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Safety Management Systems Week 4

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4 views45 pages

Safety Management Systems Week 4

Uploaded by

Bushra Hoorani
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

Chapter 2.

6
Practical safety management
Systems and techniques
J. E. Channing

2.6.1 Introduction
Societies exist and work as their members formulate rules by which to live. The foun-
dations of the rules are either religious or ethical and develop slowly over many years
to reflect the changing culture and values of the particular society. Breaking the rules
incurs censure and punishment. They are carefully scripted by highly educated legal
minds, communicated by the written word and interpreted by judges. Most citizens
grow to appreciate the general principles of the rules (or laws) without knowing the
intricate legal details. If, however, an individual citizen is accused of disobeying the
laws, then the details become important. In these circumstances another highly trained
legal mind defends the accused citizen by arguing over the written words of the law
in front of a judge who has to interpret their precise meaning and intent and decide
whether or not a contravention has occurred. This process generates many laws of an
intricate and confusing nature which extend to cover health, safety and the environ-
ment. These laws address, inter alia, hazards that need to be controlled, some of which
are obvious and some are not. The responsible citizen needs to comply but may not
have the time to read and understand the complexity of the requirements. The objec-
tive of this chapter is to provide insights into the techniques and processes that may be
used to control the health, safety and environmental risks effectively and sensibly while
complying with legal requirements. It is often forgotten that the legal objective is simply
to prevent people from being injured or suffering ill health from the activities of the
enterprise. A confusing jargon has emerged full of ‘risk assessments’, ‘safe systems of
work’ and ‘reasonably practicable options’. The straightforward approach – ‘How can
we be hurt and what can we do about it?’ – has been put aside.
Yet, as people live longer and their expectations of good health increase, it is inevita-
ble that complexity from ever more subtle risks to our well-being increases.
The conundrum facing many managers is to find practical ways of dealing with these
issues without becoming a fully trained lawyer. The problem facing the safety profes-
sional is to utilise the hazards and the legal requirements and create everyday tools
that the manager and the work group can use. The solutions will vary with the size
SYSTEMS AND TECHNIQUES 299

and nature of the enterprise. A small marketing operation which uses only computers
and telephones to operate its business has fewer and different risks from a supermarket
or chemical business. Other enterprises may be larger and encompass many different
types of operations so that each manager must consider hazards which are general
to the whole business as well as ones which are special to the part of the business
under local control. This situation may arise on larger mixed-occupancy sites where, for
example, chemical storage facilities are adjacent to the sales and distribution facilities.

2.6.2 Legal obligations


The responsibility for managing the safety of employees lies with the owners of the
enterprise and their appointed agents, usually the managers of the workplace. This
obligation is a constant feature of legislation throughout the world. In the UK it is
encoded in the Health and Safety at Work etc. Act 1974 (HSWA) and reinforced in
the Management of Health and Safety at Work Regulations 1999 (MHSW). This basic
obligation is also explicit or implicit in all other regulations and is a reflection of each
citizen’s common law duties.

[Link] Common law


Lord Maugham articulated the duties under common law in the court case between
Wilsons and Clyde Coal Co. Ltd. v. English1 when he said:

In the case of employment’s involving risk it was held that there was a duty on the
employees to take reasonable care, and to use reasonable skill, first, to provide and
maintain proper machinery, plant, appliances, and works; secondly, to select prop-
erly skilled persons to manage and superintend the business, and, thirdly to provide
a proper system of working.

The above statement was published in 1937. In the same case Lord Wright quoted a
previous judgment by Lord McLaren in Bett v. Delmeny Oil Co. in 1905,2 which said:

The obligation is threefold, the provision of a competent staff of men, adequate mate-
rial, and a proper system and effective supervision.

The duties of employers, thus well established in common law, became encoded in
criminal law in the 1974 Act where these duties are applied to the extent that is ‘reason-
ably practicable’. The meaning of this phrase was summarised in a common law case by
Lord Asquith in his judgement in Edwards v. National Coal Board.3 He said:

Reasonably practicable’ is a narrower term than ‘physically possible’, and seems to


me to imply that a computation must be made by the owner in which the quantum
of risk is placed on one scale and the sacrifice involved in the measures necessary
for averting the risk (whether in money, time or trouble) is placed in the other, and
that, if it be shown that there is a gross disproportion between them – the risk being
300 THE MANAGEMENT OF RISK

insignificant in relation to the sacrifice – the defendants discharge the onus on them.
Moreover, this computation falls to be made by the owner at a point of time anterior
to the accident.

The phrase and the interpretation once more summarised the common law duty of
care to take ‘reasonable care’. How they have been applied to different accident situa-
tions is to be found in many legal publications such as Munkman’s Employer’s Liability.4
Common themes emerge where factors such as the nature of the hazard, the obvious-
ness of the hazard, the potential consequence to the employee as well as the cost of the
control measures must be considered.

[Link] Statute law


Now that these common law duties are encoded in HSWA, failure to comply is a crimi-
nal offence. Particular regulations extend those duties by requiring risk assessments to
be undertaken as a means of determining the appropriate control measures for specific
hazards. The Management Regulations (MHSW) encompass far more, requiring that
risk assessments be undertaken for all workplace risks not otherwise referred to in
specific regulations.
The practical problem faced by employers in meeting the legal requirements is
twofold:

1 The employer must identify hazards, undertake risk assessments and institute
control measures to protect employees and others who may be affected by the enter-
prise.
2 The employer must achieve these objectives as part of a recognisable management
system which is capable of audit by enforcement officers.

2.6.3 Generic safety management

[Link] Management models


The law is a crude management model for safety. It defines a goal (a hazard which it
seeks to control) and sets forth a set of criteria to achieve that control. It also motivates
employers to apply those controls by threatening punishment for failures to do so. The
safety policy may also be seen as another attempt to apply a management model to
health and safety.
More recently, models for health and safety have emerged which are far more user
friendly to the hard-pressed manager. The HSE’s publication Successful Health and
Safety Management5 provides one of many models to manage health and safety issues
within an enterprise. It outlines a system based on establishing a policy with targets
and goals, organising to implement it, setting forth practical plans to achieve the
targets, measuring performance against the targets and reviewing performance. The
whole process is overlaid by auditing. A schematic representation of this process is
given in Figure 2.6.1.
SYSTEMS AND TECHNIQUES 301

Policy with
goals and targets

Independent
audit
Organise

Plan and
implement

Measure
Internal
progress
feedback

Review
performance

Figure 2.6.1 Schematic diagram of HSE management model

Another similar OHSAS model6 chooses as its starting point an Initial Status Review
by an independent auditor and the steps that follow are:

1 The occupational health and safety policy.


2 Planning.
3 Implementation and operation.
4 Checking and corrective action.
5 Management review.

The above steps are to be considered within an overall framework of ‘continuous


improvement’.
This model has been structured to fit with the international quality management
system standard BS EN ISO 90007 and the equivalent environmental management
system standard BS EN ISO 14001.8 Applying the OHSAS model therefore offers the
opportunity for companies who have opted for the quality management system to inte-
grate environment and health and safety into one comprehensive management process.
Figure 2.6.2 interrelates the elements of these management standards with the HSE’s
guidance.9
The Quality Standard, which was the first in the series of management system stand-
ards, is an uncomfortable fit with the safety and environment management system
standards. Managers should be aware that regulatory enforcement officers are likely
to be influenced more by their own (HSE’s) guidance than by accreditation to a safety
management system awarded by commercial organisations.

[Link] Local safety management assessment systems


Many enterprises have chosen this route and have based their safety management
systems on the Quality Standard. The chemical industry has linked its pre-existing
Responsible Care programme10 to the ISO Quality and Environmental Standards.11, 12
Regulatory bodies increasingly seek a robust formal management system and man-
agers can expect to be asked, during a site visit by inspectors, to explain how they
302 THE MANAGEMENT OF RISK

HSG 65: 1997 OHSAS 18001: 2000 ISO 14001: 1996 ISO 9001: 1994

Successful Occupational health Environmental Quality system


Health and Safety and safety management management system
Management systems

Chapter 2: Effective System requirements, general requirements and policy


health and safety
policies

Clause 4 Clause 4 Clause 4


OH&S management Environmental Quality system
system elements management system requirements
requirements

Clause 4.1 Clause 4.1 Clause 4.2.1 (part)


General requirements General requirements General

Clause 4.2 Clause 4.2 Clause 4.1.1


OH&S policy Environmental policy Quality policy

Chapter 3: Organising Structure, responsibilities, training, communication and documentation


for health and safety

Clause 4.3.4 Clause 4.3.4 Clause 4.2


OH&S management Management programme Quality system
programme

Clause 4.4.1 Clause 4.4.1 Clause 4.1 and 4.1.2


Structure and Structure and Management
responsibility responsibility responsibility and
organisation

Clause 4.4.2 Clause 4.4.2 Clause 4.18


Training, awareness & Training, awareness & Training
competence competence

Clause 4.4.3 Clause 4.4.3 No equivalent


Consultation and Communication
communication

Clause 4.4.4 Clause 4.4.4 Clause 4.2.1 (part)


Documentation Documentation General

Clause 4.4.5 Clause 4.4.5 Clause 4.5


Document and data Document control Document and data
control control

Figure 2.6.2 Alignment of HSG 65 with Safety, Environment and Quality Standard
SYSTEMS AND TECHNIQUES 303

HSG 65: 1997 OHSAS 18001: 2000 ISO 14001: 1996 ISO 9001: 1994

Successful Occupational health Environmental Quality system


Health and Safety and safety management management system
Management systems

Chapter 4: Planning Hazard identification, risk assessment and control, legal requirements, objectives,
and implementing targets, operational control

Clause 4.3.1 Clause 4.3.1 Clause 4.2


Hazard identification, risk Environmental aspects Quality system
assessment and control

Clause 4.3.2 Clause 4.3.2 No equivalent


Legal requirements Legal requirements

Clause 4.3.3 Clause 4.3.3 Clause 4.2


Objectives Objectives and targets Quality system

Clause 4.4.6 Clause 4.4.6 Clause 4.2.2/4.3/4.4/


Operational control Operational control 4.6/4.7/4.8/4.9/
4.15/4.19/4.20
Detailed operational
requirements

Clause 4.4.7 Clause 4.4.7 No equivalent


Arrangements for Arrangements for
emergencies emergencies

Chapter 5: Measuring Performance measurement, inspection, incident/non-conformance investigation,


performance preventive actions and records

Clause 4.5.1 Clause 4.5.1 Clause 4.10/4.11/4.12


Performance Monitoring and Detailed requirements
measurement and measurement for testing and
monitoring inspection

Clause 4.5.2 Clause 4.5.2 Clause 4.13/4.14


Accidents, incidents and Non-conformances and Non-conformances and
preventive actions corrective action corrective action

Clause 4.5.3 Clause 4.5.3 Clause 4.16


Records Records Records

Chapter 6: Auditing Audit and management review


and reviewing
performance

Clause 4.5.4 Clause 4.5.4 Clause 4.17


Audit Management system audit Internal audit

Clause 4.6 Clause 4.6 Clause 4.1.3


Management review Management review Management review

Figure 2.6.2 continued


304 THE MANAGEMENT OF RISK

manage health and safety. It is therefore important that systems are developed which
integrate with the responsibilities and the business needs of the enterprise.
The management system for health and safety needs to be structured in a similar
way to the financial system of controls in a company. This establishes budgetary targets
based on its previous performance and its future aspirations. The overall targets are
then broken down to area budgets. Each level of management is given defined targets
to achieve and is measured against them. Progress is reviewed regularly at each man-
agement level and the whole financial system is independently audited.
The parallel health and safety system needs to define the safety risks and to establish
the effectiveness of the control measures taken, and to monitor performance at each
operational level in the organisation. A consideration of accident data and an audit of
performance can provide this information and enable an improvement target for the
year to be set.
The management systems described above are high-level models and will need to be
supported by more detailed programmes. However, they offer little guidance on the
process of implementation beyond setting standards and requiring audits and assess-
ments.
In this chapter, an assessment refers to the identification of risks in a local area
whereas an audit covers health and safety across the whole organisation with a view to
determining its overall health and safety condition.
The local management system consists of the operational checklists that evolve out of
the generic model. An example for a telephone call service centre is given in Figure 2.6.3.

2.6.4 Implementing a regulation within a safety


management system
An essential component of any safety management system is a mechanism for recognis-
ing and implementing new regulations into the working environment. Once identified,
the regulation should be broken down into simple discrete components. Choosing the
MHOR and the associated Guidance13 as the example, the process may be applied as
follows.

[Link] Defining the key steps


In the Regulations, the sequencing of the subsections may be logical from a legal view-
point, but from a practical manager’s point of view they need to be rearranged. They
require the employer to assess the risks from manual handling and to develop methods
of work that reduce these risks to a minimum. Employees are required to follow the
work method.

Step 1 There is no requirement in the Regulations for a list of tasks to be generated.


However, planning a compliance programme is difficult without knowing the scope
of the task. The first step is to list jobs with a manual handling component together
with the specific tasks within those jobs. Groups of similar tasks may be put together
for generic assessments. For example, the task of loading supermarket shelves with
SYSTEMS AND TECHNIQUES 305

ITEM STATUS COMMENT


✓ OR X

1. Are aisles and exits kept clear?

2. Are trailing leads contained within


safety ducting?

3. Are chairs adjustable and in sound


condition?

4. Can employees adjust their


workstations to avoid fatigue and
strains?

5. Are computer screens free from


glare?

6. Do operators take work breaks at


suitable intervals?

7. Is lighting appropriate for all


workstations?

8. Are employees using telephone


headsets not the handsets?

9. Are workstations tidy?

10. Is the air conditioning effective for all


areas?

Figure 2.6.3 Example of local management system checklist for a call centre

produce would be one assessment – separate assessments would not be required for
stacking baked beans one moment and sugar the next! However, a separate assessment
may be required for loading Christmas turkeys into a chest freezer due to the greater
weight of the product and the bending component of the task. In effect an informal
assessment is being undertaken whilst compiling generic assessments so that like-for-
like risks are grouped together.

Step 2 is to undertake the formal risk assessment, as required by reg. 4(1)(b)(i), possibly
using the proforma outlined in Appendix 2 of the HSE guidance.

Step 3 is to identify the agreed control measures (or ‘remedial actions’ in the HSE pro
forma). It may have emerged from the study that the manual handling task may be elim-
inated. If so, the employer has been able to comply with reg. 4(1)(a). This conclusion,
however, may not have been reached until the assessment study has been completed.

Step 4 implements the control measures which have been identified by the assessments.
Employers are required by reg. 4(1)(b)(iii) to give employees information on the weight
306 THE MANAGEMENT OF RISK

of each load. This may be achieved in different ways. For loads of constant weight it
may only be necessary to put the information in a local procedure. However, enterprises
which supply a range of goods to a variety of customers may need to state the weight
on each package. For off-centre loads, the packaging should indicate the heavier side.

Step 5 is a procedure for reviewing the assessments whenever there is reason to suspect
that the existing one is invalid or there has been a significant change in the operation.
This step complies with reg. 4(2).

Step 6 implements reg. 5 which requires employees to adopt the safe system of work
established by the employer as a result of the assessment. This may be achieved through
training to make employees aware of the risks, and the proper working methods for the
safe performance of the task.

Decoding the regulations into practical and easily understood steps is just the com-
mencement of the implementation process.

[Link] Organising the implementation process


In establishing the above steps line managers may be best placed to generate the initial
list of jobs and tasks. They will need an understanding of ergonomics and of the regu-
lations. The risk assessments could be undertaken by line managers or team leaders,
since they usually have a better appreciation of the tasks undertaken in both normal
and abnormal circumstances. It becomes their responsibility to find less risky alterna-
tives and hence gain ownership of the whole process. Furthermore, they fulfil a basic
tenet of safety law in that the employer, through his line managers, has responsibility
for the safety of his employees. Some companies use safety advisers, specialist trainers
or medical specialists to undertake the assessments. There are, however, considerable
benefits in keeping as much of the assessment and implementation activity ‘in the line’
rather than offloading them on to a specialist.
The safety adviser’s role is to assist in the construction of the implementation process
and training those in the team who will undertake the various assessment tasks. Training
provided to people to implement a particular regulation should include:

• An explanation of the general structure of law and regulations, and where any par-
ticular regulation fits within the overall process.
• The reasons why the regulation came about and why the existing controls were
deemed inadequate. These could be:
• a significant public incident has occurred which demonstrates the inadequacy of
current legislation (e.g. a chemical plant disaster);
• injuries continue to occur at a persistent level in spite of current controls (e.g.
musculo-skeletal injury from manual handling);
• the government is implementing a European Directive to harmonise laws across
the region.
• A description of how people can be harmed if the hazard is not controlled. For
example, the majority of manual handling injuries occur to the lower back, the shoul-
der, or the wrist/forearm. Knowing this helps to focus on the risk factors.
SYSTEMS AND TECHNIQUES 307

• Information on the circumstances that contribute to injury such as the causative


factors in manual handling injuries which include lifting, twisting, repetitive actions,
or posture while moving objects of weight.
• A demonstration that compliance can generate feedback and be applied to give low-
cost practical solutions to particular problems.
• An appreciation of the need for a programme timescale and of the process to be used
in measuring the progress of implementation.

A benefit of using line employees to implement regulatory controls is that the training
they are given to help them undertake the task results in a well-educated workforce
with benefits for the entire safety programme.

[Link] Measuring the progress


‘What gets measured, gets done’ was a phrase coined by Peters.14 The phrase sums up
the belief that managers respond best to measurement systems, often numerical, to
chart progress and thereby ensure that plans reach completion. A measurement matrix
may be applied to implementing regulations once the steps have been established. An
example of a measurement matrix for implementing the manual handling operations
risk assessment is presented in Figure 2.6.4.
The matrix has several important features. Some steps are measured so that a ‘No’
answer attracts a zero score while a ‘Yes’ answer gains the maximum score. Other steps
gain a graduated score according to the percentage of the task completed. Another
important feature is that not all steps are equally weighted. In general the higher weight-
ings are given to the more important steps or those requiring the greater workload. In
the example, step 4 has the heaviest weighting, since this is viewed as the single most
important step to achieving a safe manual handling workplace. Adjusting the weight-
ing in this manner encourages a focus on the essential elements of complying with the
Regulations.
As the implementation plan proceeds, a score for each step is calculated by multiply-
ing the level achieved by its weighting. A copy of the chart may be provided to senior
managers each month from which the pace of progress may easily be seen. This can
assist in decisions regarding the allocation of resources to maintain progress.
In a multi-departmental enterprise, each area should have its own matrix with
summary scores published to spur the laggards to catch up. It acts as a simple but effec-
tive motivational and behaviour-shaping tool.
Guidance on the measurement of health and safety performance15 observes that compa-
nies measure their financial performance in terms of positive outcomes, whereas for
health and safety they use a negative measure – injury and ill-health data – which are
measures of failure. Success in health and safety boils down to the absence of adverse
(failure) outcomes.
The guidance recommends a ‘basket of measures or a balanced scorecard’ to provide
indicators of the health of the organisation and early detection of deterioration in safety
performance before it becomes overtly manifest. Figure 2.6.5, which is based on the five
elements for successful safety management advocated by the HSE,16 provides a simple
list of 20 criteria for measuring the success of management.
308

MANUAL HANDLING REGULATIONS COMPLIANCE CHART

STEP LEVEL ACHIEVED SCORE WEIGHT OVERALL

SCORE

score values 0 1 2 3 4 5 6 7 8 9 10
THE MANAGEMENT OF RISK

1. List of jobs and tasks generated no yes 5

2. % risk assessments completed 0 10 20 30 40 50 60 70 80 90 100 20

3. List of control measures agreed no yes 15

4. % of control measures implemented 0 10 20 30 40 50 60 70 80 90 100 25

5. Procedure to mark load weight no yes 5

6. Review process in place no yes 10

7. % employees trained 0 10 20 30 40 50 60 70 80 90 100 15

8. Training packages available no yes 5

TOTAL
SCORE=

Figure 2.6.4 Measurement matrix for the implementation of MHOR


SYSTEMS AND TECHNIQUES 309

ELEMENT TEST QUESTION RESPONSE


(Y/N)

1. Policy 1.1 Does the safety policy reflect the current organisation?
1.2 Does the policy specify responsibilities of those in the
organisation?
1.3 Is the policy pertinent to the hazard burden?
1.4 Are employees aware of the policy and the roles,
responsibilities and arrangements to make it effective?

2. Organising 2.1 Does a system exist to control health and safety?


2.2 Do safety committees exist at appropriate levels in the
organisation?
2.3 Do consultation arrangements promote effective co-
operation and participation of all relevant stakeholders
in the organisation and others who may be affected?
2.4 Are the communication channels effective in
distributing all the types of health and safety
information?
2.5 Are the people appointed to specific roles and tasks
trained and qualified to a sufficient competence level?

3. Planning and 3.1 Does the organisation and its parts have plans with
implementing objectives?
3.2 Do the plans have specific deliverables and suitable
time scales?
3.3 Do the plans address the identified hazards?
3.4 Do the plans ensure risk assessments are carried out
and controls implemented?
3.5 Are individuals who are responsible for delivering
specific elements named?

4. Measuring 4.1 Does the organisation measure progress against the


performance plan elements each quarter?
4.2 Is progress published to employees?
4.3 Are explanations provided to employees if progress is
slow?

5. Audit and 5.1 Are there arrangements to audit the entire health and
review safety programme periodically?
5.2 Does a senior manager/director review health and
safety performance?
5.3 Do senior managers go outside the organisation to
gain an objective view of its performance?

Figure 2.6.5 A 20-point list to measure successful safety management


310 THE MANAGEMENT OF RISK

2.6.5 Safety management and housekeeping


Managers often target ‘housekeeping’ as an area which needs improvement. Many
accidents occur because of poor housekeeping in the form of uncleared spillages, over-
stacked shelves, etc., which indicate a lack of control in the workplace. The achievement
of high housekeeping standards is also a key indicator of good safety performance in
the area because it is a manifestation of the attitudes that prevail among those working
there. Good housekeeping requires a well-structured work process, discipline in execu-
tion and motivated employees. For this reason an HSE inspector may use the workplace
condition to indicate possible weaknesses in the safety management systems.
Scoring techniques may be used to improve and maintain housekeeping in the work
area and an example of a checklist is provided in Figure 2.6.6. The checklist identifies the
expectations clearly and precisely, and should be phrased in such a way that full com-
pliance gains the maximum points. Questions may range from the physical conditions
in the workplace to the practical knowledge of the employees. Approaching housekeep-
ing in this way has several benefits. First, the area’s requirements are stated clearly.
Second, because the questions are clear and concise, each employee in the work area can
complete the checklist on a rota basis. Third, the checklist can be changed periodically.
Changing the checklist contents needs to be considered carefully so that the desired
behaviours and standards are developed and improved. Leaving an item off a well-

Housekeeping checklist – Computer Suite

Item Maximum Actual


score score

1 Emergency fire escape routes are unobstructed 20


( 2 routes, 10 points per clear route)

2 First-aid boxes contain correct contents 8


( 2 boxes, 4 points per box)

3 Work areas clear of trailing leads in walkways 10


(deduct 2 points per trailing lead)

4 Electrical leads in area visually inspected and show no sign of 12


mechanical damage
(deduct 4 points per damaged lead)

5 Computer workstation meets requirements of Regulations 20


(see supplementary list)
( 2 workstations, deduct 4 points per defect)

6 Workstation users have made correct adjustments for their 20


own use
( 2 workstations, deduct 4 points per defect)

Score maximum = 90 actual =

Figure 2.6.6 An example of a scoring checklist for housekeeping


SYSTEMS AND TECHNIQUES 311

Japanese English Meaning Examples


term equivalent

Seiri Tidiness Organisation Discard rubbish


Everything in place

Seiton Orderliness Neatness Items close to hand


Documents nearby

Seiso Cleanliness Cleaning Individual cleaning responsibility

Seiketsu Clean-up Standardisation Transparency of storage

Shitsuke Discipline Self-discipline Daily commitment to the programme

Figure 2.6.7 Overview of five Ss terminology

established checklist may lead to it not receiving attention in the future. On the other
hand, simply adding more and more items may make the whole checklist unwieldy. If this
occurs, a split checklist may be necessary with each part completed in alternate weeks.
A final point to consider relates to the scores themselves and whether to use ‘points’
or ‘percentages’. In general ‘points’ are preferred because new items on the check-
list add more to the ‘maximum points horizon’ without diminishing the value of the
points scores for the existing items. ‘Percentages’, where 100 per cent is the goal, do not
achieve this, thereby diminishing the relative worth of an existing item on the checklist.
Techniques that link housekeeping to safety, productivity and quality have become
prominent. One example is known as ’5S’s’.17 Based on five Japanese words (Figure 2.6.7),
it is a tool which encourages employees to improve their own working conditions and
reduce waste in all its forms. The essential philosophy of the process is to engage
employees in a formal structured process that is within their control but is aligned with
business objectives, of which health and safety performance is but one.

• ‘Seiri’ refers to the need to separate and retain only those things that are necessary for
the tasks undertaken by the work group. It requires the identification and removal
of superfluous materials and process steps. It directly relates to safety performance
insofar as many accidents occur from non-added-value activity. Examples of tasks
which add cost and hazards without adding value include storage and transporta-
tion of product in warehouses.
• ‘Seiton’ refers to workplace orderliness and is basically about efficiency. This part
of the process addresses the question of how quickly an employee can get the items
needed for the task. It requires that just sufficient materials are kept in a convenient,
specifically allocated place. An example would be to keep tools mounted on a peg-
board rather than haphazardly placed in a drawer. Safety benefits arise from locating
the pegboard nearby and at a suitable height to reduce manual handling hazards.
• ‘Seiso’ relates to cleanliness. It requires that everyone keeps their own work areas
clean. Communal areas may be allocated to individuals or responsibility rotated
between individuals in the work group. Each employee is encouraged to see their
workplace through the eyes of a visiting dignatory – ‘Would I be proud for the
312 THE MANAGEMENT OF RISK

Prime Minister to visit my own work area?’ The impact upon safety is to remove
hazards such as those which result in slips or trips from dirty floors. It also prompts
questions such as ‘Why do oil leaks recur from this machine?’ and prompts preven-
tive action. Organisations advanced in Seiso do not employ cleaning staff!
• ‘Seiketsu’ embraces continually and repeatedly cleaning up to maintain the work
area’s tidiness, orderliness and cleanliness. It is achieved by ‘visual management’
using colour coding to highlight quickly a breach of standards. For example, walls
are decorated with light-coloured paint which quickly shows the presence of chemi-
cal dust should a bag filter malfunction. Some organisations have attired employees
in white overalls to show when the workplace or individual habits are creating dirt
and mess.
• ‘Shitsuke’ means applying discipline to do in the right way the things that need to
be done. The emphasis is on creating good work habits and it is successful when the
self-discipline of all employees is seen as pride in the work area. It is particularly
important for safety where regular checks on safety systems need to be undertaken
to prevent failure. Reliance on the individual employee to inspect, check and record
conscientiously is critical.

The 5 Ss approach is more about attitude and culture, and it elevates humble house-
keeping into a core value.

2.6.6 Assessment techniques


The models reviewed at the beginning of this chapter set an overall framework for man-
aging health and safety issues. Once the system is established there is a requirement for
it to be assessed. The role of an assessor can vary.
One aspect is to review the management system and procedures to ensure that they
can operate as a cohesive structure. It does not need a professional understanding of
health and safety to perform this task. Another approach that might be taken is to
use a qualified health and safety adviser who checks the system and is able to judge
whether safety in the workplace is being achieved. Whichever approach is used the
assessment report should list positive features of the system as well as listing ‘non-
compliances’, ‘negative findings’ or ‘corrective action requests’ according to the termi-
nology used. The benefit of this approach is that it requires an assessment by a third
party.
But there are weaknesses. Even an enterprise which, by any objective standards,
is good in terms of health and safety performance may still be given a list of non-
conformances. In addition, the items listed in successive assessments become of increas-
ingly less importance, even trivial, and may reflect the assessor’s opinion rather than a
requirement of a regulation or internal standard.
A typical response to a third-party health and safety assessment is to see it as a
target to be aimed for and to do just sufficient to satisfy the assessment. This response
may prevail where managers fail to embrace health and safety as central to their
function.
Assessments may be undertaken once or twice a year and may follow a ‘sampling’
SYSTEMS AND TECHNIQUES 313

technique whereby a few specific areas are examined in depth and conclusions drawn
which may be extrapolated to cover the whole organisation. An assessment may seem
like an examination where the result is always ‘can do better’! While assessments are
necessary and may be beneficial to an organisation they are often approached with
apprehension because they are seen as punitive where the options lie between being
beaten with a big stick and beaten with a small one.

[Link] The positive approach to health and safety assessments


Techniques have been developed to make health and safety assessments an ongoing
and central element of a manager’s function. Section 2.6.4 demonstrated how a regu-
lation can be translated into an assessment with a numerical format so that progress
towards implementation can be given a score. The same principle of scoring may be
applied to embrace all regulatory requirements once they have been implemented with
other health and safety aspects of the workplace. Figure 2.6.8 shows a simple set of ques-
tions which may be used to maintain compliance with MHOR. Each question attracts a
points score as indicated.
The scoring concept may be applied to each element of the management systems.
Figure 2.6.9 is an example of questions set to manage the performance of safety
committees.

Audit question Points available Points


scored

1 Have tasks in the area been reviewed in the last year 10 if ‘yes’
to identify those with a manual handling component?

2 State the % of manual handling tasks with formal 50 points for 100%
written risk assessments. compliance and pro rata

3 On what % of tasks has the risk been reduced by the 50 points for 100%
control measures to as low as reasonably practicable? compliance and pro rata

4 What % of employees know where the risk 50 points for 100%


assessments are kept and have been made familiar compliance and pro rata
with them?

5 Have steps been taken to inform employees of load 20 if ‘yes’


weights?

6 Have assessments been reviewed within the last 3 30 if ‘yes’


years?

7 What % of employees have undergone training in 30 points for 100%


handling methods in the last 5 years? compliance and pro rata

8 Is there a procedure in place to review assessments if 10 points for ‘yes’


significant change occurs?

Figure 2.6.8 Example of audit questions for maintaining compliance with manual
handling operations regulations
314 THE MANAGEMENT OF RISK

Audit question Points available Points


scored

1 Does the area have a joint safety committee? 10 for ‘yes’

2 Has the committee met at least every 3 months in the 10 per meeting up to 40
last year?

3 Does the area manager attend the meetings? 20 per attendance

4 Does the safety adviser attend the meetings? 10 per attendance

5 Do employee representatives attend the meetings? 10 per meeting up to 40

Figure 2.6.9 An example of audit questions for safety committees

The questions are designed to be straightforward and easily understood by everyone.


This makes it possible for any employee or a small group of employees to monitor the
performance of the system.
The scoring principles for the question sets should award fewer points for simple
administrative tasks and greater points for actions by the people involved.
In the safety committee example, the mere existence of a safety committee attracts
few points. Furthermore, the attendance of the manager outscores the attendance of
the safety adviser and employee representatives because the manager has the greater
responsibility and plays the key role in safety issues in the workplace.
This is an example of the technique of ‘shaping’ which may be used to guide the
contents of a set of practical actions aimed at improving health and safety performance
in the area.
This approach may be applied across the range of health and safety hazards which
exist in the work area but it does raise issues of the scores given to dissimilar tasks.
For example, one question on fire safety may concern the maintenance of suitable fire
escape routes. The administrator of the assessment process must decide how many
points should be given to that question compared to a question on labelling of chemi-
cals. There is no absolute answer; nor need there be. What is important is that each
assessment is repeated on a regular basis. Increasing scores for particular areas indicate
improving safety standards.
The safety adviser plays a key role in establishing a system for ongoing assessments
and for deciding on the questions and their scores. Software packages are available and
may be preferable to paper systems in some organisations.18
Scoring systems of this type permit managers to undertake a self-audit of the per-
formance of their areas of responsibility. However, rather than carry out a comprehen-
sive audit of all areas of responsibility occasionally, greater benefit may be derived by
assessing one aspect only each month.
The following section headings have been used with success in some organisations:

1 Health and safety management and administration.


2 Fire, loss and emergencies.
3 Investigation and monitoring.
SYSTEMS AND TECHNIQUES 315

4 Chemicals and substances.


5 Environment and waste.
6 People.
7 Systems of work.
8 Machinery, plant and equipment.
9 Product safety.

Each section may be split into separate parts. For example, section 6 on ‘People’ may
be split into:

6.1 Standard operating procedures.


6.2 Permits-to-work and lock-off systems.
6.3 Manual handling operations.
6.4 Repetitive work.
6.5 Large vehicles.
6.6 Lone workers.

One section should be completed each month over an agreed period of, say, nine months.
In the three months following the final assessment the safety adviser can review and
agree the scores, thereby providing an independent validation of the self-assessment. It
also allows the manager to review his performance and act to improve his score before
submitting the final performance score for the year to his director.
With ongoing assessments an opportunity may be taken to alter or add to the ques-
tion set for the following assessment. The amendments to the assessment enable the
enterprise to incorporate newly implemented regulations into the package. It also
allows an examination of its performance and identification of the improvements to
be made. In one organisation, it was observed that a safety committee in one area was
less than effective because it didn’t have a procedure for closing actions. A procedure
was implemented and additional questions (see Figure 2.6.10) were added to the exist-
ing assessment form. As the questions set applied to all areas of the organisation the
deficiency observed in one area was able to be addressed in all areas.
The objective of any assessment process is to reduce accidents at work. Figure 2.6.11
shows data from an organisation using the self-assessment system outlined above.
Graphs of this sort can demonstrate correlations between lost time injury (LTI) levels
and self-assessment scores. A manager who takes the right actions in a structured
approach to health and safety should produce an improved accident performance.

Audit question Points available Points


scored

6 Is a list of actions produced with agreed timelines for 20 for ‘yes’


completion?

7 What % of actions were completed in the last year 100 points for 100%
within time?

Figure 2.6.10 Additional audit questions on safety committees


316 THE MANAGEMENT OF RISK

400 100
% Audit score
Hours worked per LTI

300 Hours per LTI

% Audit score
90
200

80
100

0 70
Roll 1 Roll 2 Roll 3 Chem 1 Eng Chem 2 Pack
Area

Figure 2.6.11 Correlation between accident and audit performance

2.6.7 Proprietary audit systems


Several proprietary audit systems are available. The International Safety Rating System19
was one of the first comprehensive safety audit systems to be developed. It catego-
rises health and safety issues into 20 management elements and includes a ‘Physical
Conditions’ inspection. From the score obtained an enterprise may be judged to have
achieved one of five standard levels or one of five advanced levels. Achievement at the
highest level demands a high score in over 600 questions in the management elements
and high performance in ‘Physical Conditions’ (loosely equated to housekeeping). The
assessment is undertaken by a third-party auditor who has been trained in the system.
Successful application of the system also requires that managers are educated to under-
stand its jargon and objectives. Using the system means that comparisons can be made
between companies in different business sectors and even in different countries. It has
been developed over many years to give organisations comprehensive audit processes.
The elements measured by the system are as follows:

Leadership and administration Personal protective equipment


Management training Health control
Planned inspections Programme evaluation system
Task analysis and procedures Engineering controls
Accident/incident investigation Personal communication
Task observation Group meetings
Emergency preparedness General (safety) promotion
Organisational rules Hiring and placement
Accident/incident analysis Purchasing controls
Employee training Off-the-job safety

Disadvantages of the system include the scores given to each question and the ‘pass
marks’ required for each level which are set by the system and do not allow flexibility
to meet a particular emphasis on which the enterprise wishes to focus. Another problem
arises in the application to enterprises that use a different culture and jargon from that
employed by the system. Finally, the system does not address specific national legisla-
SYSTEMS AND TECHNIQUES 317

tive requirements, since it does not set out to focus on particular national laws but seeks
a position above them by asking questions such as ‘Does the organisation have copies
of relevant legislation and related standards?’ It is necessary for the auditor to know
the legislation appropriate to the enterprise and to exercise personal judgement on the
score awarded (up to a maximum of 25 points). Additional supplementary work would
have to be undertaken to ensure compliance with specific regulations.
Similar proprietary systems are available from other organisations such as the
British Safety Council who offer a five-star audit system.20 The scope of the propri-
etary systems has been developed after considerable experience in many businesses
and cultures. They capture all of the key components for achieving superior safety
performance. If an enterprise chooses an internally developed self-assessment route,
then keeping a proprietary system as a reference and guide for future developments
may be useful.
Computer-based systems such as ‘CHASE’21 can provide preloaded audit question-
naires or blank formats into which the organisation’s own audit questions may be
written. The benefit of writing the audit questions within the organisation is that it will
reflect the culture and jargon of the workplace, but the process of setting it up can be
time consuming.

2.6.8 Safety systems and incidents


The previous sections deal with safety management from a proactive standpoint. Audit
and assessment are essential but they do tend to follow pre-designed checklists or
protocols. Many auditors under time pressure or through inexperience will limit their
assessment to the prescribed list of topics. When incidents occur an opportunity is pre-
sented to do more than identify the proximate causes. Gaps in the audit system itself
that allowed the causes to arise and had not been corrected may be identified. In prac-
tice, investigations tend to seek out a ‘root cause’ which is often identified as a defect in
the work system giving the impression that all would have been well if the work system
had been properly designed in the first instance. Such an analysis does not generate the
complete list of lessons from the incident.
A better approach is to refocus the investigation process by asking the question ‘Who
could have done what to avoid, help to avoid, or mitigate the incident?’ Normally there
are three controlling minds to a workplace incident:

1 The manager who controls the system.


2 The supervisor who controls the day-to-day workplace.
3 The employee who controls the activity.

Each of the above could have contributed to avoiding the incident or reducing its
consequence. By examining these three aspects a greater insight into the deficiencies
of the safety system may be gained and more improvement opportunities identified.
Figure 2.6.12 provides an example of this approach.
Once the various alternatives that could wholly or partly have contributed to avoid-
ing the incident have been identified then preferred solutions can be chosen. In the
318 THE MANAGEMENT OF RISK

The maintenance supervisor sends Joe, the mechanic, to fix a leak coming from a capped
pipe elbow. The capped elbow is located 9 feet high on a wall and had been left after the
removal of a pump which was once required for the production process. Joe takes a step
ladder but he finds that he cannot get to the nearest point because pallets of product have
been stored underneath. Joe places the ladder as close as he can so that he can stretch
to reach the leaking joint. As he applies force to the wrench, the ladder moves away from
underneath him. He falls and badly bruises his shoulder and ribs. At the inquiry, it emerges
that a permit-to-work was not issued as required by the Maintenance Supervisor and the
Production Supervisor was not informed (who would have looked at the job and removed the
pallets to give safe access). The inquiry noted that the capped pipe elbow could and should
have been removed when the pump was removed during the process changes made two
years previously.
Actions within the manager’s control:
Remove leaking joint.
Review permit-to-work training.
Organise ladder safety training.

Actions within the supervisor’s control:


Check location of pallet storage.
Check job locations before sending people out to work.

Actions within the employee’s control:


Request permit-to-work if forgotten.
Do not place oneself in unsafe positions.
Choose the correct tools for the job.

Figure 2.6.12 Alternative to ‘single root cause’ incident model

example given in Figure 2.6.12 the system cause was the ‘non-removal’ of the leaking
joint. It would be appropriate to remove it whatever the expense or inconvenience if it
leaks flammable solvent and does so regularly. However, if leakage is rare and when
it occurs only small amounts of water drip from it, and if it is awkward or difficult to
remove, then the ‘permit-to-work’ option may be more appropriate. In either event,
some training in the permit procedure and in ladder safety should be undertaken.
The incident investigation approach suggested promotes more creative wider ranging
thinking than traditional prescriptive root cause analysis.

2.6.9 Learning organisations


A key element of successful health and safety management is the ability of the organi-
sation to learn from its experiences. Arrangements should be made so that proactive
data (e.g. from audit results) and reactive data (e.g. from incidents) in one area of an
organisation are shared with other areas in the organisation. In this way, areas have
the opportunity to learn from the experiences of others and to consider whether they
have similar deficiencies in their systems and processes. The availability of electronic
mail systems greatly facilitates the rapid sharing of such information. The information
format should provide the following:
SYSTEMS AND TECHNIQUES 319

• a summary description at the opening of the document;


• highlights of the key improvement opportunities;
• an opening screen containing all the essential information;
• attachments with greater detail for those receiving areas that need more information.
Sharing ‘failure’ information such as this is a feature of mature and confident organisa-
tions. It means that their first intention is to learn from their experiences and improve
their safety performance, and indicates that they operate in a ‘no-blame’ environment.
It also means that their desire to improve outweighs their fear of any consequences
that may arise from publishing information across their organisation. Included in this
process of sharing data should be any comments made by visiting regulators or external
third-party auditors.
Many organisations find that incidents repeat themselves after a passage of time
either in the same location or in another location. This is a particular challenge.
It arises because organisations per se do not have memories – it’s the employees
who remember, and as they change jobs or leave and are replaced, their memories,
knowledge and experiences are lost. It is important to record and file reports of
incidents, remedial actions and their effectiveness for future reference. Particular
attention should be paid to ensuring that the safety management system retains key
learning points that have been developed with the passage of time. This may be
achieved by:

• turning incidents into training packages for new entrants;


• adding explanatory notes to procedures explaining why a certain action is necessary;
• issuing company newsletters or bulletins referring to past experiences and the lessons
to be learned.

Learning from external sources is also important. Major incidents are usually investi-
gated and reported by the regulatory authorities and their reports published. They are
always worth reading and can provide lessons for organisations that operate in differ-
ent business sectors. Commercial health and safety journals often carry a summary of
incidents and court cases which again can highlight for other organisations areas that
need to be checked. Learning from other organisations about their health and safety
processes may best be achieved through a ‘benchmarking’ visit.

[Link] Benchmarking
Benchmarking is an increasingly important tool in safety management. The term
‘benchmarking’ describes a concept of comparison with and learning from other com-
panies. There is a misconception that benchmarking of safety performance and pro-
cesses should only take place with companies who are perceived to be superior, i.e. who
set the ‘benchmark’. However, by undertaking a benchmarking exercise the enterprise
is able to obtain a better understanding of its own safety processes. This aspect alone
brings benefits before it seeks to identify alternative processes and quality gaps in
comparable processes observed in other companies.
A natural starting point for benchmarking exercises is to focus on the elements con-
tained in their audit process. Features of benchmarking studies include the following:
320 THE MANAGEMENT OF RISK

• identification of the elements of the safety system;


• how the elements fit together;
• how management leads and monitors the safety system;
• what topics are subject to formal risk assessments, who does them, and what is their
quality;
• how employees are involved and motivated to play a full part in safety.
From the above it is clear that safety benchmarking is less about a comparison of acci-
dent statistics and much more about comparing management processes and their effec-
tiveness. Benchmarking should not be the sole preserve of the safety adviser but should
involve line managers who can gain considerable benefit from it. The process compels
them to focus their attention on both the subject of safety and their own performance.
Safety advisers benefit because it enables them to formulate new improvement strate-
gies which have been proved elsewhere and can be recommended to managers with
confidence.

2.6.10 Safety management systems in small organisations


Small organisations are required to meet the same legal standards as large organisa-
tions. They usually have fewer, if any, specialist support staff and need to find ways to
manage the hazards appropriate to their activities. This needs to be done systematically
and a good starting point is to examine four aspects of the operations:

1 Facilities – which includes premises, plant and employees.


2 Products – which refers to the articles the enterprise produces for customers.
3 Services – the service elements which the enterprise provides to customers.
4 Contractors – the use made of contractors in any of the enterprise’s activities.

Each of these aspects should be examined with a view to:

• identifying the hazards involved;


• identifying the different groups of people who may be harmed;
• identifying the possible circumstances that could arise to cause the harm and how
likely they are to occur;
• examining the measures that currently exist to prevent harm from occurring and to
decide if they are adequate or if additional controls are necessary;
• making a record of the findings with the date and the name of the person who carried
out the examination;
• making arrangements to review the findings periodically (at least once a year).
Figure 2.6.13 lists topics which fall within each aspect.
Small organisations generally find checklists a valuable aid in assessing their stand-
ard of compliance. Periodically they may need to seek professional assistance to ensure
that the safety standards achieved are adequate for the hazards faced and that there are
no glaring omissions in the scope of their checklists that need to be addressed.
SYSTEMS AND TECHNIQUES 321

FACILITY PRODUCT SERVICES CONTRACTOR

– Fire safety – Information on its – Safety while working – Selection criteria


use on client’s premises
– Office and office – Work methods
equipment – Composition of – Lone worker safety
– Materials used
product
– Chemicals and – Home working
– On-site hazards
substances – Maintenance of
– Working hours
product – Off-site hazards
– Machinery
– Travelling between
– Transportation of – Communication on
– Visitor safety locations, etc.
product safety issues and
– Electrical safety performance, etc.
– Storage of product
– Storage
– Disposal of
– Radiations product, etc.
– Noise
– Employee
communication, etc.

Figure 2.6.13 Example of safety management system topics for small organisations

2.6.11 Risk profiling


Organisations that are unable to employ a trained safety professional can use a tech-
nique such as ‘risk profiling’ to make an initial assessment. This is a simple technique
that can be used by workplace employees to make an initial assessment of risks. The
technique is based on the completion of the form shown in Figure 2.6.14. An employee
in the workplace considers a specific aspect of the work undertaken and judges how
likely it would be that ‘hurt’ or ‘injury’ could occur and how serious the outcome could
be. The employee then highlights the box and submits the form to the local manager.
This process is repeated endlessly by different employees. Each day or shift, one of the
employees undertakes the process, thereby encompassing all workplace activities and
all of the knowledge and observation of the workforce while simultaneously improving
local awareness and thus prevention. ‘Risk profiling’ can of course be computerised and
with internet technology it can be made applicable remotely.

Completing the risk profile


The risk process is a flexible way to manage health and safety. It is based on a booklet
issued by the Health and Safety Executive entitled Essentials of Health and Safety at
Work. This booklet provides a guide which spans the health and safety issues that must
be addressed to protect people at work. The risk profile process is aligned with each
chapter of the Essentials of Health and Safety at Work booklet.

Completing the hazard column


Consider each aspect and judge if it applies to the area under review. If it does not,
then write n/a (not applicable) in the hazard column. You also have the option of
322 THE MANAGEMENT OF RISK

Risk Profiling Form

Name of organisation:

Registered address:

Assessment area:

Number of people employed:

Maximum total number of people in the area:

Findings of the assessment:

Priority action plan:

Signature …………………. Position in organisation ……………….. Date ………….

Signature …………………. Position in organisation ……………….. Date ………….

Figure 2.6.14 Risk profiling forms

adding a comment in the observation column. If the aspect does apply then use
the Risk Assessment matrix to assess if the hazard presents negligible (N), low (L),
medium (M) or high (H) risk and enter the letter into the hazard column. A negligible
risk may be obtained if a simple control recommendation is adopted. Thus, if you
have written N in the hazard column and the recommendation in the observation
column, suitable comment may be low risk reduced to negligible risk following rec-
ommendation.
SYSTEMS AND TECHNIQUES 323

Completing the hazard column


The observation column may be used in several ways. You can:

1 State why an aspect does not apply.


2 Make a comment.
3 Specify a simple control measure that removes the hazard completely or reduces it to
a negligible risk.
4 State for low or medium risks when a specific formal risk assessment should be com-
pleted by.
5 State that a hazard presents a high risk and stop the work immediately until the risk
is removed or reduced.

The risk profile process may be used as a day-to-day management tool, as an audit tool
and as a training tool.

Risk assessment matrix


Assess each risk by considering how likely the hazard is to hurt someone, and how
severe the consequence may be.
LIKELIHOOD SEVERITY
'how likely is H to hurt 'how seriously can tt hurt someone?'
someone?' CATASTROPHIC MAJOR MODERATE MINOR INSIGNIFICANT
ALMOST CERTAIN High risk High risk Medium risk Medium risk Low risk
LIKELY High risk High risk Medium risk Low risk Negligible risk
OCCASIONAL Hiah risk Medium risk Medium risk Low risk NQllli ible risk
UNLIKELY High risk Medium risk Low risk Negligible risk Negli ible risk
RARE Medium risk Low risk Low risk Negligible risk Negli ible risk

GUIDANCE - LIKELIHOOD & SEVERITY


LIKELIHOOD SEVERITY
ALMOST CERTAIN Almost every time lIle task is done CATASTROPHIC Dealll or disabli,,1L
LIKELY Once a day MAJOR Fracture, long-tenn in'uryfliiness, pennanent damage
OCCASIONAL Once or twice a week MODERATE Strain cut, lIlat impedes wor1<; >3dayabsence
UNLIKELY Once or twice a monlll MINOR Bruise or abrasion se~-treated , 1 or 2 day_s absence
RARE Once or twice a year INSIGNIFICANT No in'ur'{ or slight bruise
IF IN DOUBT INCREASE THE CATEGORYI

GUIDANCE - RISK CATEGORY AND ACTIONS REQUIRED


RISK CATEGORY ACTIONS REQUIRED
HIGH RlSK Act Now - stop the job untillile hazard is removed or reduced
MEDIUMRlSK Act As Soon As Possible - do not undertake lIle 'ob until a specific Risk Assessment is completed
LOWRlSK Plan - to undertake a Risk assessment to reduce the risk and meanwhile infonn emplovees of interim steps to be taken
NEGLIGIBLE RISK OK For Now - but review at set time intervals and especially Wequi mentlpeople/materialslwor1< melilods change
Review the RIsk Profile and any RIBk A_menta with your meneger and your employees

Figure 2.6.15 Risk assessment matrix

Guidance
A risk exists if a hazard is present. A hazard is something that has the potential to cause
harm. If a hazard is not present then there is no risk. Consequently a critical step is to
decide if a hazard exists and, if it does not, then no further action needs to be taken.
However, if a risk does exist then it must be evaluated by taking into account how
likely the hazard is to cause harm and how severe the harm could be. The guidance
tables provide advice on making risk categorisation. Obviously a judgement is being
made with respect both to the experience and not what could happen under excep-
tional circumstances. For example, if someone were to slip on a wet floor the most
credible outcome is a sprain or bruise, not a fatality, even though under exceptional
324 THE MANAGEMENT OF RISK

circumstances it is possible. Second, where genuine doubt exists, elevate your choice
to the higher risk category. Even though you are making the assessment to the best of
your judgement it is important that the people affected are involved and aware of your
work. They may have some experience that will cause a change to a different category.
The risk profile and risk assessments must be shared with employees and supervisors.
An example:

Area to assess Aspect Hazard Observation

Handling and 1a – essential manual handling L Three tasks to be risk


transporting only assessed.
1f – job rotation N Good teamwork.
3b – equipment checks N Negligible risk but record
document checks.

Harmful 1a – MSDSs available L Get data for cleaning


substances materials.
3c – spillages L
Low risk – access and
7b – employee knowledge of N
introduce procedure.
control measures
Negligible risk – refresh at
Huddle meeting.

Accidents and 2a – first-aiders M Medium risk – agree


emergencies arrangements with client.

Forms to use in the workplace

Area to assess Aspect Hazard Observation

The workplace 1. Safe place of work


a) Satisfactory state of repair
b) Safe access and egress, indoor and outdoor
routes
c) Slip and trip hazards from wet or icy floors/
trailing cables
d) Space for safe movements
e) Storage facilities
f) Hazards from falling materials

2. Lighting
a) Adequate level of natural/local light
b) Suitable lighting appliances

3. Moving around the premises


a) Safe passage for pedestrians and vehicles
SYSTEMS AND TECHNIQUES 325

Area to assess Aspect Hazard Observation

b) Safe walk surfaces and vision panels in doors


c) Painted markings as necessary

4. Work stations
a) Working positions fit the worker and the work
b) Suitable seating
c) Comfortable work positions

5. Cleanliness
a) Work areas, walls and floors are clean
b) Dirt and rubbish are stored and removed
regularly

6. Hygiene and welfare


a) Clean, well ventilated toilets
b) Suitable washing and changing facilities
c) Drying facilities for wet clothes
d) Suitable eating facilities and drinking water

7. Comfortable conditions
a) Reasonable temperature and ventilation
b) Sufficient space in rooms to work

Area to assess Aspect Hazard Observation

Building work 1. Construction work


a) Systems in place to ensure that all construction
regulations are followed
b) Proper planning undertaken before work begins
c) Good process in place to select competent
contractors
d) Suitable arrangements made to segregate work
from other people nearby, e.g. barriers, signs

2. Access equipment
a) Suitable ladders in good repair are available
b) Users trained to select/use ladders safely,
knowing:
i) When and how to use step ladders
ii) 4-to-1 rule for straight ladders
iii) Footing and tying off of straight ladders
326 THE MANAGEMENT OF RISK

Area to assess Aspect Hazard Observation

c) Ladders inspected regularly


d) Users aware they should not:
i) Overreach
ii) Carry heavy items or long lengths of material
iii) Carry tools other than in a shoulder bag or
holster
iv) Have only one hand free to hold the ladder
e) Use mobile tower scaffolds according to
manufacturer’s instructions, e.g. site on firm
ground, secure from strong winds, etc.
f) General access scaffolds erected by competent
people

3. Trucks and vehicles


a) Lift trucks not used as working platforms unless
fitted for the task
b) Site vehicles suitable for the terrain

4. Roof work
a) Safe access provided
b) Safe means of moving across the roof
c) Fragile roof marked out
d) Roof edge protection provided
e) Materials not thrown from roof so as to cause
injury
f) Permanent means of access provided where
necessary e.g. regular cleaning of skylights

5. Ground work
a) Digging work undertaken only after testing for
underground services
b) Trenches properly shored up

6. Other hazards
a) Paints, glues and cleaning materials are used
according to manufacturer’s instructions
b) Awareness of gasses to be found in confined
spaces
c) Personal protective equipment available and is
used
SYSTEMS AND TECHNIQUES 327

Area to assess Aspect Hazard Observation

Machinery 1. Suitability of machinery


safety
a) Adequate for tasks
b) Reputable supplier
c) Information provided from supplier

2. Maintenance of machinery
a) Properly maintained by competent people
b) Maintenance records available
c) Information on malfunction and corrective
actions kept

3. User information
a) Users trained in safe use of machines
b) Record of training kept

4. Specific hazards
a) Entanglement or trapping hazards safeguarded
b) Suitable guards provided

Area to assess Aspect Hazard Observation

Gas and 1. Energy supply


oil-fired
a) Installation checked and satisfactory
equipment
b) Isolation of supply simple and accessible
c) System in place for checking for leaks

2. Appliances
a) Appliances installed satisfactorily
b) Appliances maintained and repaired properly
c) Adequate ventilation for appliances
d) Appliances regularly serviced

3. Plant
a) Flame failure protection fitted as necessary
b) Portable equipment maintained so that correct
fuel/air ratios are in place
c) Operators fully trained to operate plant
328 THE MANAGEMENT OF RISK

Area to assess Aspect Hazard Observation

Plant and 1. Safe plant


equipment
a) Plant and equipment made safe before
maintenance
maintenance starts
b) Isolated/de-energised
c) Separated from pipelines/services
d) Lock off/tag out application
e) Moving parts stopped
f) Parts that could fall off supported
g) High temperature components cooled off
h) Mobile plant in neutral/braked/choked wheels
i) Vessels emptied of flammable/toxic materials

2. Confined spaces
a) Confined spaces identified
b) Work undertaken from outside where possible
c) Vessels isolated from hazardous materials
d) Rescue precautions taken prior to entry
e) Work in confined spaces does not generate
hazards from cleaning solvents, fumes, lack of
oxygen (tests taken)
f) Suitable tools used inside confined spaces
g) Low voltage lighting used

3. Safe work areas and procedures


a) Job cannot be done less frequently
b) Competent people chosen for the job
c) Safe access provided and safe workplace
d) Signs and barriers used for safety of worker and
passers-by
e) Formal work procedures and training is
necessary
f) Personal protective equipment is provided

4. Hand tools
a) Hand tools are properly maintained
b) Users inspect the tools before use
c) Only hammers without damaged shafts or
chipped heads and heads properly secured to
the shafts should be used
d) Files should have proper handles
SYSTEMS AND TECHNIQUES 329

Area to assess Aspect Hazard Observation

e) Chisels should be sharpened correctly


f) Screwdrivers should not be misused (as chisels,
levers, hammers) and should be in good
condition
g) Spanners should not be damaged e.g. splayed
jaws

5. Vehicle repair
a) Only competent people maintain vehicles
b) Brakes applied and wheels chocked before work
begins
c) Raised vehicles supported on axle stands, not
wheel jacks alone
d) Batteries not short-circuited, fuel removed safely

Area to assess Aspect Hazard Observation

Pressurised 1. Design and maintenance


plant and
a) All plant designed, constructed and installed to
systems
prevent danger
b) Systems properly maintained
c) Modifications and repairs satisfactory
d) Written scheme of examination available for
pressure systems, fittings and pipework
e) Good records kept

2. Safe operation
a) Work must be a pressurised system and lowest
practicable pressure system is used
b) Plant operated within stated operating limits
c) Operating instructions, including manufacturer’s
manuals must be available
d) Emergency instructions must be available

3. Pressure cleaning
a) Suppliers operating advice available
b) No risk from electrical hazards
c) Lowest pressure compressed air used
330 THE MANAGEMENT OF RISK

Area to assess Aspect Hazard Observation

Handling and 1. Manual handling (MH)


transporting
a) Only essential manual handling undertaken
b) Risk assessments made on unavoidable MH
tasks and controls to reduce risks identified
c) Mechanisation used where possible
d) Mechanical aids used where possible
e) Loads reduced in weight and awkwardness
where possible
f) Work system (e.g. layout, job rotation) designed
to reduce MH risks
g) Training provided for safe handling

2. Repetitive handling
a) Workforce aware that repeated/awkward
movements that are too forceful (e.g. gripping,
squeezing), too fast and unvaried, too frequent
can cause injury
b) People of different sizes are accommodated for
c) Workplace improvements considered, e.g.
reduce levels of force required, number of
movements, job pace/rotation

3. Safe lifting by machine


a) Certified lifting equipment used
b) Equipment checked and maintained properly
c) Equipment checked for condition, suitability and
damage before each use
d) Load properly attached to equipment before use,
e.g. slings, chains
e) Users competent and aware of lifting principles,
e.g. correct balancing, use of outriggers

4. Safe stacking
a) Stacked materials are unlikely to fall
b) Stacks on firm, level base and the racking is
sound
c) Safe loads known and not exceeded
d) Stacks are tidy – nothing sticks out
e) Heavy materials not stacked near to floor
f) Stacks/racks not climbed
g) De-stacking done safely
SYSTEMS AND TECHNIQUES 331

Area to assess Aspect Hazard Observation

5. Safe transport
a) Pedestrians are safe from vehicles
b) Vehicles used by competent trained people
c) Essential vehicle checks done daily
d) Good road/workplace markings for crossings,
parking, etc.
e) Lighting, visibility clothing, mirrors, audible alarms
used as necessary
f) Reversing of large vehicles supervised
g) Loading/unloading operations ok
h) Control over unauthorised drivers/passengers

Area to assess Aspect Hazard Observation

Noise and 1. Noise levels and risk


vibration
a) Noise exposures known (noise level and
exposure times)
b) Noise risks understood

2. Noise control
a) Suitable measures taken to reduce noise at
source should be taken (use quieter machines,
enclose noisy machines, use silencers on
exhausts)
b) Exposure reduced by removal of people after
suitable time
c) Noise zones marked

3. Hearing protection
a) Hearing protection available
b) Training in use of hearing protection given
c) Employees aware of noise risks and controls
d) Suitable medical checks done

4. Vibration risks and controls


a) Vibration risk from noise, power tools, lift trucks,
etc. known
b) Tools and equipment chosen with low vibration
levels in mind
c) Alternative ways of work considered to reduce
vibration risks
332 THE MANAGEMENT OF RISK

Area to assess Aspect Hazard Observation

d) Work system reduces vibration risks e.g. job


rotation, finger exercises to aid blood circulation,
etc.

Area to assess Aspect Hazard Observation

Radiations 1. Microwaves and radio frequencies


a) Door seals on microwave ovens, hinges, door
latch and safety interlocks OK
b) Radio frequencies from heaters, driers, presses,
etc. minimised and RF electrodes not accessible

2. Ionising radiations
a) Risk assessment made before any work begins
b) Applicability of Radiation Regs 1999 made
c) Applicability of Environmental regs made
d) Systems in place to notify HSE as required
e) Appointed persons in place as required

3. Infrared radiation
a) All IR sources identified
b) Protective clothing available and worn

4. Ultraviolet radiation
a) All UV sources identified
b) Users follow equipment maker’s instructions
c) Passers-by protected from stray UV light

5. Lasers
a) Users do not/cannot look directly into laser
beams
b) Laser beams not reflected into eyes
c) High-powered lasers in safety-interlocked
devices

6. Safety rules
a) Users provided with written safety rules/
procedures
b) Users trained in rules and training records kept
c) Equipment maintained as per supplier’s
instructions
d) Suitable protective equipment available
SYSTEMS AND TECHNIQUES 333

Area to assess Aspect Hazard Observation

Electricity 1. Installation
a) Low voltages are used where possible
b) Residual current devices are used where possible
c) Sufficient socket outlets provided
d) Fuses and circuit breakers correctly rated
e) Isolators close to each fixed machine
f) Mains switches readily accessible and identified

2. Insulation, protection and earthing


a) Power cables to machines properly installed
b) Flexible cables and plugs in sound condition
c) Plugs, sockets and fittings suitable for
environment
d) Fragile items suitably protected from damage
e) Appropriate equipment/methods used in
hazardous environments or with hazardous
materials

3. Safe operation
a) Work not done on live equipment/conductors
b) System in place to check and remove faulty
equipment
c) Users switch off before plugging/unplugging
d) Appliances unplugged when cleaned or adjusted

4. Maintenance
a) System for checking electrical installation and
equipment in place
b) All isolator/fuse boxes closed
c) Residual current circuit breakers checked

5. Electric shock
a) Training to deal with electric shock/poster
displayed

Area to assess Aspect Hazard Observation

Harmful 1. Risk assessments


substances
a) MSDSs are available for all substances used
b) The manner in which the substances can cause
harm are known
334 THE MANAGEMENT OF RISK

Area to assess Aspect Hazard Observation

c) The way that people use the substances


or could be exposed to them, routinely or
accidentally, is known
d) Occupational exposure limits are considered
e) Appropriate risk assessments have been
undertaken

2. Control measures
a) Risk assessments specify suitable control
measures
b) The control measures considered include:
i) Substitution
ii) Isolation or enclosure
iii) Local exhaust ventilation
iv) General ventilation
c) Checks made periodically to ensure control
measures are functioning properly

3. Housekeeping
a) All substances stored in labelled sealed
containers
b) Dangerous substances stored securely
c) Spillages cleared quickly and waste stored safely

4. Welfare and hygiene


a) Smoking, eating and drinking do not occur
where substances are handled
b) Proper washing facilities are available

5. Personal protective equipment (PPE)


a) PPE used as a ‘control measure of last resort’
b) PPE readily available and in good condition

6. Information and training


a) Hazards and risk assessment data available to
employees
b) Employees know of control measures and how
to apply them
c) Employees able to spot when things go wrong
d) Employees know emergency procedures

7. Record and review


a) Written risk assessments kept
SYSTEMS AND TECHNIQUES 335

Area to assess Aspect Hazard Observation

b) Review of risk assessments made periodically


c) Changes in activity prompts a review of risk
assessment

8. Specific hazards
a) Asbestos
i) Location known
ii) requirements of asbestos regulations applied
b) Lead
i) use in area is known
ii) requirements of lead regulations applied
c) Bacteria and viruses
i) exposure to legionella is minimised
ii) exposure to bodily fluids risks minimised
iii) exposure to animal-borne infections
minimised

9. Skin problems
a) Employees take suitable precautions including:
i) reading labels on containers and following
them
ii) keeping work spaces clean
iii) avoid skin contact and wear gloves

Area to assess Aspect Hazard Observation

Flammable 1. Inventory
and explosive
a) Alternatives to these substances are not possible
substances
b) A record of these substances and quantities is
kept
c) MSDSs are available for them

2. Storage
a) Materials, including empty containers, are stored
safely in well-ventilated areas
b) Ignition sources are minimised
c) Minimum quantities are stored
d) Flameproof cabinets are used as necessary
e) Incompatible substances are segregated
336 THE MANAGEMENT OF RISK

Area to assess Aspect Hazard Observation

3. Housekeeping
a) Flammable waste removed regularly
b) Workplace tidy and spills quickly cleared up
c) No build-up of materials in dust, ventilators, grills,
etc.

4. Flammable liquids and dust


a) Minimum storage in workplace
b) Bulk storage in separate properly designed area
c) Dispensing done safely
d) Hazards from flammable dust identified
e) Dust build-up avoided
f) Ignition sources controlled/reduced
g) Suitable ventilation, explosion vents, etc.

5. Gas cylinders
a) Cylinders properly stored outside in a compound
b) Cylinders in storage or use protected from
damage
c) Valves, regulators, hoses, torches, etc. checked
d) Only competent persons to use gas cylinders

6. Transportation
a) Substances are transported in suitable
containers or packages
b) All containers are suitably labelled
c) Vehicle is suitable for transporting flammable
substances
d) Only compatible substances transported
together
e) Emergency arrangements in place for
transporting substances
f) The recipient of the substances is provided with
all necessary data

7. Emergencies
a) Emergency procedures are in place
b) Staff are trained in use of procedures
c) Spillages/leakages can be dealt with properly
d) Any special first-aid requirements are available
SYSTEMS AND TECHNIQUES 337

Area to assess Aspect Hazard Observation

Safe systems 1. Work procedures


a) Work procedures establish the safe way to work
b) Sufficient work procedures exist to cover tasks
routinely undertaken
c) Less routine tasks, e.g. maintenance tasks,
should also be covered by procedures
d) Procedures ensure that equipment, tools, etc.
are suitable and OK for use
e) People are trained in the work procedures
f) Shift handover arrangements and leaving tasks
part finished are covered

2. Permits-to-work
a) Tasks that require formal permit-to-work
arrangements are identified
b) People are trained in the permit-to-work
procedure
c) Arrangements are in place to monitor that
permit-to-work procedures are followed

3. Lock-off procedures
a) Plant and equipment is isolated from power
supply before work on them begins
b) Formal physical lock off devices are specified
and used as required
c) People are trained in the lock off procedure

4. Review
a) Procedures are reviewed when changes occur
b) Procedures are reviewed on a periodic basis
even if no change to work practice occurs

Area to assess Aspect Hazard Observation

Accidents and 1. Emergency procedures


emergencies
a) Consideration has been given to what
emergencies might arise and a response plan
put in place
b) People know their role if an emergency arises
including how to summon help
c) There are enough marked emergency exits
338 THE MANAGEMENT OF RISK

Area to assess Aspect Hazard Observation

2. First aid
a) A first-aider or appointed person is available
b) A first-aid box is available and regularly checked
c) Notices are posted stating the location of the
first-aid box and the appointed person/first-aider

3. Reporting injuries and incidents


a) Company/organisation rules for reporting
accidents and incidents are known
b) Arrangements are in place to report as necessary
to enforcing authorities

4. Investigating accidents and incidents


a) An accident/incident investigation form exists
b) An accident/incident investigation procedure
exists
c) Suitable supervisory/management people are
involved in investigations
d) Causes of incidents are identified and measures
to prevent a recurrence result
e) Risk assessments are reviewed following
investigations

Area to assess Aspect Hazard Observation

Health care 1. Work-related ill health


a) Health hazards that may arise from work tasks
are known
b) Employees’ ill-health complaints are monitored

2. Mental health and stress


a) Work situations that may cause stress are known
b) Signs of stress can be recognised
c) Employee concerns/complaints are monitored
d) Assistance is provided for people who show
signs of stress

3. Drugs and alcohol


a) Supervisors are able to recognise signs
that alcohol, drugs, etc. are affecting work
performance
b) Procedures are in place to deal with/support
employees in these conditions
SYSTEMS AND TECHNIQUES 339

Area to assess Aspect Hazard Observation

4. Passive smoking
a) Arrangements in place to protect non-smokers

5. Health surveillance
a) Arrangements are in place for health surveillance
as necessary

Area to assess Aspect Hazard Observation

Personal 1. Selection and use


protective
a) PPE only used as ‘control of last resort’
equipment
(PPE) b) Selection takes into account who will wear it, for
how long and how much exposure is involved
c) PPE products chosen comply to recognised
standard
d) Users involved in selection of PPE (for suitability)
e) Instruction and training in use provided
f) Use of PPE combinations, i.e. eye and ear
protection, provides required protection
g) Users checked regularly to ensure PPE is worn

2. Maintenance
a) PPE is looked after, cleaned and stored properly
when not in use
b) Sufficient replacement/spares of correct type are
available
c) Sufficient supply of disposable suits for dirty jobs
available if necessary
d) Employees use PPE properly and report loss/
faults

3. Specific protection
a) Proper selection of PPE chosen/available for:
i) eyes
ii) head and neck
iii) ears
iv) hands and arms
v) feet and legs
vi) lungs
vii) whole body
viii) emergency equipment
340 THE MANAGEMENT OF RISK

Area to assess Aspect Hazard Observation

Selection and 1. Selection


training
a) Jobs that place particular physical/mental
demands on people are identified
b) Demands are reduced where possible
c) Essential health requirements for training in
specific tasks are followed
d) Ongoing medical examinations are undertaken
as needed
e) Post-illness medical reviews are done as
necessary

2. Training
a) Training needs for all levels of staff are
identified
b) Legal requirements for training in specific
tasks are followed
c) Special training needs of new recruits, young
people, trainees, part-time staff etc. are
identified and given
d) Training needs identified during investigations
e) Training provided by competent persons

2.6.12 Limitations of safety systems


There is a danger that arises from safety systems. The danger is simply that direc-
tors and managers believe that if an area conforms to the system requirements by, for
example, achieving a good outcome such as a high score when assessed against it, that
safety is assured. They fail to realise that however good a system may be, it is inherently
flawed. This is because each system is developed by people, assessed by people and
completed by people. People are, of course, fallible in creating the system and ingenious
when demonstrating adherence to it. If managers overburden their people to attain a
‘good result’ against the requirements of a safety system assessment they commit a
grievous error because real risks will be covered up.

2.6.13 Conclusion
Safety legislation has been on the statute book for many years but the development
of safety management as a subject is a recent innovation. It is now recognised that
the levels of safety expected by employees and the general public cannot be achieved
without utilising safety management strategies. So much has been written about the
SYSTEMS AND TECHNIQUES 341

subject that it is sometimes forgotten that conventional management techniques are just
as applicable to safety as to any other aspect of business. In particular the emergence of
quality management processes is highly relevant. The exact application of each element
of a cohesive practical safety management system depends on the area of business and
the aspirations of the organisation itself.
Effective safety management does not occur by chance. It arises out of a clear under-
standing of obligations and the application of considered strategies and techniques.
Managing safety does not exist in isolation from other aspects of the business. An
enterprise may change direction in terms of its business plan, its products or markets
which in turn results in increases or reductions in the number of employees, relocation
of premises and adopting changing technologies. In all these circumstances the obliga-
tions to the safety of its employees, customers and the public at large remain but it is
only the style and techniques applied that differ. Recognising changing operational
environments and adjusting the management techniques to suit are essential to improv-
ing safety. The principles outlined in this chapter remain constant. The techniques
described offer flexibility. Together they offer a pragmatic approach to safe working for
the busy manager.

Notes
1. Wilsons and Clyde Coal Co. Ltd. v. English (1938) AC 57 (HL).
2. Bett v. Dalmey Oil Co. (1905) 7F (Ct of Sess.) 787.
3. Edwards v. National Coal Board (1949) 1 KB 704, (1949) 1 All ER 743.
4. Munkman, J., Employer’s Liability at Common Law, 12th edn, Butterworths, London
(1996).
5. Health and Safety Executive, guidance booklet no. HSG 65, Successful Health and
Safety Management, HSE Books, Sudbury (1997).
6. British Standards Institution, OHSAS 18002: 2000, Occupational Health and Safety
Management Systems, BSI, London (2000).
7. British Standards Institution, BS EN ISO 9000, Quality Systems. Specification for the
Design/Development, Production, Installation and Servicing, BSI, London (1994).
8. British Standards Institution, BS EN ISO 14001, Environmental Management Systems.
Specification with Guidance for Use, BSI, London (1996).
9. Health and Safety Executive, guidance booklet no. HSG 65, Successful Health and
Safety Management, HSE Books, Sudbury (1997).
10. Chemical Industries Association, Responsible Care, CIA, London.
11. British Standards Institution, BS EN ISO 9000, Quality Systems. Specification for the
Design/Development, Production, Installation and Servicing, BSI, London (1994).
12. British Standards Institution, BS EN ISO 14001, Environmental Management
Systems. Specification with Guidance for Use, BSI, London (1996).
13. Health and Safety Executive, legal publication no. L23, Manual Handling. Manual
Handling Operations Regulations 1992, Guidance on the Regulations, HSE Books,
Sudbury (1998).
14. Peters, T.J. and Waterman, R.H., In Search of Excellence, Harper & Row, New York
(1982).
342 THE MANAGEMENT OF RISK

15. Health and Safety Executive, guidance publication, A Guide to Measuring Health and
Safety Performance, [Link]/opsunit/[Link]/.
16. Health and Safety Executive, guidance booklet no. HSG 65, Successful Health and
Safety Management, HSE Books, Sudbury (1997).
17. Pojasek, R.B., Five S’s: A tool that prepares an organisation for change. Environmental
Quality Management, pp. 97–103, autumn 1999.
18. HASTAM, CHASE, Health and Safety Technological Management Ltd, Fullbridge,
Essex, CM9 4LE.
19. Bird, F.E. and Germain, G.L. Practical Loss Control Leadership, International Loss
Control Institute, Loganville (1986).
20. British Safety Council, 5 Star Health and Safety Management System Audits, BSC,
London.
21. HASTAM, CHASE, Health and Safety Technological Management Ltd, Fullbridge,
Essex, CM9 4LE.

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