Health & Safety Management Lecturing Resource for Quarrying Related Degree Courses LECTURE NOTES: HEALTH & SAFETY MANAGEMENT SYSTEMS Objectives of this Section To define the concepts and components of a health and safety management system; To outline recent developments in health and safety management including the development of OHSAS18001 and accreditation. 1.0 Introduction Many of the industrially developed countries of the world have seen injury and illness rates decline over the last 50 years. However these rates have generally reached a plateau over the last decade. This fact, coupled with the realisation of the role of management and organisational (latent) failures in accident causation, has lead to new approaches in managing health and safety, most notably the use of a systems approach. The importance of managing health and safety has been highlighted in recent official reports of major accidents and has received increasing emphasis in OH&S legislation. A Health and Safety Management System can be defined as ‘the means by which an organisation controls risk through the management process’. The BSI define a OH&S management system as ‘part of the overall management system that facilities the management of the OH&S risks associated with the business of the organisation. This includes the organisational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing and achieving, reviewing and maintaining the organisation’s OH&S policy. 2 2.0 What is meant by a systems approach? A systems approach to management is based on system theories developed primarily in the natural and social sciences. Four elements common to general systems theories are input, process, output and feedback. Systems are also classed as being either open or closed. An open system is one where there are identifiable pathways where the system interacts with the external environment and is subject to external influences. In health and safety these influences include legislation, public opinion and the economy. Closed systems do not interact with the environment and so their ability to adapt or respond to changing internal conditions is limited. A management system is an open system, and based on the following approach: INPUT PROCESS OUTPUT FEEDBACK Organisation External Environment In the past organisations put a great deal of emphasis on safety programmes. These are different from health and safety management systems in a number of ways: Programmes are focused on compliance with the standards/regulations within and do not have the strong or any feedback mechanisms where the contents are adjusted or modified to accommodate changing circumstances. Systems have this facility. The performance of a programme is based on compliance with the system and with trailing (or reactive) indicators such as the number of accidents, injuries etc. In a systems approach performance is also measured from the input and process components of the system. In 1991 the HSE published a document entitled “Successful Health and Safety Management” which was designed to be a practical guide for businesses who wanted to improve their health and safety performance. Their approach to health and safety management has six elements: 3 Policy Organising Planning and implementing Measuring performance Reviewing Performance Auditing A summary of this guidance is given in the next section. 4 3.0 Key elements of a H&S Management System The key elements of successful health and safety management are set out in this summary. This is taken from the HSE Guidance document HSG651. Diagram I outlines the relationship between them. Policy Organising Audit Policy development Organisational development Planning and Implementation Measuring Performance Developing techniques of planning, measuring and reviewing Reviewing Performance Policy Effective health and safety policies set a clear direction for the organisation to follow. They contribute to all aspects of business performance as part of a demonstrable commitment to continuous improvement. Responsibilities to people and the environment are met in ways which fulfil the spirit and letter of the law. Stakeholders' expectations in the activity (whether they are shareholders, employees, or their representatives, customers or society at large) are satisfied. There are cost-effective approaches to preserving and developing physical and human resources, which reduce financial losses and liabilities. 1 HSE (1997) Successful Health and Safety Management, HSG65, HSE Books. 5 Organising An effective management structure and arrangements are in place for delivering the policy. All staff are motivated and empowered to work safely and to protect their long-term health, not simply to avoid accidents. The arrangements are: underpinned by effective staff involvement and participation; and sustained by effective communication and the promotion of competence which allows all employees and their representatives to make a responsible and informed contribution to the health and safety effort. There is a shared common understanding of the organisation's vision, values and beliefs. A positive health and safety culture is fostered by the visible and active leadership of senior managers. Planning There is a planned and systematic approach to implementing the health and safety policy through an effective health and safety management system. The aim is to minimise risks. Risk assessment methods are used to decide on priorities and to set objectives for eliminating hazards and reducing risks. Wherever possible, risks are eliminated through selection and design of facilities, equipment and processes. If risks cannot be eliminated, they are minimised by the use of physical controls or, as a last resort, through systems of work and personal protective equipment. Performance standards are established and used for measuring achievement. Specific actions to promote a positive health and safety culture are identified. Measuring performance Performance is measured against agreed standards to reveal when and where improvement is needed. Active self-monitoring reveals how effectively the health and safety management system is functioning. This looks at both hardware (premises, plant and substances) and software (people, procedures and systems) including individual behaviour and performance. If controls fail, reactive monitoring discovers why by investigating accidents, ill health or 6 incidents which could cause harm or loss. The objectives of active and reactive monitoring are: to determine the immediate causes of substandard performance; and to identify the underlying causes and the implications for the design and operation of the health and safety management system. Longer~term objectives are also monitored. Auditing and reviewing performance The organisation learns from all relevant experience and applies the lessons. There is a systematic review of performance based on data from monitoring and from independent audits of the whole health and safety management system. These form the basis of self-regulation and of complying with sections 2 to 6 of the Health and Safety at Work etc Act 1974 (HSW Act) and other relevant statutory provisions. There is a strong commitment to continuous improvement involving the constant development of policies, systems and techniques of risk control. Performance is assessed by: internal reference to key performance indicators; and external comparison with the performance of business competitors and best practice, irrespective of employment sector. Performance is also often recorded in annual reports. 7 4.0 Recent Developments in OH&S Management Systems Standardisation In recent years a great deal of emphasis has been placed on standards and standardisation. One of the main reasons for this is that most major companies in the industrially developed world are multinational and favour a standardised approach to aspects of their business. Over the last decade the International Standards Organisation (ISO) has produced two major standards for organisations namely: ISO 9000 series: Quality Management Systems ISO 14000 series: Environmental Management Systems Both these standards integrate their respective functions within a business and management framework and have been developed internationally by the world community. A standard is defined by the BSI as: A document, established by consensus and approved by a recognised body, that provides for common and repeated use, rules, guidelines, or characteristics for activities or their results, aimed at the achievement of the optimum degree of order in a given context. Such Standards are voluntary and are designed to be externally verified by nationally accredited bodies. It is argued that companies who register with these schemes will experience market advantages, a better relationship with regulatory authorities, investors, insurance companies as well as experiencing financial benefits through greater efficiency. Within these series mentioned above there are two types of ‘standards’ document, which are specifications and guidance documents. A specification is a “detailed set of requirements to be satisfied by a product, material, process or system, indicating the procedures for checking conformity to these requirements”. Specifications are written in such a way to enable conformity to be verified by any first party (supplier), second party (purchaser) or third party (independent certifier). A guidance document provides advice rather than a set of verifiable requirements and is designed as an internal management tool. It has long been recognised that a health and safety management system is analogous to an environmental management system and much debate has taken place across the world on whether such a certifiable standard should be produced for health and safety management 8 systems. The ISO 14001 management system model is shown in the figure below and as can be seen there is a great deal of overlap with the HSE model described earlier. Continual Continu Improvement Improvem al ent Status OHS Policy Review OHS Policy OHS Policy Planning Plannin Planning g Implementation Management Manageme Review Revie nt w Checking & Checking Corrective Correctiv Action & Implementation & Operation & Operation Actio e n In 1997 the ISO decided for various reasons not to proceed with the development of a formal international standard on health and safety management systems. As a result a number of individual country based standards have been produced, and a recent survey undertaken by the University of Michigan 2 identified a total of 31 standards, guidance documents and codes of practice available in the world community. The publishers of these documents include national and state/provincial governments, national standards organisations and professional health and safety associations. The UK was one of the first countries to produce such a document when in 1996 the British Standards Organisation produced BS 8800. BS 8800 BS8800 3was written as a guidance document and describes how the management system models in both the HSE publication (HSG65) and ISO 14001 can be used to enable the 2 Dairymple at al (1998), Occupational Health & Safety Management Systems: Review and Analysis of International, national and regional systems and proposals for a new international document, Report prepared by International Occupational Hygiene Association for the International Labour Office. 3 BSI (1996): BS8800: Guide to Occupational Health and Safety Management Systems. 9 integration of health and safety management within an overall management system. BS8800 is intended to be suitable for both large and small organisations covering a wide range of manufacturing and service industries and gives advice on: How to evaluate shortcomings with an existing health & safety management system (OHSMS); What an adequate system should comprise of; How to progress from existing system to an adequate system. Over 7000 copies of BS8800 were sold in the first twelve months and absence of any ‘officially’ accredited certification scheme lead to a large number of organisations offering ‘unofficial’ certification to the guidance. The OHSAS Series Following the success of BS8800 and the concern over the number of organisations, such as consultancies offering independent certification to the guidance in BS8800, several organisations (both from the UK and internationally) lead by the BSI got together to produce a OHSMS specification. The principal aim of this was to produce some consistency. The result was the publication in 1999 of OHSAS 180014. This is not an official British Standard nor an ISO standard, however many of the major accreditation companies are offering certification to the standard. The management system model used in OHSAS 18001 is the ISO 14001 model. As a specification, OHSAS 18001 lists a number of management system requirements using ‘shall’ statements such as ‘the organisation shall establish and maintain documented health and safety objectives, at each relevant function and level within the organisation’. The elements and sub-elements of OHSAS 18001 are shown in the diagram below: 4 BSI (1999): OHSAS 18001: Occupational Health and Safety Management Systems – Specification. 10 1. 2. Continual Continu Improvement Improvem al ent 3. Management Manageme Review Revie nt w Checking & Checking Corrective Correctiv Action & Status OHS Policy Review OHS Policy OHS Policy Planning Plannin Planning g Implementation 4. & Implementation Operation & Operation Actio e n 5. OH&S Policy 1.1. The Health & Safety Policy Planning 2.1. Planning for hazard identification, risk assessment and control 2.2. Legal and other requirements 2.3. Objectives 2.4. OH&S management programme(s) Implementation and Operation 3.1. Structure and responsibility 3.2. Training, awareness and competence 3.3. Consultation and Communication 3.4. Documentation 3.5. Document and data control 3.6. Operational Control 3.7. Emergency preparedness and response Checking and Corrective Action 4.1. Performance measurement and monitoring 4.2. Accidents, incidents, non-conformances and corrective and preventative action 4.3. Records and record management 4.4. Audit Management Review 5.1. Management Review In 2000 the BSI produced OHSAS 18002 5 to provide generic guidance on the application of 18001. This document describes the intent, typical inputs, processes and typical outputs, against each requirement of 18001 listed above in order to aid the understanding and implementation of OHSAS 18001. 5 BSI (2000): OHSAS 18002 Occupational Health and Safety Management Systems: Guidelines for the Implementation of OHSAS 18001. 11 5.0 Practical Aspects of a H&S Management system Whatever the management system adopted whether it be that of OHSAS 18001, the HSE or any other international model, they are all based on the systems model described earlier (i.e. input, process, output and feedback) and all have a number of common requirements. This purpose of this section is to look at some of those common elements from a practical perspective. The order these elements are presented is based on the OHSAS18001 model. The Health and Safety Policy An OH&S policy establishes an overall sense of direction and sets the principles of action for an organisation. It sets goals for the level of OHS responsibility and performance required from the organisation. It demonstrates the formal commitment towards good OH&S management, particularly that of the organisation’s top management. Under the Health and Safety at Work Act, 1974, there is an obligation on all organisations with five or more employees to prepare a written statement of general policy on occupational health and safety. Most organisations should, therefore, already have a ‘mission’ statement committing themselves to managing health and safety effectively. BS8800 sets out nine specific commitments that must be included to develop a comprehensive policy statement. 1. Recognising that OH&S is an integral particle of its business performance OH&S should not be a 'bolt-on' to your existing management process. It is essential that a proactive approach is adopted, embracing OH&S within the overall management system. This is the most cost effective way and one which will reap the maximum benefit for the organisation. 2. Achieving a high level of OH&S performance, with compliance to legal requirements as a minimum, and to continual cost-effective improvement in performance. Inevitably society's expectations are increasing pressure on organisations to reduce the risk of ill-health accidents and near-miss incidents in the workplace. In addition to meeting legal responsibilities, the aim should be to move ahead, in a cost-effective manner to improve OH&S performance, and continuously evolve the management system to meet changing business and legislatory needs. 12 3. Provide adequate and appropriate resources to implement the policy Planning and adequate preparation are the key to successful implementation. Often policy statements and objectives are unrealistic because there are inadequate and/or inappropriate resources available to deliver them. 4. The setting and publishing of OH&S objectives, even if only by internal notification' While the basic requirements and aims of health and safety management remain, the impetus of producing and reviewing an annual plan acts as a business focus. It also enables organisations to demonstrate to employees and other stakeholders how OH&S management is being developed. All employees should be aware of the objectives. 5. Place the management of OH&S as a prime responsibility of line management, from the most senior executive to first line supervisory level Including a safety objective as part of the annual management performance review reinforces this responsibility as well as maintaining an individual focus on your specific safety targets. 6. To ensure that the policy statement is understood, implemented and maintained at all levels in the organisation Any policy statement should be clear and concise and related to the activities of the organisation. Effective communication to staff at all levels throughout the organisation is vital. Initial induction training should be used to demonstrate to new staff from day one the genuine commitment of the organisation to OH&S management. 7. Employee involvement and consultation to gain commitment to the policy and its implementation. Involving employees is often neglected. In most, if not all industries, employees wish to contribute, positively to OH&S management to reduce the likelihood of costly incidents and/or claims. At the end of the day, they recognise that OH&S needs to be managed cost-effectively to maintain the security of their employment and the quality of their workenvironment. 8. Periodic review of the policy, the management system and audit of compliance to policy OH&S management cannot be compartmentalised. It must evolve continually as part of overall management philosophy to meet changing business demands, new legislation and new technology, as well as maintaining the complete involvement of all employees. 9. Ensure that employees at all levels receive appropriate training and are competent to carry out their duties and responsibilities. 13 It is a common misconception that the only employees needing training are those working at the sharp end. This is not the case: management at all levels need to understand their responsibilities and be competent to undertake the tasks they are required to perform. Training must be appropriate to the needs of each employee and to the positive benefit of the organisation. Training should not be a 'one-off but tailored to business demands and supported by appropriate refresher courses to maintain standards, Planning for Health & Safety Management From the outset, it is essential that there is commitment at the highest level within the organisation to the OH&S management system. The planning process should be based on a proactive approach, identifying those areas of risk that are not tolerable, and putting in place controls wherever this is deemed to be necessary. Planning for OH&S involves: Identifying requirements for the system - what needs to be done Setting clear performance criteria -what is to be done Identifying who is responsible - who gets it done Setting time scales – when it should be done by Identifying the desired outcome -what should be the result Both BS8800 and OHSAS 18001 identify three key areas which need to be addressed during the planning stage. Risk Assessment and Management The intent of this requirement is so that the organisation can appreciate all significant OH&S hazards facing it using the process of risk management. This is described in full in another part of this course. Legal requirements The organisation should identify all legal requirements applicable to it as well as any other industry or company specific requirements to which it subscribes 14 Health & Safety Objectives and Programmes Health and safety objectives are a major part of a management system and are defined as “the goals in terms of H&S performance that an organisation sets itself to achieve and should be quantified wherever practicable”. OH&S Objectives should be set annually. Examples of types of an OH&S objective include: The introduction of additional features into the OH&S management system (e.g. permit to work systems for specific tasks, strategic OH&S safety training for supervisors etc.) The improvement of existing features, or the constancy of their application across the organisation (e.g. accident reporting, communication of standard procedures etc.). The elimination or the reduction in frequency of particular undesired incidents (e.g. reduce accidents by 20%, remove all hazardous material etc.) Suitable indicators should be defined for each objective. These indicators should allow for the monitoring of the implementation of the objectives. Formal action plans should be drawn up for each OH&S objective that has been identified. These should form the basis of the business plans for each forthcoming year. The OH&S action plans should identify the: Individuals who are responsible for the deliverance of the objectives across the organisation and/or within each operation Various tasks that need to be undertaken in order to meet each objective. These action plans should be developed in consultation with the responsible person(s). Implementation & Operation For successful implementation and operation of an OH&S management system the following requirements should be addressed. Roles and Responsibilities At all levels within the organisation, people need to be aware of their roles and responsibilities. According to BS8800 the following aspects should be addressed: 1) Individual OH&S responsibilities should be clearly defined. Where job descriptions are used it may be appropriate to include such responsibilities. 2) All personnel should be given the authority and resources (including time) necessary to carry out their responsibilities. 15 3) Appropriate arrangements should exist whereby people are held accountable for discharging their responsibilities. 4) Reporting relationships should be clear and unambiguous. 5) Where personnel appraisal systems exist OH&S responsibilities should be included. Training & Competence The quarry should have effective procedures for ensuring the competence of personnel to carry out their designated functions. According to BS8800 the OH&S management system should include: 1. Systematic identification of the competencies required by each employee and the training needed to remedy any shortfall. 2. Provision of training identified as being necessary in a timely and systematic manner; 3. Assessment of individuals to ensure that they have acquired and maintain the knowledge and skills necessary for the level of competence required. 4. The maintenance of appropriate training/skills records. Ensuring the training and competence of employees is also a specific requirement of the Quarries Regulations, 1999 (Regulation 9). Consultation & Communication The organisation should encourage participation in, and support for, OH&S, from all those affected by its operations, by a process of consultation and communication. BS8800 states that organisations need to ensure that they have effective arrangements for: A. Identifying and receiving relevant OH&S information from outside the organisation including: 1. New, or amendments to legislation; 2. Information necessary for the identification of hazards and evaluation and control of risks; 3. Information and developments in OH&S management practice. B. Ensuring that pertinent OH&S information is communicated to all people in the organisation who need it. This requires arrangements to: 1. Determine information needs; 16 2. Ensure that these needs are met, bearing in mind the legal requirement that relevant information has to be provided in a form and manner that is comprehensible to the person receiving it. 3. Ensure that information does not just flow from the top down, but also from the bottom up and across the various parts of the organisation. 4. Avoiding restricting OH&S items to dedicated OH&S meetings by including them on the agenda of a variety of meetings wherever appropriate. 5. Report hazards and shortcomings in OH&S arrangements; C. Ensuring that relevant information is communicated to people outside the organisation who require it. D. Encouraging feed-back and suggestions from employees on OH&S matters. Documentation The organisation should document, and maintain up-to-date sufficient documentation to ensure that its OH&S management system can be adequately understood and effectively and efficiently operated. This requirement will be covered later in the course as it is analogous to Regulation 7 of the Quarries Regulations, 1999 which require the production of a health and safety document. Operational Control The organisation should establish and maintain arrangements to ensure that activities are carried out safely. These arrangements should be based on the results of the risk assessment, and any health and safety objectives that have been defined. Depending on the results of the risk assessment these arrangements could be in the form of instructions, rules and procedures, which are a specific requirement of the Quarry Health and Safety Document (Regulation 7) and Regulation 10 of the Quarries Regulations, 1999. The organisation should also plan and prepare for all foreseeable accident, incident and emergency situations. This again should be based on the risk assessment and is a requirement of Regulation 15 of the Quarries Regulations, 1999. 17 Measuring Performance “If you can’t measure it, you can’t manage it.” - Peter Drucker “Management will attach an increased dimension of importance to anything that is quantified.” - Frank E. Bird “Performance measurement and motivation are almost synonymous.” - Dan Peterson “What gets measured gets done.” - Thomas J. Peters Performance measurement is an essential part of a OH&S management system. According to BS8800 and OHSAS 18002 the key purposes of measuring performance are to: 1) Determine whether OH&S plans have been implemented and objectives achieved; 2) Check that risk control measures are in place and are effective; 3) Learn from system failures such as areas of non-compliance, accidents and incidents. 4) Promote the implementation of plans and risk controls by providing feedback to all parties 5) Provide information that can be used to review, and if necessary to improve aspects of an OH&S management system. An organisation’s performance measurement system should incorporate both active and reactive monitoring as follows: Active measuring systems should be used to check compliance with the organisations OH&S activities. Examples of active monitoring data are: The extent to which plans and objectives have been set and achieved. Whether a director for OH&S has been appointed. Whether a safety policy has been published. Extent of compliance with statutory requirements Frequency of OH&S audits Frequency and effectiveness committee meetings. OH&S specialist reports Health Surveillance reports 18 of OH&S The numbers trained in OH&S Workplace exposure levels Number of risk assessments completed Personal protective equipment use. Extent of compliance with risk controls Reactive monitoring should be used to investigate, analyse and record OH&S management system failures, including accidents and incidents. Examples of reactive monitoring data include: Unsafe Acts Sickness absences Unsafe conditions Criticisms made by regulatory agency staff Near misses Complaints made by members of the public. Lost time accidents Major accidents & fatalities Investigating Accidents and Incidents Organisations should have procedures for both the reporting and investigating of accidents and incidents. The prime purpose of these procedures should be to prevent further occurrence of the situation by identifying and dealing with the root causes. Accident and Incident Investigation is covered later in this course. Auditing OH&S auditing is a process whereby an organisation can review and continuously evaluate the effectiveness of their OH&S management system. Safety auditing is a positive and proactive means of checking the safety performance of an organisation. The general principals of auditing below are based on those given in OHSAS 18002. Scheduling An annual plan should be prepared for carrying out internal safety audits. The safety audit should cover the entire operation which is subject to the OH&S management system, and assess compliance with OHSAS 18001. Audits should be carried out according to a written procedure, and only by competent independent personnel. The results of the audits should be recorded and reported to management. A review should be carried out by management and effective corrective actions(s) taken, where necessary. 19 Management Support For OH&S auditing to be of value, senior management should be fully committed to the concept of auditing and its effective implementation within the organisation . This includes a commitment to consider audit findings and recommendations and to take appropriate action as necessary, within an appropriate time. Once it has been agreed that an audit should be carried out it should be completed in an impartial way. All relevant personnel should be informed of the purposes of auditing and the benefits. Staff should be encouraged to cooperate fully with the auditors and to respond to their questions honestly. Audits Audits provide a comprehensive and formal assessment of the organisation’s compliance with OH&S procedures and practices. The end result of an audit should include a detailed written assessment of OH&S procedures, the levels of compliance with procedures and practices and should where necessary identify corrective actions. Auditors One or more persons may undertake audits. A team approach may widen the involvement and improve co-operation. They should be independent of the part of the organisation or the activity that is to be audited. Auditors need to understand their task and be competent to carry it out. Thy need to have the experience and knowledge of the relevant standards and systems they are auditing to enable them to evaluate performance and identify deficiencies. Auditors should be familiar with the requirements set out in any relevant legislation. In addition, auditors should be aware of and have access to standards and authoritative guidance relevant to the work they are engaged in. Data collection and interpretation The techniques and aids used in the collection of the information will depend on the nature of the audit being undertaken. The audit should ensure that a representative sample of essential activities is included in the audit and various personnel should be interviewed. Relevant documentation should be examined. This may include. OH&S management system documentation OH&S Policy statement OH&S emergency procedures 20 Permit to work systems and procedures Minutes of OH&S meetings Accident/Incident Reports and records Training records Reports or communication with the enforcing authority Wherever possible checks should be built into the system to help to avoid misinterpretation or misapplication of audit records. Audit results At the end of the audit, and before submitting their report, the auditor or the Audit team should hold a meeting with the responsible manager of the audited area. The main purpose of such a meeting is to communicate the results of the audit to the responsible manager in order to ensure that it is understood and agreement is reached. Minutes should be kept of such meetings. The content of the final audit report should be clear, precise and complete. It should be dated and signed by the auditor. It should, depending on the case, contain the following elements: The audit objectives and scope the particulars of the audit plan, identification of the members of the auditing team and the audited representative, dates of audit and identification of the area subject to audit; The identification of reference handbooks used to conduct the audit; The cases of non conformance. The auditors assessment of the degree of conformity to OHSAS 18001 The ability of the OH&S management system to achieve the stated OH&S objectives The results of all audits should be fed back to all relevant parties as soon as possible to allow corrective actions to be taken. As many employees as possible., including the employee safety representative where selected, should be consulted on activities in their area during each audit. An action plan of agreed remedial measures should be drawn up 21 together with identification of responsible persons, completion date, and reporting requirements. Follow-up monitoring arrangements should be established to ensure satisfactory implementation of the recommendations. 22