1. Health and safety management systems
The “How” not the “Why”!
Steve Pearce

2. 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

3. The Health and Safety at Work Etc
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.

4. Legislation goal setting
The Management of Health and Safety at Work Regulations 1999
Health and safety arrangements
5.  (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;

5. 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

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PAS 55 (now superceded by ISO Asset Management),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

7. 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.  

8. 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”) …….

9. How – focus areas Leadership Roles and responsibilities Permits
Organisational memory
Ownership
Touching the surface
Many more suggestions in this room

10. Leadership Leadership behaviours Test them Review and change
Establish what you expect of people
Survey – example
Test them
Individually
As a group
Review and change
Baseline and movements
Target areas.

11. 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”

12. Leadership questionnaire results

13. Roles and responsibilities
How are roles and responsibilities assigned in your organisation?
Job descriptions
Role profiles
Procedures, systems ….

16. 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

17. The right way to do activities
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
Review before use
Sign-off
Training
Competence 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

18. 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.

19. 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.

20. Permit health checklist
Authorisation
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
ensuring the proper authorisation of designated work.
making clear to people carrying out the work
the exact identity, nature and extent of the job and
the hazards involved, and
any limitations on the extent of the work and the time during which the job may be carried out;
specifying the precautions to be taken, including safe isolation from potential risks such as hazardous substances, electricity and other energy forms
ensuring that the person in direct charge of a unit, plant or installation is aware of all hazardous work being done there;
providing not only a system of continuous control, but also a record showing that the nature of the work and the precautions needed have been checked by an appropriate person or people;
providing for the suitable display of permits
providing a procedure for times when work has to be suspended, ie stopped for a period before it is complete ;
providing for the control of work activities that may interact or affect one another ;
providing a formal handover procedure for use when a permit is issued for a period longer than one shift ;
providing a formal hand-back procedure to ensure that the part of the plant affected by the work is in a safe condition and ready for reinstatement;
providing a process for change, including the evaluation of change on other planned activity, a determination of when hazards need to be reassessed, and a means for controlled communication of change.
How does your permit system stand up against these requirements?

21. 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

22. 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”

23. Standards Systems engineering Suggestion
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

24. Standards Suggestion It cannot be done? 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 –
it is unreasonable in all the circumstances for it to be dead; and
it is reasonable in all the circumstances for him to be at work on or near it while it is live; and
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?
I’m sure Windsor will have a view and it may not coincide with mine.
But debate is positive.

25. 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”

26. 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

27. Ownership Working definition Key tool in the Safety Pro’s tool kit
“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

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

29. 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

31. 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.

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