Scenario
You
have a dual role as an experienced and respected Process Operator and a
representative of workers at a large, high hazard site, run by an international
chemical manufacturing organization.
The
organization has a reputation for having a world-class health and safety
culture, with many other industries using them as a benchmark. It is a legally
compliant organization that sets clear objectives and checks that they are met.
It employs and retains motivated workers who are aware of their clearly defined
and documented responsibilities and want to continuously improve in their
roles. Absence and sickness rates are low.
The
organization listens to workers when they raise concerns and responds
professionally to external customer complaints. The organization also takes
pride in recording low accident and incident rates and investigating any near
misses to learn lessons and prevent more serious outcomes. Across the
organization, there are clear lines of internal and external communication.
This allows effective resolution of complaints. The organization is fully
insured even though the premium is high. The organization conducts frequent
internal audits and is also externally audited.
The
process you operate is running at a reduced production rate, due to a technical
problem with a large storage tank containing a highly toxic product. You have
an idea what the problem is, but knowing the limits of your authority, you feel
the issue should be escalated to someone more senior. Local site managers,
engineers, supervisors, and operators meet to discuss the situation. They
conclude that the tank has an internal blockage, that would normally require a
complete process shutdown to clear. However, the planned maintenance shutdown
is 12-months away. They decide to seek advice from the corporate management
team to explore whether there is a different solution that would resolve the
blockage problem but keep production going.
The
local site and corporate management teams meet by video conference. The
corporate management team includes a very experienced senior engineer with
25-years’ company service. This engineer has overseen process plant
modifications, at many international sites, with zero lost-time incidents. They
all agreed that modifications could safely be made to the tank, without the
need to shut it down, and that the necessary resources would be made available
for this work.
The
senior engineer is sent to the site to advise on, and manage, the changes that
are needed to the tank; and on the day of arrival presents a solution to you.
You are unfamiliar with the technology to be used for the modification and your
reaction is one of disbelief, and you politely ask if the engineer is serious.
The engineer invites you to a meeting to conduct a systematic and detailed risk
assessment of the tank modification task. The Health and Safety Adviser, worker
representatives, and Plant Manager will also be at the meeting.
At
the meeting, the engineer introduces the proposed tank modification and leads
the risk assessment exercise. The risk assessment includes consideration of the
highly toxic chemical, the release of which would be catastrophic for workers,
as well as people in adjacent businesses, residential houses, and schools.
The
engineer confirms that this proposed modification method is a safe and widely
used solution where the safety improvements are worth the cost. The risk
assessment then continues with discussion and agreement on risk evaluation,
existing control measures, and any additional control measures necessary. Some
of these control measures include safe systems of work, a permit-to-work
system, supplementary emergency arrangements, and suitable induction training
for all contractors. Collectively, these precautions and control measures
reduce high risk to low risk.
A
summary of the risk assessment is circulated to all workers likely to be
affected by the proposed modification. The full version of the risk assessment
will be made available on request.
Before
commencing the work, a permit-to-work is issued to the contractors carrying out
the tank modification. The permit-to-work includes an explanation about the
associated risk assessment and how the plant has been safely prepared for this
non-routine modification. The contract workers accept the permit-to-work with
the necessary precautions, including wearing of specified personal protective
equipment. Precautions listed on the permit-to-work are also communicated to
all contractors and other plant workers who may be affected. The permit-to-work
explains that precautions will be enforced, along with any other site rules, by
active monitoring. This will be done while you carry out routine plant checks
and simultaneously check on the progress of the modification.
To
confirm safe working and clarify overall expectations, you, along with an
independent site contact have been nominated to monitor and liaise with the
contractors. The independent site contact will also actively monitor and check
additional expectations, such as contractor site entry and exit control,
resolution of any queries, and the supervision standard. You and the
independent site contact will check to see whether the modification work is
being controlled and is progressing as planned. This is consistent with the
organization’s safe system of work based on the findings of the risk assessment
and the method statement provided by the contractor, the aim is to complete the
job safely without incident.
Findings
from inspections form part of the overall health and safety performance review.
The performance review enables an overall assessment of opportunities for continuous
improvement within the site and reveals any need for change.
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Task 1: Comment on the organization’s health and
safety morals. |
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The organization provides an ethical way to do work by providing good health and safety culture: It has a world-class health and safety culture, which is used as a benchmark by other industries. The
organization considers humanitarian ground as its moral responsibility to
provide a safe workplace: The organization listens to workers when they raise
concerns and responds professionally to external customer complaints. The
organization is fully insured even though the premium is high to safeguard
the interest of both employee and employer. The organization has a moral obligation not to cause harm to others: The organization has moral reasons and societal expectations of providing
occupational accident and disease-free work environment to all
workers so that everyone returning home happily in a healthy condition: The
organization conducts frequent internal audits and is also externally audited
to maintain good health and safety management. The
organization has an approach to do in a right way to do the things rightly: There is equality and the right to live for all workers and equal
treatment in aspects of health and safety. Workers get killed when
health and safety are not managed properly managed. Organizations investigate
any near misses to learn lessons and prevent more serious outcomes. As a
result, very low accident and incident rates were recorded. |
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Task
2: Comment on the evidence from the scenario that would contribute to the
effectiveness of the roles and responsibilities |
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Following
evidence contribute to the effectiveness of my roles and responsibilities as
dual role Process Operator and worker’s representative: As I have dual roles and
responsibilities, I have the advantage of knowing the process better and
if any issues related to health safety are observed I shall immediately
approach senior management for possible safe solution. When a
technical problem with a large storage tank containing a highly toxic product
arises, I immediately informed the senior management. As constituents
of safety committee personnel as worker’s representatives, the technical issue is consulted with
local site managers, engineers, supervisors, and operators and also with the
corporate team to have a safe solution for tank modification work. To understand the risks
associated with the work, meeting with a senior engineer for specialist
advise conducting a systematic and detailed risk assessment of the
tank modification task. Providing
supervision to workers and
contractors for implementation of control measures like safe
system of work, permit to work, and suitable emergency arrangement for tank modification work. Circulation of risk
assessment to all workers who may be affected by the proposed tank
modification. I
will also inspect the work and enforce to allocate adequate resources being issued
to the contractors as agreed in the permit to work, like wearing of
specified personal protective equipment. As I have been nominated
with an independent site contact to confirm
and monitoring safe working and consultation with the contractor. I
will participate
inactive monitoring by doing the inspection for contractor
site entry and exit control, resolution of any queries, and the supervision
standard. I will enforce
organization’s safe systems of work procedures based on the findings
of the risk assessment and the method statement provided by
the contractor to complete the tank modification job safely without incident. |
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Task3:
Based on the scenario only, what are the indicators of health and safety
culture in the organization? |
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The
indicators of health and safety culture in the organization shows positive as
mentioned below: Incidents or
Accident records:
Organisation conducts proper investigating
of any near misses to learn lessons and prevent more serious outcomes as
a result low accidents and incident rates were recorded. Absenteeism: The
organization employs
motivated workers who are aware of their roles and responsibilities,
as a result, less absence from work is reported. Sickness rates: Since world-class health & safety
culture is provided with implementation of the safe system of work,
allocation of proper PPE, lesson learned from the investigation, the
sickness rate is less recorded. Staff turnover
rate: As workers
are motivated and experienced, fewer incidents and low accidents
were reported in high hazard site, workers morale is high
less staff turnover is reported No Blame
culture: No fear of reprisal to the workers and are encouraged to report concerns on
health and safety aspects. Across the
organization, there are clear lines of internal and external
communication was defined for the effective resolution of complaints. Level of compliance
with health and safety rules: organization complies with all rules and regulations.
For this, they set specific objectives and regular checks were
made to achieve the targets. Procedures: The
importance is
given to the implementation of control measures like safe
systems of work, a permit-to-work system, supplementary emergency
arrangements after detailed risk assessment were conducted for tank
modification work. Importance to
Risk Assessment: Detailed
risk assessment is conducted for tank modification work considering
the highly toxic chemical and its release which would be catastrophic for
workers, as well as people in adjacent businesses, residential houses, and
schools. A summary of the risk assessment is circulated to all workers
likely to be affected by the proposed tank modification work. Complaints about
working conditions: The
organization listens to workers when they raise concerns.
Organisation also responds professionally to external customer
complaints about effective resolution. Strong
leadership & Management: Organisation
provides world-class health & safety culture which is used as a benchmark
by other industries. The organization is fully insured even though the
premium is high to safeguard the interests of both employee and employer. Adequate
allocation of resources: Organisation employed
experienced an expert engineer from the corporate management team
with zero lost time incident to oversee the process of
tank modification works. Management has also enforced necessary
precautions, including the wearing of specified personal protective equipment
to the contractor as part of the permit to work conditions. Worker
consultation & participation: Competent
experienced process operator as representative of the worker. Due to this, the worker
can easily approach and give feedbacks related to health &
safety aspects. Since worker representative is experienced operator, he can
easily understand the technical problem of operation and can easily
approach the senior management for possible solutions. Prompt
investigation of incidents and accidents: Organisations investigate
of all near misses to learn lessons and prevent more serious outcomes. The
organization conducts frequent internal audits and is also externally
audited to comply with all non-conformities related to incidents and
accidents Commitment to
H&S at all levels: To
confirm safe working and clarify overall expectations of permit to work,
organization nominated worker representative and an independent site contact
to monitor and liaise with the contractors. Teamwork (Peer
Group) among all levels of management: There is a possibility Peer group pressure can
be harnessed to encourage good safety-related behaviour. As an organization
review its health and safety performances from the findings of active
monitoring inspections for continuous improvement opportunities can be
sourced. |
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Task
4: Other than a general improvement of health and safety, what specific
reasons are there for this
organization to learn lessons from incidents? |
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Specific
reasons organization can learn lessons from incidents are: Prevent
future accident: Organisation can prevent future
accident-related to tank modification to prevent blockages by learning
lessons obtained during the implementation of permit to work system. A new modification
process may help the organization to perform without doing a shutdown. To
increase awareness and competence: Suitable
training modules will be available to the organization for implementing the
tank modification work, which was learned from the previous tank
modification incidents. This will safeguard employees from highly toxic
chemicals and may reduce worker sickness rates. Prevent
reoccurrence: To
remove the blockage of the tank available solution of the tank will be
present in the organization. Modifications can be safely made to the tank and
that all the necessary resources will be available for this work in the
future. Improves
business reputation: Organisation can set
new health & safety benchmarking standards for others for
implementing a safe system of work related to tank
modification without complete process shutdown. Reduce
Staff turnover rate: By learning lessons workers
will be more aware, more motivated and have more confidence in the
system, so the staff turnover rate will reduce. Cost-effectiveness
in managing risks: By
understanding the underlying and root causes from the
incident, health and safety risk can be managed cost-effectively. Comparison of
own system: Knowledge
learned from incidents will allow for comparison with the effectiveness of
own systems. Encourage
creative solution: Workers,
supervisors, operators, managers involved in modification work will have
hands-on experience and can provide opinions and creative solutions
for further tank modification processes. Improve
organization key performance Indicator: From the findings of active monitoring
inspections, opportunities for continuous improvement
can be implemented. Site managers, engineers, supervisors, and operators will
be aware of new risks. New performance indicators can be assigned for
managing health and safety systems. Confidence to
Various Stakeholders: Lesson
learned from the tank modification incident will bring confidence to various
stakeholders on health and safety management system. |
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Task 5: Based on the scenario only,
comment on whether the risk
assessment is ‘suitable and sufficient in the following areas: - (a) who
might be affected. (b) the precautions are reasonable, and the remaining
risk is low |
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Answer
5(a): - As per HSG65 Risk assessment is suitable
and sufficient as it is completed and headed by a competent
very experienced senior engineer who has 25 years of
experience from a
corporate management team with zero lost time incident
for tank modification work. Health and safety adviser, worker
representatives and plant managers were also involved during the
preparation of risk assessment. The
risk assessment considers activities taking consideration of who
might be harmed and affected due to the tank modification. Risk
consideration of the highly toxic chemical, the release of which
could harm the workers, as well as people in adjacent businesses,
residential houses, and schools. Risk assessment also considers all
contractors and other plant workers who may be affected due to the
tank modification work. Answer
5(b): - As per HSG65 Risk assessment is suitable
and sufficient as systematic and detailed risk assessment of the
tank modification task is completed and headed by
competent experienced senior engineer involving Health and safety
adviser, worker representatives and plant manager. Risk
assessment considers highly toxic chemicals and their release, which
could affect the workers, people in adjacent businesses, residential houses
and schools. The proposed modification method is a safe and
widely used solution where the safety improvements are worth
the cost. It also includes risk evaluation, existing and additional
control measures like safe systems of work, a permit-to-work system,
supplementary emergency arrangements, and suitable induction training for all
contractors. Implementation of these precautions and control measures reduce
high risk to low risk. A
summary of the risk assessment is circulated to all workers likely
to be affected by the proposed modification. Permit to work requirement with
the necessary precautions, including wearing of specified personal
protective equipment was communicated to the contractor involved in
tank modification work. For active
monitoring of safe working, experienced process operator along with
independent site contact has been nominated. |
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Task
6: Why should a PTW be used to help manage this storage tank modification? |
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Permit to Work
(PTW) system to be used to manage this storage tank modification for the
following reasons: PTW
is a formally documented safety procedure, forming the part of safe
system of work, which ensures the necessary action to be taken before and
after work to prevent injuries to personnel from accident. PTW
system normally considered most appropriate to non-routine operations.
Tank modification work is a non-routine work which usually planned
during a planned maintenance shutdown. Risk
consideration of the higher the toxic chemical, the release of
which could harm the workers, as well as people in adjacent
businesses, residential houses, and schools in the risk
assessment shows tank modification work is a high-risk
activity. This can be managed by the PTW system. PTW
system is required when two or more individuals or groups need to
coordinate activities to complete the job safely. Involvement
of contractors carrying out the tank modification and all contractors and
other plant workers where co-ordination is required for control of the contractor
site entry and exit. PTW
system will ensure proper training and instructions are
provided to the contractors and workers before work execution. PTW
system will ensure an explanation of the associated risk of tank
modification, how the work is safely prepared and what necessary
precautions, control measures were provided. Wearing of
specified personal protective equipment by contract workers is required. The
supplementary emergency arrangement is available at the site. PTW
system will ensure monitoring
and auditing to
ensure that the system works as intended as specified in the organization’s
safe system of work based on the findings of the risk assessment and the
method statement provided by the contractor. PTW
system ensures clear identification of who may authorize particular
jobs and who is responsible for specifying the necessary precautions to
confirm safe working. Dual role experienced process operator
& worker representative along with independent site contact has been
nominated. |
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Task
7: Based on the
scenario only, discuss how effectively the contractors will be managed by the
organization during the modification. |
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The organization
will effectively manage the contractors during the modification work by
following: Planning the
work: Safe
system of work of an organization like permit to work requirement
based on the findings of risk assessment and the method a statement
provided by the contractor will be exchanged with each other. Contractor
must be given basic site information of the workplace like site
entry and exit control systems, supervision standard, supplementary emergency
arrangements related to tank modification works. Co-ordinating
the work: During the work, there should not
any mismatch of priority. Permit-to-work is issued to the contractors and it
is accepted by them. Necessary precautions, including wearing
of specified personal protective equipment and precautions
of permit to work are communicated to all the affected contractors
and workers. Monitoring
the work: Organisation will monitor the
contractor’s work to ensure that they are adhering to required H&S
standards as stated in the permit to work, specified personal
protective equipment being used for tank modification work. Active
monitoring will be carried out to enforce precautions along with other site
safety rules as shared during the planning of work. Contractor
site entry and exit control will be verified, how supervision
standards will be implemented. For managing work and to communicate with the
contractors, dual role experienced process operator & worker
representative along with independent site contact have been nominated. Managing
the Work: Nominated dual role experienced worker
representative along with independent site contact will be monitoring the
modification work to confirm safe working. They will ensure proper
arrangements, adequate resources like specified PPE were allocated to the
workers, supplementary emergency arrangements were made as
planned. If any deviation is noted as per the safe system of work based
on risk assessment and method statement of contractor work will be
immediately stopped, the aim being to complete the job safely without
incident. |
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Task
8: The organization’s
world-class reputation is partly due to carrying out an annual health and
safety performance review. What types of information should this review
consider? |
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Annual health
and safety performance review shall consider the following types of
information: Legal
compliances: Organisation must verify its legal
requirement and its compliances. Any changes to the law shall be
recognized and if required specific objectives to be set. The organization
shall also consider statutory inspection reports for conformity to health
& safety standards. It is a legally compliant organization that
sets clear objectives and checks that they are met. Active
monitoring: Results
from active monitoring like routine safety inspection of
premises, safety tours by senior management, safety survey reports regarding
implementation of specific precautions shall be reviewed for their
performances and effectiveness. During tank modification work permit
to work explains that precautions will be enforced along
with any other site rules, by active monitoring. Reactive
monitoring: Organisation
shall review incident rate, absenteeism rate, compensation
claims, staff turnover rate to review poor health & safety
practices for possible improvements. Accident &
incident data: Incidents
like near miss, property damage accidents,
lost-time accidents, and
accident reports shall be reviewed for possible underlying and root
causes. An organization must verify the implementation of corrective
and preventive action and if any issue arises adequate
resources shall be provided. Absence
and sickness data: Absenteeism and sickness data shall
be reviewed for work-related Illnesses. If any work-related illness is
reported, effective control measures shall be implemented. Absence and
sickness rates are low as the organization employs motivated workers with
clearly defined responsibility. Training record: How the training needs are identified for all
employees, workers, and contractors. Management shall verify how refresher
training was imparted when the new process was introduced. Review of specific
training requirements like first aid and fire safety training. For
tank modification work suitable induction training for all contractors is
designed as part of safe control measures. Investigation
reports: Review of
investigation reports shall be done to verify corrective and preventive
measures were properly implemented. The organization conducts proper investigating
of any near misses to learn lessons and prevent more serious outcomes as
a result of low accident and incident rates were recorded. Risk
assessments: Risk
assessment shall be reviewed periodically for their effectiveness, especially
after incidents and accidents. Whether risk control measures are suitable
and sufficient. Systematic and detailed risk
assessment of the tank modification the task is completed and
headed by competent experienced senior engineer involving
Health and safety adviser, worker representatives, and plant manager. Results
of participation and consultation: A review of
specific needs and complaints from workers shall be done to identify the
issues and how effective it can be resolved. A competent experienced
process operator was nominated as a representative of the worker. The
organization listens to workers when they raise concerns and clear lines
of internal communication defined to allow effective resolution of
complaints. Previous
management reviews: Implementation of the completion of
actions identified during previous reviews. Whether they were properly
implemented and how it improves the overall performance. Achievement
of objectives: Objectives defined by management
are specific, measurable, attainable realistic, and timely where
specific targets have been set, achievement can be measured. It is a
legally compliant organization that sets clear objectives and periodic
checks were conducted to achieve the targets. Audit
reports: Internal and external audit findings should be
reviewed, which may provide detailed information on the safety management
system and its effectiveness. The organization conducts frequent
internal audits and is also externally audited. Communications
and complaints from external sources: Communication from
external sources like enforcement agencies, stakeholders shall
be reviewed for effective resolution. Organization responds
professionally to external customer complaints. Across the organization,
there are clear lines of internal and external communication are established
for the effective resolution of complaints. Review
of external sources of information: Review of national
legislations, approved code of practices, HSE guidelines, safety standards of
ISO, EU, ILO. Manufacturer’s safe operating instruction for plant &
machinery, Trade Association and NGO reports for possible improvement in
health & safety performances. |