The Health and Safety Audit – Chemical Industry Experience
JFA
Basis of Presentation
 The following notes are based on experience of audits in the
Chemical Industry – both operational audits and acquisition due
diligence.
 Much of the experience in this field has been for a multi-site
international manufacturer based in Australia, and has covered sites
in the UK, France, Spain, Austria, The Netherlands, Egypt, the USA,
and Canada.
 The plants concerned involve medium scale organic synthesis, are
not large, but are complex, and use a wide range of flammable, toxic,
corrosive and environmentally sensitive materials.
 Based on a multi-site organisation, it is nevertheless relevant to any
large industrial enterprise with multiple operations.
 It is not unusual to combine such audits with a simultaneous audit of
environmental issues.
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Preamble
A gentle disclaimer
The author has little knowledge of, and no
experience of High Energy Physics facilities. It is
hoped however that the audience can draw
something useful from experience in a world where
molecules are of more concern than are particles.
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
Typical factory layout
John Freeman Associates 2005
JFA
The Health and Safety Audit – Chemical Industry Experience
A selection of typical plant details
John Freeman Associates 2005
JFA
The Health and Safety Audit – Chemical Industry Experience
JFA
What is it?
It’s a bit like a financial audit

Similarities
 It provides an external overview
 It aims to confirm due propriety of “internal” procedures

Differences
 It is Management initiated – not a regulatory imposition
 A principal aim is improvement, training and development
 The downside is human suffering – not negative dollars!
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Why do we have them?
 To justify fine words in policy statements
 A duty of care to employees and neighbours
 To reduce risks to the business of untoward events
 Management being seen to be serious about safety
 For consistent interpretation of management policy
 To improve safety by training and development
 Internal cross-fertilisation of experience and ideas
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Corporate Concerns
Hatfield UK
High Speed
Derailment
Oct. 2000
July 10 2003
Two rail companies and six of their
executives and staff have been charged
with manslaughter following a
police investigation into the 115 mph
Hatfield rail crash…….
Four fatalities and 100 injured
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Where in the overall safety scheme of things?
Tools for Ensuring Safety
MAJOR
HAZARDS
DESIGN
Hazard Analysis
Risk Analysis
HAZOP
Protection Systems
Design
Team
John Freeman Associates 2005
OPERATIONAL
INTEGRITY
WORKPLACE
SAFETY
SYSTEMS
Procedures
Reporting
Statistics
Support
ACTIVITIES
Housekeeping
Vigilance
Notification
Compliance
Health and Safety Audit
Inspection
Tour
The Health and Safety Audit – Chemical Industry Experience
JFA
Who is involved?
Typical Organisation Structure
Group
Management
Group HSE
Manager
Data and
Statistics
Site A
Management
Safety
Officer
Operations
John Freeman Associates 2005
Site B
Management
Safety
Officer
Operations
Third Party
Independent
(Occasional)
Audit Team Site B
Group HSE Manager (Chair)
Safety Manager
Operations rep (varies)
Management rep
Site A rep (option)
(Third Party Independent)
The Health and Safety Audit – Chemical Industry Experience
JFA
How do we go about it?
Typically annual, the main steps are:
1 – Collation of statistics and comparative performance review
2 – Circulate self-audit questionnaire to each site
3 – On-site review of responses and Action Progress
4 – Site tour by Audit Team
5 – Round up discussion and Action Plan
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
What is the Auditor looking for?

Throughout the process, the Audit Team should be
asking itself:
Are Systems and Procedures appropriate and adequate?
Are Systems and Procedures correctly followed?
Are the correct Documentary Records available?
Are the H&S Facilities and Equipment appropriate and
adequate?
 Is there a general awareness of Safety as an issue?
 Is there a programme for safety training?
 Could the organisation respond to a serious emergency?

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John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Typical Audit Team

Leader – Senior Safety Manager
 Responsible directly to Top Management (e.g. Group Board)
 Not responsible for operations

Local personnel
 Local safety officer and a management representative
 Operating supervisor of a specific area under review
 Visiting representative from another site/area

Others (if needed)
 To give full experience cover of specialist technology and
general operation/engineering (e.g. Chemist + Engineer)

Independent Neutral (Say every third audit or so)
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Actions and Feedback

Action Programme to correct deficiencies identified
 Agreed actions (Where the team has authority to decide)
 Recommended Actions (If 0ther authorisation is needed)
 Include Target dates

Progress Reviews of previous action programme



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Record Completions
Provide early prompts
Highlight missed dates
Record decisions not to proceed – with reasons
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Safety Statistics
To be meaningful, statistics must be consistent and accurate
 Typical statistical analysis would include
 Injury Frequency Rates – Lost time, Medical treatment
 Injury Severity Index – extent of lost time
 Injury analysis - by type, location, worker group
Central recording and analysis ensures consistency
Care with definitions such as “Lost-time injury” – how many days?
Figures are only useful if lessons are learned and improvement targets imposed
Rigorous recording is essential
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Procedures – availability and adherence
Defined procedures must be set down

Standard Operating Procedures





Default procedures for all main operations
Are they Available, Accessible and Clear
Use them or change them – don’t ignore them
Obtain user views
Maintenance Safety Procedures
 Permit to Work System – hot work, confined spaces, heights
 Isolation and Lock-off arrangements – a critical area
 Authority to sign – training essential
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
Training Procedures

Safety Training
 Management, Factory workers, Office workers
 Specialist functions (e.g. Fire, Rescue)

Induction programmes



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New Employees
Temporary Employees
Contractor’s personnel
Visitors
John Freeman Associates 2005
JFA
The Health and Safety Audit – Chemical Industry Experience
JFA
Safety Systems
Some of the more important Systems to check

Change Control System
 Design vetting of any modification to plant, process or alarm and
trip functions

Accident Reporting, Investigation and Remedial Actions

Abnormal Incident Reporting
 Reporting, Investigation and Remedial Actions as for Accidents

Inspection and Testing programmes
 Pressure Systems, Lifting Equipment, Access Equipment, etc.
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Change Control
Flixborough – UK 1974
Plant modification destroys
original design integrity
Failed flexible connector
Aftermath
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Emergency Procedures
Investigate preparedness for emergencies

Response Plan for a major emergency
 Does it exist and is it well known and understood
 Liaison with local services – e.g. Fire Service?

Internal Emergency Actions
 Fire fighters – trained? equipped?
 First aiders – availability and training
 Evacuation drill – clearly posted? practiced?

Notifications – to management, authorities, local services
 Nominated person? Standard routine?
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
Health and Safety Facilities

First aid
 Location and Equipment
 Trained personnel and call-out arrangements

Fire fighting and Rescue
 Extinguishers, breathing equipment, trained personnel

Security
 Visitor control – record of people on the site
 Intruder prevention
John Freeman Associates 2005
JFA
The Health and Safety Audit – Chemical Industry Experience
JFA
Health monitoring policy
Requirements depend on local circumstances

Occupational Health Issues
 General medical checks and hearing tests
• On first employment
• At regular intervals

Specific Risk Areas
 Exposure to chemicals – measurement of ambient levels
 Known potential health hazards
• Biological checks
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
JFA
Some general comments

Avoid a “blame” culture
 Encourage positive approach
 Inter site participation helps

Numerical basis for performance assessment
 Not generally successful unless based on objective measures
 Subjective assessment is not usually satisfactory

Site visits help to reinforce comments
 Photographs of areas of concern

Review meetings are as much about Training as
Communication
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
Especially Vulnerable Situations

Growth by Acquisition

High Staff Turnover

Regular use of Temporary Staff

Extensive use of Contractors

Language Differences
John Freeman Associates 2005
JFA
The Health and Safety Audit – Chemical Industry Experience
JFA
In Conclusion
A systematic and regular audit of Safety Systems
and Performance can lead to significant improvements.
Benefits include:
Consistent and effective implementation of policy.
Protection against corporate exposure.
Reductions in accident rates.
Improvements in Safety Training and Development.
Cross fertilisation in Safety thinking.
Increased awareness of the importance attaching to Safety issues.
John Freeman Associates 2005
The Health and Safety Audit – Chemical Industry Experience
Don’t be like this guy!
John Freeman Associates 2005
JFA