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 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 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;

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 Linkages PAS 55 (now superceded by ISO 55001 Asset Management), ISO 9001 (under review.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 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.

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

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

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 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?

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 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

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.

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 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

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