16(2)
CMT REP.
AREA SHE COMMITTEE
CHAIRPERSON
16(2)
Figure 3
MANAGEMENT
REP.
HR
MANAGEMENT
REP.
FINANCE
MANAGEMENT
REP.
TS
MANAGEMENT
REP.
CORP.SERV.
MANAGEMENT
REP.
IS
MANAGEMENT
REP.
CUST.SERV.
SHE REP.
SHE REP.
SHE REP.
SHE REP.
SHE REP.
SHE REP.
SHE COORDINATOR
28
29