Health and safety management systems

The “How” not the “Why”!

Steve Pearce

Structure

• Goal setting and the “Why”!• “Why” to “How” – the cycle• Key focus areas– Leadership– Roles and responsibilities and competence– Permits and standards– Organisational memory– Ownership

• Conclusion

• The Health and Safety at Work Etc. Act is a goal setting piece of legislation

• This goal setting approach is mirrored in the Regulations.

• Many standards reflect the approach leaving the difficult work to the “user” to work how how he will achieve the goal.

Legislation goal setting• The Management of Health and Safety at Work Regulations 1999

– Health and safety arrangements5. (1) Every employer shall make and give effect to such arrangements as are appropriate, having regard to the nature of his activities and the size of his undertaking, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures.

• The Construction (Design and Management) Regulations 2007– Competence

4. (1) No person on whom these Regulations place a duty shall—(a) appoint or engage a CDM co-ordinator, designer, principal

contractor or contractor unless he has taken reasonable steps to ensure that the person to be appointed or engaged is competent;

Standards goal setting• BS OHSAS 18001:2007

• There is clear accountability in the management structure• Legal and other requirements which apply to all activities

are identified and the relevant documents are held• All personnel working for, or on behalf of, the organization

are aware of their individual responsibilities• A training, awareness and competence assessment

programme is in place for personnel working under its control

• Emergency response takes into account the needs of relevant interested parties and is periodically tested

ISRS• Extract from ISRS7 Omega audit workbook (Eight version launched in 2009)

• Process 10 – Asset management– 10.1.1

• Does the organisation have a comprehensive register(s) of physical assets for the following categories• Land and natural resources• Civil structures• Pressure and non pressurised systems ….

• Guideline– The maintenance programme describes the maintenance regime for each asset in the asset

register. The asset register should be a complete listing of all facilities and equipment to be maintained.

• Linkages– PAS 55 (now superceded by ISO 55001 Asset Management), – ISO 9001 (under review. End 2015 for new standard),– ISO 14001 (under review. Early 2015 for new standard)– and OSHAS 18001

ISRS “Book of knowledge”• The ISRS Book of Knowledge is an evolving web

resource to support the implementation of safety and sustainability management systems using ISRS

• 1.8. Accountabilities– 1.8.2. Appoint System Owner

• The system owner is usually a senior manager who reports directly to the most senior manager on site.

• He has responsibility for the development and maintenance, but especially the interaction and effectiveness of the business processes including HSEQ activities and has a vital role in supporting all business process owners.

Dave Brailsford

• Vision – Most successful British Cycling team ever• Desired outcomes – Win Tour de France and “X” Gold

medals• Performance goals – The “What”. Eg. complete the

pursuit in a given time. Power output over time …• The “Hows” – Granular detail on deploying the

systems– Marginal gains

• Hand washing, Pillows, best equipment, wind tunnel, fitness, training, support, the tour bus, sports science and measurement, sports psychology (your inner “chimp”) …….

How – focus areas

• Leadership• Roles and responsibilities• Permits• Organisational memory• Ownership

• Touching the surface• Many more suggestions in this room

Leadership

• Leadership behaviours– Establish what you expect of people– Survey – example

• Test them – Individually– As a group

• Review and change– Baseline and movements– Target areas.

Leadership behaviours• What are your expectations?• Some suggestions :-

– Right organisation with the right level of competence– H&S part of appraisal– Sets standards– Visibility– The leader cares.– Communication– What he does reflects his approach to H&S– Recognise and reward, correct and challenge

• “ I can’t hear what you are saying because I am deafened by your actions”

Leadership questionnaire results

Roles and responsibilities

• How are roles and responsibilities assigned in your organisation?

• Job descriptions• Role profiles• Procedures, systems ….

Roles and responsibilities• Performance standards. Some examples

– Management• Leadership, engagement, competency, monitoring, review

– Major accident hazards scenarios• Awareness, Safety critical procedure deployment and monitoring, measures

in place deployment and monitoring– Risk control systems

• Management of change, process gas control, permits, procedures, – Asset management

• Maintenance programme, maintenance review, pressure systems, lifting equipment, process excursions, routine maintenance (stat or policy), safety related control systems,

– Emergency preparedness• Roll call/accounting, Site incident controller, Site major controller, Works

executive action team, Emergency procedures, alarms, equipment, gas refuges, fire fighting roles

Shift Manager – Roles and

Responsibilities

Procedures

Section Leader / Shift Engineer –

Roles and Responsibilities

Senior Operator / Leading Hand –

Roles and Responsibilities

Process Operator Craft Team Member

- Roles and Responsibilities

Procedure for Emergencies

Normal Operations

Usual Events e.g. Start-up / Shutdown

Special / one-off / rare events and

procedures

Training Manual

Checklists

Job-Aids

Troubleshooting

Checklists

Review before use

Sign

-off

Sign

-off

TrainingCompetence

Assurance

Performance Review

Training Needs Identification

Training Programme

HSE 7 Step Process

Human Failure Assessment

Task Based Risk Assessments and SWPs

COMAH RA and Predictive Work

PHR / LOPA

HAZOP

What we expect of roles

The right way to do activities

How we communicate the right way to do activities

How we check activities are done right

How we improve the way we do activities

Permits

• How many of you have one or more permit systems?

• How long have they been in place?• What issues do they cover?

• Permit to work system definition (HSG 250)– A permit-to-work system is a formal recorded

process used to control work which is identified as potentially hazardous.

Permit system generation• “We designed it long ago and we have used it to good effect since”• “It’s grown as we have progressed”.• Systematic approach to identification of the need for a permit

– Risk portfolio– Legislation– Guidance

• When is a permit system required?– non-production work (eg maintenance, repair, inspection, testing, alteration,

construction, dismantling, adaptation, modification, cleaning etc);– non-routine operations; – jobs where two or more individuals or groups need to co-ordinate activities to

complete the job safely; – jobs where there is a transfer of work and responsibilities from one group to

another.

Permit health checklistAuthorisation Record

Identity, nature and extent or work Display

Process to communicate to the people carrying out the work

System for planning, completion and issue

Hazards Suspension procedure

Limitations Procedure for interacting activities

Time Formal handover procedure

Precautions to be taken Formal hand back procedure

Person in direct charge aware Process for change

System of continuous control Hazard reassessment

Work and precautions checked by appropriate persons(s)

Process to communicate change

How does your permit system stand up against these requirements?

Permit system reviews

• Agenda– Incident and accident learning– Permit system checklist report– System description – Central and local ownership– Monitoring strategy– Audit strategy– Best practice identification

Standards• What are standards?• Definition• Standards with a capital “S”.• Standards with a small “s”.

• Working definitions– “Circumstances I am not prepared to walk past”– “What I accept and what I show through my actions that I

do not accept.”– “The systems procedures and arrangements we have in

place in our organisation”

Standards

• Systems engineering– Attempting to ensure that they reflect reality and

work– But our work area is complex and do we really want

systems that are as complex?• Understanding• Training workload• Agility

• Suggestion– Engineer to address 80% and manage the rest by

exception

Standards• Illustration• Arrangements for live working on electrical systems• Reg 14. EAW Regs 1989

– No person shall be engaged in any work activity on or so near any live conductor (other than one suitably covered with insulating material so as to prevent danger) that danger may arise unless –

(a) it is unreasonable in all the circumstances for it to be dead; and (b) it is reasonable in all the circumstances for him to be at work on or near it while it is live; and (c) suitable precautions (including where necessary the provision of suitable protective

equipment) are taken to prevent injury.

• Suggestion– Set a standard that says no live working.– Manage deviations by exception– Put in arrangements to manage those situations where you must work live

• Case to work live made• Suitable precautions in place

• It cannot be done?– So the alternative is to rely on the specific training and standards in individual

electrically competent staff and their decision making?

Organisational memory

• Cardiff contractors in court over worker’s roof plunge– A Cardiff building contractor has been fined for

breaking safety legislation after a young worker broke his back in a seven-metre fall through an unprotected hole in a roof.

• “We must ensure this never happens again”

Organisational memory

• Audit protocols• Risk assessment – Reference database– HAZOP processes• Formal link between process and events

• Training and competence• War stories• Exit and retirement strategy

Ownership

• Working definition– “Someone who loses sleep if the system/process/issue

they own is not being properly managed”• Key tool in the Safety Pro’s tool kit

Ownership

• But before you look at others, I suggest that you be clear about what you own and how you are managing it!

Benchmarking• Internal – best practice• External - Rank Xerox model• What?

– Get the right product to our customers at the right time and place.• How?

– Benchmarked sports good supplier• Staged benchmarking process developed

– Understand the problem– Understand the issues and who is best at managing them– Define the “as is”– Develop a system for the Benchmarking visit and information – Take action on return

Conclusion

• There is a great wealth of advice on the “Why” and “What” in health and safety– You probably already know the “why” and the

“what”

• The real benefit is in the “how”• Look to people who have developed the

“how” and have an implementation track record.

Steve Pearce – Mobile: 07885 660952

Web site: www.bprm.biz