jfa the health and safety audit – chemical industry experience john freeman associates 2005 basis...
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John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
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
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Preamble
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.
A gentle disclaimer
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Typical factory layout
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
A selection of typical plant details
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
What is it?
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!
It’s a bit like a financial audit
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
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
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Corporate Concerns
Hatfield UK
High Speed DerailmentOct. 2000
July 10 2003 Two rail companies and six of their executives and staff have been chargedwith manslaughter following apolice investigation into the 115 mph Hatfield rail crash…….
Four fatalities and 100 injured
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry ExperienceWhere in the overall safety scheme of
things?
Tools for Ensuring Safety
MAJORHAZARDS
OPERATIONALINTEGRITY
WORKPLACESAFETY
DESIGNHazard Analysis
Risk AnalysisHAZOP
Protection Systems
SYSTEMS Procedures ReportingStatisticsSupport
ACTIVITIES Housekeeping
VigilanceNotificationCompliance
Health and Safety Audit
InspectionTour
DesignTeam
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Who is involved?
GroupManagement
Group HSEManager
Site AManagement
Site BManagement
SafetyOfficer
SafetyOfficer
Operations Operations
Audit Team Site BGroup HSE Manager (Chair)Safety ManagerOperations rep (varies)Management repSite A rep (option)(Third Party Independent)
Third PartyIndependent(Occasional)
Typical Organisation Structure
Data andStatistics
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
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
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
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?
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
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
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
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 Record Completions Provide early prompts Highlight missed dates Record decisions not to proceed – with reasons
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Safety Statistics
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
To be meaningful, statistics must be consistent and accurate
Central recording and analysis ensures consistencyCare with definitions such as “Lost-time injury” – how many days?Figures are only useful if lessons are learned and improvement targets imposedRigorous recording is essential
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Procedures – availability and adherence
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
Defined procedures must be set down
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Training Procedures
Safety Training Management, Factory workers, Office workers Specialist functions (e.g. Fire, Rescue)
Induction programmes New Employees Temporary Employees Contractor’s personnel Visitors
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Safety Systems
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.
Some of the more important Systems to check
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Change Control
Failed flexible connector
Aftermath
Flixborough – UK 1974
Plant modification destroysoriginal design integrity
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Emergency Procedures
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?
Investigate preparedness for emergencies
John Freeman Associates 2005
JFAJFAThe 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
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
Health monitoring policy
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
Requirements depend on local circumstances
John Freeman Associates 2005
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
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
JFAJFAThe 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
JFAJFAThe Health and Safety Audit – Chemical Industry Experience
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.