PAST Exam

Question 1

Explain the purpose and key features of each stage of the safety management the model described in the UK HSE document Managing for Health and Safety (HSG65)

Answer 1

The model starts with Plan, where we need to think about where we are now and where we need to be. What do we want to achieve, who will be responsible for what, how will we achieve our aims, and how will we measure success? We will need to write down this policy and the plan to deliver it. We also need to decide how we will measure performance, using leading and lagging indicators (active and reactive indicators) rather than just accident figures. Planning should also consider fire and other emergencies and the need to co-operate with anyone who shares the workplace, future changes and any specific legal requirements that apply to the organisation.

The Do stage starts with identifying the organisation’s risk profile, assessing the risks, identifying what could cause harm in the workplace, who it could harm and how, and what needs to be done to manage the risk. From this, priorities can be identified (i.e. the biggest risks). Activities need to be organised to deliver the plan, including involving the workforce and providing adequate resources and competent advice. To implement the plan we need to decide on the preventive and protective measures required and put them in place. These can include providing and maintaining the right tools and equipment to do the job, training and instruction to ensure competence and supervision to make sure that the arrangements are followed.

Check involves measuring performance to make sure that the plan has been implemented. We need to assess how well risks are being controlled and investigate the causes of accidents, incidents or near misses. In some circumstances formal audits may be useful

The final Act stage requires review of performance and learning from accidents andincidents, ill-health data, errors and relevant experience, including experiences of other organisations. We can then revisit plans, policy documents and risk assessments to see if they need updating and take action on lessons learned, including those from audit and inspection reports.

Question 2

A multi-site business has a quality management system compliant with ISO 9001. It also has a health and safety management system and an environmental management system that operates independently. The Board of Directors is now considering the possibility of developing an integrated management system encompassing all three elements. In order that a decision can be made objectively, prepare a brief for the board that outlines the key potential benefits of:

(a) An integrated management system.
(b) Retaining the existing system of separate management systems.

Answer 2

(a)
Consistency of format - integration will require that a consistent format is applied to all three areas. The same basic philosophy underpins each area (conformance to a standard) and therefore the same management process and language can be applied to each.

Avoidance of duplication of procedures - consistency of approach reduces duplication, leading to efficiencies. These efficiencies might show in terms of indirect labor costs, productivity increases, and reduction in direct labor paperwork. Record-keeping - (as referred to above) since systems are integrated, personnel will look at three areas of concern once rather than looking at three separate areas of concern independently.

This should lead to improved record-keeping and a reduction in the amount of paperwork generated by the three independent systems.

Auditing - once integrated, all three management areas will be audited together.

Certainly from an internal audit perspective, this should lead to improved auditing across three areas and may lead to a reduction in the time taken to audit. In short one audit will look at one management system rather than conducting three separate audits to look at three separate management systems.

Software - the integration of management systems will require the integration of software systems. Again this should lead to efficiencies in time spent interacting with the system.

Holistic solutions rather than just optimizing for quality or environment - one of the major benefits of integration is that a holistic approach is adopted. Unlike current arrangements, where one system (and therefore the personnel who run that system) is looking at one area of improvement and has little interest in improving other areas, the integrated system gives ownership of all three areas to all personnel. Therefore it is in everyone’s interest to see improvements across the board. In other words, with an integrated system an improvement that enhances quality but is detrimental to environmental performance is not seen as worth making. One that enhances health and safety (H&S) and has no negative impact on environment and quality is worth making.

Synergy - another key benefit of the integrated system approach is synergy; i.e. the idea that benefits from one area can be applied to other areas and that when this happens the whole becomes greater than the sum of the parts.

One final benefit of integration is that it encourages interaction between specialists and will require specialists to branch out into other areas of knowledge.

Though specialists may retain a higher level of competence in a chosen area, they will have to develop their competence in other areas.

This can be of great benefit since cross-pollination of ideas should then flow within the organization; there is greater sharing of knowledge and practice and less ring-fencing of know-how.

(b)
Flexibility - current arrangements are highly flexible. This is especially the case with the SMS and EMS since these are not in compliance with an external system and can be operated as we see fit. The QMS is less flexible since it is ISO 9001 compliant and therefore must meet external standards in order to retain certification. It must be recognized that in order to retain this certification, any integration of systems would have to remain ISO 9001 compliant. This complicates the integration process.

Safety standards set by legislation, quality set internally - while the general philosophy of all three systems is the same (conformance to standard) both H&amp’S and environmental systems are driven by the need to comply with the law. Quality, however, is driven by our own internal need to meet customer expectations. Current arrangements allow internal standards to carry equal weight with legal standards. Integration may lead to more weight being given to legal standards and a dilution of quality standards as a consequence.

May not need such a complex system in one area compared to another - integration inevitably leads to complexity because the need to achieve compliance in one area ripples out across all three areas of concern. This can lead to an over-complication of systems. The QMS is driven by the requirements of ISO certification. This might therefore drive complexity into the SMS and EMS.

Why fix what isn’t broken? All three management systems are functioning acceptably across the multi-site operation and look to be working well. Any attempt to change these systems may lead to disruption (at least in the short term) for little benefit.

Integration may be a costly exercise - inevitably there are costs associated with integration. An IMS will have to be selected, tailored to our needs, and then implemented across the whole operation. Personnel, both specialists and others, will require re-training in new systems. The potential for business disruption exists, which may have unforeseen cost implications.

May encourage more detailed auditing if kept separate - current audit arrangements require a detailed focus on the three areas of concern independently. This separate focus does mean that greater scrutiny is applied to each topic area.

Specialists stay specialists - the current system requires that QMS staff are specialists in quality management only. The same applies to EMS and SMS staff. These staff have developed their competence over years of practice and study. Retaining the current system allows these people to stay specialists, rather than requiring them to move into other areas where they have little or no experience or knowledge and therefore no competence.

Question 3

A financial review within your organisation has resulted in a proposal to the Board of Directors to cut its health and safety budget and to cancel a capital project that was designed to lead to significant improvements in the working environment.

As the organisation’s Health and Safety Manager, explain why this proposal should be rejected and justify your opinion. (20)

Answer 3

The report will argue for the rejection of this proposal based on three basic principles: the sound economic argument that underpins good health and safety management within this organisation, the legal implications of failing to manage health and safety effectively, and the moral imperative. Each of these arguments will now be discussed in detail.

The Economic Argument

Health and safety (H&S) failings cost money; in fact they can cost a lot of money. And while it is true that putting good H&S standards in place also costs money, the costs associated with failures far outweigh the costs of implementation.

There are two ways in which this organisation may fail to ensure H&S - one is a failure to ensure safety. This leads to accidents. The other problem is failure to ensure health; this leads to ill-health, sickness and chronic disease. Both accidents and ill-health have direct costs associated with them. For example, a workplace accident leads to production downtime, damage to equipment, plant and premises, and loss of product. Damaged equipment and premises must be repaired or replaced. This in turn usually leads to indirect losses to the organisation - losses that do not stem directly from the event itself, but flow from it as inevitable consequences. Lost product must be re-made, which incurs overtime or additional labour costs.

Personnel who have been injured remain absent from the workplace; they are paid full salary during their absence and at the same time the organisation has to employ temporary labour to cover their work. In some instances this temporary labour solution cannot be applied and then other workers in the workplace have to pick up the work of their absent colleague. This leads to overworking, fatigue and stress which in turn leads to an increase in human error and higher absenteeism.

While some of the costs highlighted above are quite apparent, some may be hidden to the organisation; others are non-discoverable in nature. If industrial relations are severely damaged by a workplace accident, that reflects in poor productivity, higher absence rates and reduced efficiency. But how could that be exactly costed out? The answer is it cannot be. If bad publicity were to result from a workplace accident, that might have a direct effect on our customers’ willingness to do business with us. Again, this could be a very significant cost that would be difficult to quantify and discover.

The above arguments relate to workplace accidents and ignore the cost implications of work-related ill-health. Occupational ill-health often results from poor working conditions and poor working environments. It almost invariably leads to workplace absence and, in some instances, may be severe enough to warrant dismissal on medical grounds. There are costs associated with the worker absence, the management of that absence and the legal action that often results from such ill-health and dismissals, not to mention the poor industrial relations and PR that can accompany such illnesses.

Studies which have analysed workplaces looking for the costs associated with workplace accidents suggest that the uninsured losses to an organisation are greater than the insured losses by a factor of 8× as a minimum. In other words, our insurance company cannot be approached to fund the vast majority of losses that we incur when we injure people at work or make them sick. We fund those losses ourselves None of the above included any comment about the financial implications of legal actions, which this report will now move on to consider.

The Legal Argument
There are legal standards that we must comply with and failure to comply can lead to enforcement action being taken against us in the form of legally binding notices that require us to carry out such improvements or to stop certain activities. This enforcement action invariably carries with it the costs associated with carrying out the improvement to the enforcement officer’s timescale, or stopping an activity that we find to be financially beneficial. This is not to mention the bad IR and PR that is usually associated with these enforcement notices. In other instances, failure to achieve legal compliance may result in prosecution. Directors may also face personal liability for legal failing of the organisation that they direct. Needless to say, all of the above legal actions carry with them the risk of incurring huge legal fees in mounting a defence (and paying the prosecution legal fees in the event of the case being lost) In addition, injure a worker, or cause ill-health, and we may well be sued by the injured party. These cases may result in the payment of compensation to injured victims. Though this money may come from our insurers in the first instance, it invariably leads to higher insurance premiums in the short- and long-term as those insurers attempt to claw back their losses from us.

The Moral Argument
We have a clear policy obligation to our staff to ensure their ongoing health, safety and welfare. That has been made clear in the statement of intent signed by our Managing Director as the headline of our H&S policy. Aside from the legal and financial arguments discussed above, we must also consider the huge personal impact of accidents and ill-health that can and do occur as a result of our H&S standards. One worker may be injured or made ill, but that one person has a family, friends and colleagues. The impact of a serious accident or case of ill-health has wide-ranging implications.

We must reflect on our own personal values and decide whether we would wish to see the unpleasant and sometimes tragic consequences of poor H&S standards occurring in our organisation. In conclusion, I would state that cutbacks cannot be made to the H&S budget, nor to the capital project, on the basis of the three arguments described above. We owe it to ourselves, to our workforce and to our shareholders to retain our H&S budgets so that we are best able to avoid the losses that workplace accidents and ill-health might cause.

Question 4

An organisation is proposing to move from a health and safety management system based on the ILO-OSH-2001 model to one that aligns itself with BS OHSAS 18001. Outline the possible advantages and disadvantages of such a change

Answer 4

ILO-OSH-2001 is a model that the regulators have championed for a number of years; one of the advantages of this system is that it is simple and straightforward for all types of companies to implement without too much trouble (which isn’t the case for 18001 for smaller companies). The system doesn’t need any certification by an outside body and it follows a tried-and-tested system which has been used by quality organisations for a number of years. Moving from ILO-OSH-2001 to BS OHSAS 18001 would mean that the company would need to bring in an external organisation to accredit the system, which will bring additional initial and on-going costs to the organisation – including extra paperwork and activities to source information, procedures, etc. This would strengthen the organisation’s image, as accreditation is done by an outside agency, rather than in-house as per ILO-OSH-2001 and by achieving the standard the company would be able to promote its business within the local community and secure orders/work with organisations that require an accredited standard for you to work with them.If the organisation already has other accredited systems (environmental, quality), they may be able to integrate the systems to save money for the organisation, as well as supporting the organisation embed health and safety into the organisation. Other benefits from moving to this system would involve undertaking the initial review and measuring its current practices, to ascertain where improvements can/should be made and actually measuring the improvements it has made.The final thing to consider with the new system would be that 18001 looks at continuous improvement as one of its central themes, so the organisation can look at getting better performance over a period of time.

Question 5

An organization has decided to adopt a self-regulatory model for its health and safety management system.
distinguish between:

(a) the benefits; and (6)
(b) the limitations of self-regulation in connection with the management of health and safe

Answer 5

(a)
One of the more important benefits of self-regulation is that it is developed by those directly involved in the management of health and safety and this can generate a sense of ownership. Other benefits include the fact that it may be quicker to achieve than statutory regulation and can result in higher levels of compliance. It can also be easily adapted or updated and may offer a cheaper and quicker means of addressing issues. Finally, the application of self-regulation may result in a closer relationship between industry and its clients.

(b)
Key limitations of the model are that all those involved may not operate within the self-regulatory rules and that there is a danger of self-interest being put ahead of employee or public interest. Additionally, self-regulation can result in lower levels of compliance because there is no third party or independent auditing and it may not be valued highly by stakeholde

Question 6

(a)Outline the benefits and limitations of prescriptive legislation. (5)
(b)Outline the benefits and limitations of goal-setting legislation. (5)
Give examples in both cases to illustrate your answer

Answer 6

(a)
The benefits of prescriptive legislation are that its requirements are clear and easy to apply and it provides the same standard for all. It is not difficult to enforce and does not require a high level of expertise.Its limitations are that it is inflexible and may be inappropriate in some circumstances by setting standards too high or too low. It does not take account of local risks and may need frequent revision to keep up with changes in technology and knowledge

(b)
The benefits of goal-setting legislation are that it has more flexibility in the way compliance may be achieved and it is related to actual risk. Also it can apply to a wide variety of workplaces and it is less likely to become out of date.These benefits are countered by the fact that it may be open to wide interpretation and the duties it lays down and the standards it requires may be unclear until tested in courts of law. As a result it may become more difficult to enforce and may require a higher level of expertise to achieve complianc

Question 7

(a)Outline the meaning of the phrase ‘punitive damages’ in the context of a compensation award, and clearly identify the purpose of these damages and to whom they are paid. (5)

(b)

(i) In the context of claims for compensation, outline the meaning of the term ‘no fault liability’.
(ii) In the context of claims for compensation, outline the meaning of the term ‘breach of duty of care’.

Answer 7

(a)“Punitive damages”, are a financial or monetary award which, while paid to a claimant, are not awarded to compensate them, but in order to reform or deter the defendant and similar persons from pursuing a course of action such as that which damaged the claimant. As such they are both a punishment and a deterrent. The amount of the award is determined by a court and is not linked to the losses suffered by the claimant.

(b)
(i) “No fault liability” is a liability which is independent of any wrongful intent or negligence. As such, an injury alone is sufficient to confer liability with compensation being paid either by an insurance company or from a government fund.

(ii) There are three standard conditions that must be satisfied in order to establish a breach of duty of care. These are that a duty of care was owed by an employer to his employee; that the employer acted in breach of that duty by not doing everything that was reasonable to prevent foreseeable harm and lastly that the breach led directly to the loss, damage or injury.

Question 8

(a) In relation to the improvement of health and safety within companies, describe what is meant by:
(i) corporate probation;
(ii) adverse publicity orders;
(iii) punitive damages.
(b) Outline the mechanism by which the International Labour Organisation can influence health and safety standards in different countries.
(c) Explain the role of legislation in improving workplace health and safety.

Answer 8

(a)
(i)Corporate probation is a supervision order imposed by a court on a company that has committed a criminal offence. When applied to a health and safety offence, the court might require the company to review its safety policy or health and safety procedures, initiate a training programme for its directors and senior management or reduce the number of its accidents. The aim is to instigate a change in the organisation’s culture under the supervision of the court

(ii) The intention of an adverse publicity order would be to publicise the failings of an organisation and seek to change its conduct through public perception. It requires the company to make a public statement and to change its approach to the management of health and safety.
(iii) “Punitive damages” is a financial or monetary award which, while paid to a claimant, is not awarded to compensate them, but in order to reform or deter the defendant and similar persons from pursuing a course of action such as that which damaged the claimant. As such it is both a punishment and a deterrent. The amount of the award is determined by a court and is not linked to the losses suffered by the claiman

(b)
The ILO develops international labour standards through conventions. These are supplemented by recommendations containing additional or more detailed provisions. Ratification of conventions by member states commits them to apply the terms of the convention in national law. There is also a requirement for member states to submit a report to the ILO detailing their compliance with the requirements of the conventions that they have ratified. The ILO can also initiate complaint procedures against countries for a violation of a convention that they have ratified and also provide technical assistance to member states where this is necessary. In addition ILO can also apply pressure internationally on non-participating countries to adopt ILO standards.

(c)
Legislation improves workplace health and safety by setting minimum standards which can be enforced by a regulator and allowing punishment of the offender if standards are not achieved. It is kept up to date by government and applies to all workplaces ensuring consistent application. The legislation may be prescriptive, or goal-setting, supported by approved codes of practice or guidance to assist interpretation of standards required

Question 9

Non-governmental bodies have an important role in influencing health and safety standards.
Identify FIVE relevant influential parties and outline their role in influencing health and safety performance

Answer 9

Employer Bodies
These represent the interests of employers. In the UK the main body is the Confederation of British Industry (CBI). The CBI helps create and sustain the conditions in which businesses in the United Kingdom can compete and prosper for the benefit of all. The CBI is the main lobbying organisation for UK business on national and international issues. It works with the UK government, international legislators and policy-makers to help UK businesses compete more effectively.

Trade Associations
Trade associations are formed from a membership of companies who operate in a particular area of commerce and exist for their benefit. They can promote common interests and improvements in quality, health, safety, environmental and technical standards. This can be through various appropriate means. For example, the publication of guidelines, information notes, codes of practice and regular briefing notes on technical issues and regulatory developments. Sharing of good practice can be facilitated together with provision of news and events appropriate to their members’ areas of activity.There can also be meetings, workshops and seminars held, depending on an association’s membership, both internationally and at a national/regional level, to enable networking and the exchange of information and ideas, for example on technical and safety issues Safety is of prime importance in any industry and there is usually a way of publicising and circulating safety messages to the members on a regular basis.Membership of a trade association is generally available to companies and organisations active in the relevant industry.

Trade Unions
A trade union is an organisation of workers who have formed together to achieve common goals in key areas such as wages, hours, and working conditions. The trade union negotiates with the employer on behalf of its members and negotiates contracts with employers. This may include the negotiation of wages, work rules, complaint procedures, rules governing hiring, firing and promotion of workers, benefits, workplace safety and policies. The agreements negotiated by the union leaders are binding on the rank and file members and the employer and in some cases on other non-member workers. In the UK, Unions may appoint safety representatives from amongst the workers who may investigate accidents, conduct inspections and sit on a safety committee.

Professional Groups
A professional group is an organisation of individuals who work in a particular profession and have achieved a defined level of competence. Members typically pay a subscription to join the group and receive a range of benefits. In the UK, the Institution of Occupational Safety and Health (IOSH) is the largest body for health and safety professionals. It is an independent, not-for-profit organisation that sets professional standards, supports and develops members and provides authoritative advice and guidance on health and safety issues.

Pressure Groups
A pressure group is an organised group of people who seek to influence government policy or legislation. They can also be described as ‘interest groups’, ‘lobby groups’ or ‘protest groups’. They carry out research, lobby members of parliament and so aim to influence public and ultimately government opinion. One example in the UK is the Centre for Corporate Accountability. This is concerned with the promotion of worker and public safety. Its focus is on the role of state bodies in enforcing health and safety law and investigating work-related deaths and injuries

Question 10

Companies are subjected to many influences in health and safety.

(a) In contract law, identify what is meant by express terms.
(b) Outline how influential parties can affect health and safety performance in a company

Answer 10

(a) Express terms in contract law refer to the specific details mentioned and agreed in the contract. They cover unusual circumstances, but shouldn’t include unfair terms.
(b) Different groups can affect the H&S performance of a company; these can be by employers’ bodies, who can set standards to follow for its members, trade unions who influence their members and provide H&S advice, insurance companies who impose conditions of operation, design and management on companies, ILO who publish advice and guidance and enforcement of standards as well as the media who will publish information of company ethics and conditions to the local or national community

Question 11

Witnesses can often provide essential information for accident investigations. Describe the various issues to think about during the interview process so that the best quality of information relating to a workplace accident can be obtained from witnesses

Answer 11

The first requirement is to interview as soon as possible after the event although injury or shock may make this difficult. The interview should be carried out in a suitable environment where the witness can be put at ease. Only one witness should be interviewed at a time, with the interviewer taking time to establish good rapport. The purpose of the interview should be explained, that of preventing a recurrence and not to apportion blame, and also the need to record the findings. Questioning techniques should establish facts and avoid leading questions or implied conclusions. Sketches and photographs may help with the interview. Finally, the witness should be listened to without interruption, given sufficient time to answer, and the issues discussed should be summarised and agreed at the end of the intervie

Question 12

An accident has occurred where a forklift truck skidded on a patch of oil and collided with an unaccompanied visitor, causing a crush injury to their leg.

(a) Outline, with justification, why the accident should be investigated.
(b) Outline the actions necessary to collect evidence for the investigation of the accident. Assume that the initial responses of reporting the accident and securing the scene have taken place.
(c) Describe the factors which should be taken into account when analysing the information gathered as evidence

Answer 12

(a) The accident should be investigated for various reasons. First, investigation allows for the identification of the immediate and underlying causes of the accident and the various factors that may have contributed to it. This in turn should allow for the identification of the corrective actions necessary to prevent a recurrence of this event and others like it.Second, any investigation gives the organisation a good opportunity to assess its compliance with legal requirements and best practice. Third, an investigation provides an opportunity for management to demonstrate a clear commitment to health and safety and show that they are interested. This has a direct impact on the safety culture of the organisation and on employee morale. Indeed, employee morale would suffer badly if the event were not investigated.Fourth, the factual evidence collected during the investigation will be vital in deciding liability issues should there be a civil claim for compensation based on this accident
(b) Assuming that first-aid assistance has been given to the injured visitor, and that the scene has been secured, the first actions must be to collect evidence from the scene itself before that evidence becomes contaminated. This would be done by photographing the scene, or perhaps even videoing it, drawing sketches and taking measurements to annotate that sketch. It would also be appropriate to write a brief description of the scene including any additional information that may be relevant but that is not apparent from photographs or a sketch, (e.g. a loud tannoy, or high or low ambient temperatures in the workplace). CCTV footage may be available and should be secured.Factual information about the environment around the accident scene must also be gathered, so the condition of the floor, light levels, markings on the floor, the presence of pedestrian walkways and signage must all be recorded in some way. The oil patch must be photographed in situ before clear up and perhaps a sample taken as evidence.The position of the forklift truck must be carefully recorded and any forensic evidence that shows its route must also be noted (such as skid marks on the floor, collision marks on surrounding structures such as racking, etc.). The FLT must also be carefully examined to determine its condition and the acceptability of its safety-related features. This examination should also take into account the position of any load on the FLT and the capacity rating of the F LT.The oil spill on the floor will have to be investigated in more detail to determine its source and the reasons for its presence on the floor.Failures in the spill detection and clear-up procedures may be identified.Following investigation of the physical evidence, the background documents and records must be scrutinised and copies may have to be taken. Risk assessments, safe systems of work, operating procedures, FLT maintenance and inspection logs, training records and other company documentation will all have to be examined.Another vital source of information must also be addressed during the investigation and that is, of course, the witnesses. The FLT driver should be isolated from other people to prevent possible contamination of their evidence. They should be interviewed about the event as soon as possible to prevent the natural process of reviewing an event and then embellishing it. Other witnesses would also be interviewed as soon after the event as possible, including the injured party, although this may depend on their availability. Other personnel who did not directly witness the scene, but who have information relevant to the investigation, may also be interviewed and this would include reception staff who greeted the visitor to site, and maintenance personnel who recently carried out work on the FLT

(c) The various factors that will have to be analysed in order to determine the causes of this accident can be thought about in various ways, but one way that might be useful is to consider organisational, job and personal factors.Organisational factors that should be considered in the analysis would include:ƒ
- The safety culture of the organisation, especially as perceived by the staff and the FLT driver.
- Peer group pressure and the influence of this on the behaviour of the driver (he may have been speeding because to drive slowly is considered unmanly) and the visitor (they may have been in a group of peers and behaving recklessly).
- Pay and reward schemes in operation.
- The FLT driver may have been incentivised to drive fast due to the pay and reward system.
- Personal factors that should be considered would include:

The basic personality traits of the driver, their attitude towards health and safety in general and pedestrian safety in particular.

• Their training in FLT driving, including basic skills training, job-specific training and any induction training they may have had into the workplace.ƒ
• The FLT driver’s experience and their general reliability and competence level.
• The intelligence level of the driver and their ability to understand instructions.
• The driver’s fitness as assessed against the fitness criteria that exist for FLT drivers.

ƒFactors that may have compromised the driver’s ability to function correctly, such as fatigue, stress, drugs and alcoho

Job factors would play an enormous part in the analysis and the following factors would have to be considered:

ƒSignage in the workplace, markings on the floor and the provision of barriers to segregate pedestrians and vehicles.The levels of supervision in the workplace.

ƒProcedures and rules in place to govern the movement of visitors around the site.

ƒProcedures and rules relevant to the movement of FLTs within the workplace.

ƒMaintenance, testing and inspection regimes in place for the FLT.

ƒShift patterns, hours of work and workload allocation within the workpla

Question 13

Accident investigations can vary in terms of duration, size and specialisms of the investigation team and resources allocated.

(a) Explain why it is important for an organisation to investigate workplace accidents.
(b) Outline the factors that would influence the level of investigation required following a workplace accident.

Answer 13

(a)
There are many important reasons why an organisation should investigate workplace accidents. These might be considered under the following areas:

ƒIdentification of causes. The true causes of an accident must be discovered if any form of effective corrective action is to be taken. It is important that the true underlying causes are identified as well as the immediate causes. These principles are clearly identified in both the simple domino theory of accident causation as well as the more complex multi-causality theory.

ƒTo take corrective action to prevent recurrence. Unless the true root causes and underlying causes of accidents are known, then effective corrective action to prevent recurrence cannot be identified and taken. The prevention of accidents is a legal, moral and economic imperative for an organisation.
Underlying deficiencies in safe systems, risk assessments, etc. must be identified and corrected. Even though these deficiencies may not have directly led to a particular event, they will contribute to future accidents in the workplace. Deficiencies must be addressed in the interest of continuous improvement.

ƒInvestigations can be used to determine cost (financial) to an organisation. This may be important as a way of promoting good health and safety internally, by highlighting the financial impact on the organisation of failure.ƒGood accident investigation is vital for worker morale and helps to promote a positive culture by involving people in a practical way in health and safety in the workplace. In the absence of visible investigation, workers will make their own minds up about the organisation’s priorities and they may form negative views.

ƒAccident investigation may be a necessity in order to gather information for legal requirements regarding accident reporting.

ƒFinally, accident investigation is often mandatory under insurance policies for the simple reason that an accident may result in a claim for compensation. In such an event the insurance company must have good quality factual information, gathered at the time of the accident, in order to make an informed decision about liability; do they fight the claim or pay out

(b)
The various factors that might influence the level and complexity of an accident investigation would include the following:ƒSeriousness of the event. Accidents that have minor outcomes may not require detailed, complex investigations because they had minor outcomes. No one was seriously hurt; there will not be a claim for compensation, so why spend a lot of time and effort investigating? This argument can be effectively applied to some accidents but not all (as we shall discuss next).ƒPotential seriousness. Accidents that result in minor injury, or minor property damage and even near misses, can have the potential for very serious outcome. That outcome was not realised in this instance, but the possibility existed. Therefore, one factor that is crucial to examine is the potential of an event to have serious outcomes in terms of severity of injury caused and/or number of people involved. Where there is the potential for high severity outcomes, then a more detailed and complex investigation would be warranted. Where that potential does not exist, then a simpler, quicker investigation will suffice

Nature of accident. Many accidents are very simple in their causation. They take little time to investigate and little time to analyse. A complex and in-depth investigation is not going to reveal any hidden depths and therefore is unwarranted. An organisation can learn all it needs to know with a simple, quick investigation.ƒPermits-to-work. Any event involving permits-to-work (PTWs) will be, by the very nature of PTWs, high-risk work and often complex high- risk work. It is therefore often sensible to undertake a thorough and detailed investigation to ensure that the permit system is working correctly. Any accident occurring under permit control implies a failure of the permit system itself and therefore must be taken seriously (if the permit system was working well, then the accident would not have happened).ƒAny event that results in the necessity to report to the enforcing authorities should be investigated in more depth and detail because of the reporting requirements. This is not because a complex investigation is required to discover the facts of the event. Often these events are relatively simple. Instead, it is because of the potential involvement of the enforcer at some stage after the event has been reported. Site visits, enforcement actions and ultimately prosecution may result from the report and therefore it is in the interest of the organisation to collect detailed factual information should the need arise.ƒSimilarly, any event which seems to indicate that there has been a breach of legal requirements (and possible enforcement action that may follow) must be investigated to a higher degree.Finally, as was mentioned above, any event that appears to involve significant injury or loss to a person, and therefore may result in a civil claim, should be investigated in more depth and detail because of the liability issues that may rest on having detailed factual evidence and analysis from the time of the eve

Question 14

Witness interviews are an important part of the information-gathering process of an accident investigation. Describe the requirements of an interview process that would help to obtain the best quality of information from witnesses

Answer 14

Following an accident you would need to investigate witnesses of the events to establish the facts; to do this you need to undertake an interview of the witnesses.The process should take place in a non-confrontational manner, as soon as possible after the event, to keep the facts fresh and untainted by others’ accounts/recollections.The room itself should be somewhere that is non-threatening, i.e. not the manager’s office, and should start in a relaxed manner with an introduction of why the interview is taking place and the need to establish facts to prevent re-occurrence of similar type of incidents in the future, and learn from what went wrong and why.Questions should be open, to get responses which give information to the interviewer; the interviewer should allow witnesses time to answer questions and avoid interruptions and putting words into their mouth. The interviewer should have an open mind about the incident and make sure they listen sympathetically; sometimes they may need to highlight that they aren’t the best person to interview the witness as they may be part of the causal factors of the incident.Pen, paper, plans, documents, etc. should be available to talk about/discuss at interview, as well as for the interviewer to use to capture the facts. The interviewer should clarify what they think the witness has said or meant, because things often get mistaken in the process.The language used should be appropriate to the incident; summarise the interview and let the interviewee know that they can always come back later with anything else they may remember about the incident

Question 15

(a) Usingexamples, explain the differences between active and reactive systems for monitoring health and safety performance. (6)
(b) Outline FOUR limitations of using accident and ill-health data as a means of measuring health and safety performance. (4)

Answer 15

Active systems measure the compliance with standards, whereas reactive monitoring measures previous failures in performance, enabling an organisation to learn from its mistakes. Active measures are often referred to as leading indicators, since they measure achievement of objectives and targets and therefore indicate the direction that the organisation is currently taking. Reactive measures are often referred to as lagging indicators since they reflect where the organisation has already been - its history, in effect. Completion of safety inspections might be used as an active measure; number of accidents during a time period might be used as a reactive measure.

Reactive data, such as accident and ill-health statistics, can be seen as rather limited because they measure failure, even though there might have been successes in other areas. They are therefore inherently negative. This data as a measure of performance provides only a prediction, rather than a determinant, for the future. The data lags current performance; it does not lead current performance. Health statistics can be very limited, simply because occupational diseases have a long latency period, so current data reflects workplace standards that existed years previously. One final limitation of reactive data is that they are extremely reliant on good reporting systems. Poor reporting leads to poor data quality and consequently poor meanin

Question 16

A national campaign aimed at improving standards of health and safety in a particular industry has been deemed a failure due to a significant increase in the rate of reported accidents over the period of the campaign.Explain why accident rates may have proved a poor measure of the campaign’s effectiveness and identify other measures that might have been used

Answer 16

Accident rates may have been a poor measure to use to indicate the success of the campaign because there may have been under-reporting of accidents prior to the launch of the campaign. This under-reporting would have led to an artificially low accident rate. The campaign would then have raised awareness of safety issues within the industry.

This draws people’s attention to safety and accident reporting. As a result, accident reporting improves despite the fact that the underlying accident rate might not change at all or might even go down. Consequently the apparent accident rate increases during and after the campaign.

This is a common occurrence as safety awareness improves within industries and organisations.Other techniques that might have been used as an alternative to accident rates to measure the effectiveness of the campaign might have included:

Auditing workplaces before and after the campaign to get an in-depth view of safety management systems and their effectiveness.

Safety inspections of sites to gather a snapshot of the standards within workplaces and the standards of behaviour.

Safety sampling exercises where representative numbers of workplaces are visited before and after the campaign to make reliable predictions about the industry as a whole

Attitude surveys given to workers before and after the campaign to see if there was any change in workers’ opinions about safet

Question 17

As a health and safety practitioner advising at a large organisation, you have decided to develop and implement an in-house auditing programme for the organisation’s health and safety management system.Describe the range of organisational and planning issues that would need to be addressed in the development of the audit programme. Note that you do not need to identify the specific factors to be audited.

Answer 17

The organisational and planning issues that would have to be addressed would include:

ƒCorrectly identifying and then gaining the resources required (money, time and personnel) through careful planning and analysis.

ƒGaining the support of directors and senior managers so that:
–Those resources are made available.–Access is authorised to all of the necessary information and personnel across the organisation.
–Access to the senior managers themselves during the audit process is agreed.

ƒThe scope of the auditing to be carried out must be decided upon; will the audit stick to health and safety issues, or range across other areas as well? And which parts of the organisation are to be audited? These will be particularly important questions to answer with regards geographic locations to be audited and consequently the legal standards that will apply.

ƒThe type of auditing will also need to be decided upon. Will a proprietary system be purchased, or will one be developed from scratch internally, or a combination of the two? The manager will have to decide on whether to use a scored audit system or one more reliant on narrative judgments. A software system may need to be purchased to run the audit system, and again, decisions will have to be taken as to the type of software and resource requirements.

An audit schedule will have to be designed, taking into account the resources made available for conducting audits, the size of the organisation and the frequency required. The frequency of auditing may have to vary from one part of the organisation to another, depending on the risk level presented by the different parts of the organisation.

ƒSome thought will have to be given to the personnel who will carry out the audits. Their time will have to be secured as well as their personal commitment to the process. Training and ongoing support will have to be made available and this may have to be supplemented with background knowledge building as well. This will, of course, require the co-operation of their managers.

ƒThe methods used to provide feedback on audit findings, the type of feedback given, the methods used for resolving disagreement with feedback and the review process will all have to be considered and finalised.

ƒConsideration must be given to how the audit programme will be launched. This might involve clear communication of the programme, its aims, methods and processes through various media. A test pilot may have to be carried out to ensure the efficient working of the system and the acceptability of the scheme to others

Question 18

An advertising campaign was used to promote improvement in safety standards within a particular organisation. During the period of the campaign the rate of reported accidents significantly increased, and the campaign was deemed to be a failure.(a)Explain why the rate of reported accidents may have been a poor measure of the campaign’s effectiveness.(2)(b)Describe four active measures which might have been used to measure the organisation’s health and safety performance.(8)

Answer 18

(a)
Following the campaign, the number of accidents may have significantly increased because of a number of factors; these could include that previously very few people were actually aware that they needed to report accidents, so accidents happened, but weren’t reported – resulting in under-reporting.It may also have been that the campaign was very successful because it now raised people’s awareness and expectations of what will be done now you have encouraged people to report accidents on site.

(b)
Four active methods of measuring H&S performance of the organisation could entail:
–Safety tours
– these tours could take place on a regular basis and identify good and poor practice; these practices could then be logged to measure performance by scoring or tracking good and poor practice.–Procedures, risk assessments, etc.
– measuring the numbers that have been done against numbers required, checking whether they are in date and being reviewed in line with set frequencies, communicated to staff
– by measuring awareness or understanding of them.
–Safety surveys
– using a set survey and evaluating strengths and weakness and setting strategy for the future and implementing campaigns and then being able to measure through a survey the effectiveness of this campaign.
–Benchmarking
– comparing your performance to previous years/months, other departments, sites or comparable companies (e.g. from national accident statistics published for your particular sector) to measure

Question 19

Outline the range of internal and external information sources that may be useful in the identification of hazards and the assessment of risk. For each source, indicate the type of information available and how it contributes to hazard identification or risk assessment.

Answer 19

External information sources that might prove useful during the risk assessment process would include:

National governmental enforcement agencies such as the UK’s HSE, USA’s OSHA, Western Australia’s Worksafe. These all produce legal and best practice guidance and statistics.

ƒInternational bodies such as the European Safety Agency; the International Labour Organisation; the World Health Organisation.

There are various professional bodies that have an interest in occupational safety and health and these bodies often issue guidance that can help in hazard identification and risk assessment. In many instances specific advice can be obtained relevant to a specific issue.

This guidance can often be augmented by further guidance available from trade bodies and trade unions

• these organisations can often give excellent practical guidance based on their close working knowledge of the practical issues arising. They are in a good position to indicate exactly what the principal hazards associated with their kind of work are, and the consequent risks.

ƒFinally, information can be obtained from manufacturers or suppliers which can indicate the extent of a hazard and the relevant control options that might be necessary. For example, safety data sheets from chemical suppliers provide essential information on the chemical nature of a hazardous substance and necessary controls. Similarly, the noise and vibration magnitude data from a machinery supplier can give an insight into the potential noise or vibration exposure and the subsequent exposure controls necessary.

Internal information sources might include:

ƒAccident and near-miss reports and investigation reports. These are useful because they will clearly identify hazards that either have or had the potential to cause injury. They may also be useful during the risk assessment process because they help in the evaluation of likelihood and severity of injury, and hence the degree of risk.

ƒInspection reports may be useful in identifying the easily observed hazardous conditions in the workplace and also the common types of control failure. This process not only helps the hazard identification process, but also influences risk assessment; the effectiveness of various control options can be better estimated based on current controls.

ƒAudit reports may also be useful in a similar way by identifying hazards that have been overlooked and the effectiveness of existing controls.

ƒMaintenance logs may be useful in determining the effectiveness or otherwise of particular controls in the workplace, such as automatic warning systems, guards and PPE.

Question 20

A complex manufacturing site situated close to a housing estate includes a storage vessel containing liquefied petroleum gas (LPG). It has been calculated that a major release of the LPG in the vessel could occur once every one hundred years (frequency = 0.01/year). This LPG release, in combination with the presence of an ignition source (probability, p = 0.1), would lead to a vapour cloud explosion on the industrial site. However, if the wind is blowing from the prevailing direction (p= 0.6) and the wind is slow and stable (p = 0.5), the LPG vapour cloud would drift over the housing estate where it might be ignited (p = 0.9).

(a) Using the information contained in the description above, demonstratean event tree and calculate the level of risk of explosion BOTH on the manufacturing site AND in the local housing estate. (10)
(b) Comment on the significance of these results.(4)
(c) Outline a hierarchy of control options that could be used to eliminate or minimise the risks and give examples to illustrate your ideas.

Answer 20

(a)
The event tree should look something like this:
(Remember that the probabilities on each yes/no branch point must add up to 1, so having been given the probability of there being an ignition source on site as 0.1, the probability of there NOT being an on-site ignition source (and therefore no on-site explosion) must be 1 - 0.1 = 0.9. This is a vital step to remember when calculating the probability of an off-site explosion because the question itself does not give you this vital number - you have to work it out for yourself.)An explosion will only occur on site if the release encounters the on-site ignition source. The frequency of such an occurrence on-site is 0.01 x 0.1 = 0.001/yr, which is once every 1,000 years (i.e. 1/0.001).An off-site ignition will only occur if: the vapour isn’t ignited on site AND the wind is in a certain direction AND the wind speed is < 8 m/s AND the vapour finds an ignition source in the housing estate. Thus, the expected frequency of off-site explosion is 0.01/yr x 0.9 x 0.6 x 0.5 x 0.9 = 0.00243 per year. This result can be alternatively expressed as approximately once in about 411 years (obtained by taking the reciprocal of the previous figure, i.e. 1/0.00243)

(b)
The results show that the risk to members of the public is greater than the risk to employees on site. Figures allow comparison with benchmark data, e.g. the UK HSE proposes an individual risk of death from workplace activities as one in a million per annum. Here the greater risk to members of the public is clearly unacceptable and given the fact that an explosion would be likely to cause multiple fatalities, both of these expected frequencies would appear unacceptable.

(c)
A standard hierarchical approach - elimination, substitution or minimisation of quantity/use of LPG, reduce probability of release (protective systems, maintenance, operation, ignition sources, emergency procedures, siting of tanks) - will contribute to minimising the risk in this situation

Question 21

An employer wishes to build a new gas compression installation to provide energy for its manufacturing processes. An explosion in the installation could affect the public and a nearby railway line. In view of this, the employer has been told that a qualitative risk assessment for the new installation may not be adequate and that some aspects of the risk require a quantitative risk assessment.

(a) Explain the terms ‘qualitative risk assessment’ AND ‘quantitative risk assessment’.(5)
(b) Identify the external sources of information and advice that the employer could refer to when deciding whether the risk from the new installation is acceptable.(5)
(c) A preliminary part of the risk assessment process is to be a hazard and operability study. Describe the principles and methodology of a hazard and operability (HAZOP) study.(10)

Answer 21

(a) The terms qualitative and quantitative refer to the way the risk assessments are conducted.

Qualitative – as the word suggests this is a subjective approach to deciding on the level of risk; it looks at likelihood of incidents occurring and the severity of injury or damage to people or the environment from those incidents. It will be ranked and a typical approach is to rank them HIGH, MEDIUM or LOW risk

Quantitative – this is a numbers-based approach using data/frequencies of events happening and their consequence and is used more formally for higher risk applications, as it is an objective approach to assessing the risk

(b)
- An employer could consult, externally, consultants who are experts in the installation/topic

• Industry guidance,
• Manufacturers of the equipment to find out failure rates and types of incidents;
• Insurance providers will also be able to put employers into contact with advice and guidance and support the employer with information
• The HSE, the OSHA, the European Safety Agency, the ILO and the World Health Organisation are all good sources of information and their websites may have good guidance on reducing risks.

(c)
A hazard and operability study (HAZOP) is a formal type of risk assessment which follows a set format, with a study leader gathering a team of people, who would consist of supervisors, operators, maintenance staff, designers, H&S professionals, etc. The team will follow a checklist which looks at the plant operating parameters, such as flow, temperature and pressure, together with agreed guide words, e.g. no, more, less, part of and reverse. Each parameter is combined with each guide word to identify possible deviations from the designed operating conditions. The possible causes of the deviations are then discussed, together with possible controls to prevent such deviations.

The process should take place at the design stage of new facility/plant or before modifications to existing take place.

This study should have an action plan which should be managed to ensure the plant is designed safely; anything that needs operational controls should be identified and this information acted upon by the operational department. The study should be kept as part of the H&S file for the installation.

Question 22

Business risk management involves the following approaches:
(a)Risk avoidance. (2)
(b)Risk reduction. (3)
(c)Risk transfer. (3)(
d)Risk retention. (2)
Distinguish between each of these approaches and give a specific example of each

Answer 22

(a)
Risk avoidance: actively avoiding or eliminating the risk. This might be done by, for example, discontinuing or avoiding a risky process or activity or by eliminating a hazardous material. Closing down a butchery operation within a food factory (with the hazards associated with that operation) and buying in ready-prepared meat from a supplier is an example of risk avoidance.

(b)
Risk reduction: reducing the level of residual risk. This might be done, for example, by adopting a hierarchy of measures to control the risk, such as removing one hazardous agent and introducing another less hazardous agent in its place, or adopting an engineering control by guarding a piece of machinery, or adopting a safe person strategy by training workers so that they are aware of a hazard and can behave accordingly.

(c)
Risk transfer: transfer of risk to a third party. This is often done by insurance. If the risk is realised and a loss occurs then the insurance policy will pay for the loss, so the financial risk has been transferred from the workplace on to the insurer (at a cost). Alternatively risk might be transferred to a contractor. Here, a separate organisation is retained to undertake an activity that the workplace does not want to carry out directly. However, because of the complexity of health and safety (and contract) law, it must be remembered that liability for losses may be laid at the door of the workplace and not just the contractor

(d)
Risk-retention: accepting a residual level of risk within the company. This is often done with the knowledge of the workplace (i.e. knowingly) where the risk is small and the costs of reducing the risk seem disproportionate to any benefit. If a loss occurs, then the organisation will have to cover that loss from revenues. Sometimes a risk may be retained without knowledge (i.e. unwittingly). This can occur when a risk has not been recognised (and therefore goes uninsured) or when a risk is recognised and insurance is put in place, but the insurance fails to cover the loss. This might occur if the loss is greater than the amount of insurance cover purchased, if there is a large excess, or if there are policy exclusions that mean the insurer avoids payment.

Question 23

Production line workers in a textile plant are required to use knives routinely as part of their work.

Outline the factors to be considered when developing a system of work designed to minimize the risk to these workers. (10)

Answer 23

The first factor to consider is the identification of the tasks requiring the use of knives (by task analysis, for example). This might then be followed by risk assessment. The people at risk, the hazards and various risk factors must be identified and recorded in this risk assessment. The correct methods needed to control the risk must be designed and implemented. During the risk assessment process the potential for risk elimination by automation or process change should be considered (though it must be expected that use of knives will remain). Consideration must be given to the type of knife (safety features), safe storage of knives, safe carrying of knives and knife sharpening arrangements. The environment must be considered (factors such as space constraints and lighting), as must individual factors relevant to workers using knives (age, attitude, skill). Suitable PPE must be selected and supplied. Worker training in much of the above will be necessary

Question 24

An investigation of a serious accident has concluded that maintenance operations in a particular area of a factory should have been subject to a permit-to-work system. Identify and explain the main factors that should be considered when setting up such a system.

Answer 24

Maintenance operations in a factory environment may involve various high-risk types of work, such as work on large complex items of machinery, work on pressure systems, work on high-voltage electrical systems, work in confined spaces, work on plant containing hazardous chemicals, work at height and work on plant at extremes of temperature, to name but a few. Often multiple hazards will exist at the same time and generate high and complex risk. Consequently maintenance work may often be designated as high risk and made subject to permit-to-work (PTW) control. In these cases, a PTW system must be carefully designed and implemented to ensure safety at all stages of the maintenance work.

Various factors must be considered when such a system is being designed, developed and implemented:

ƒIn the first instance the system parameters must be clearly identified so that there is a clear understanding of what the permit system covers. The system must define which work is covered by the permit system and which work falls outside of permit control. This may sometimes be subject to legal requirements. For example, confined space entry should always be made subject to permit control as a matter of course. In other instances the use of a permit system will be dependent on perceived risk on site (e.g. hot work). The definition of permit parameters must also identify the key site personnel and what their specific responsibilities and authorities actually are with regards the permit system. Personnel with responsibility for authorising work under the permit system must be clearly identified, as must personnel who have responsibility delegated to them in the absence of key personnel. Personnel responsible for undertaking specific activities, such as risk assessment or atmospheric monitoring, should have their responsibilities clearly allocated, as should staff responsible for monitoring the effective operation of the permit system.ƒ

Another factor to consider is the effective selection, training and competence of personnel. Competence is a key word here. All personnel associated with the PTW system must have the necessary competence to undertake their specific roles or task. This implies training, knowledge, experience and perhaps other qualities, such as ability. Assessment of competence may be necessary. Training records, and in some instances specific certification for key personnel, may have to be obtained and records retained.

ƒWhat the permit itself prescribes must be considered in the development of the permit system. This will vary depending on the nature of the types of work that fall within permit control. Generally, there would be arrangements designed into the system for the formal specification of key safety requirements before the commencement of work. These safety requirements would be communicated to relevant personnel through use of the permit system and the actioning of key controls would be verified. There would be some form of formal hand-over of control from authorising manager to personnel undertaking the maintenance work activities, as well as some specific restrictions placed on those workers as to types of work permitted and types of work not permitted. The verification of safety throughout the operation and the formal hand-back of plant/equipment or areas would then follow. Formal acceptance of these areas would follow, with the cancellation of the permit to prevent future work being carried out under old permissions.ƒ

The PTW system must clearly identify how the work should be co-ordinated and monitored. Personnel with key responsibilities must be identified here, as well as the co-ordination and monitoring arrangements being described in the system

Question 25

(a)Explain briefly what is meant by the ‘health and safety culture’ of an organisation. (b)Outline, using practical examples, the barriers to the development of a positive health and safety culture within an organisation.

Answer 25

(a) The health and safety culture of an organisation is the system of shared values and beliefs about the importance of health and safety in that workplace. The culture is how workers at all levels within the organisation think and feel about health and safety, and about how this translates into their behaviour. The culture may be positive or negative and will pervade the whole organisation from top to bottom.
(b) There are many possible barriers to the development of a positive health and safety culture within an organisation. These are not dissimilar to the factors that promote a negative health and safety culture and include the following:ƒ

Company reorganisations - change is unsettling for all people in an organisation and during times of change people may lose their belief in the company and its aims and means. For example, a company downsizing and making workers redundant will struggle to secure worker commitment to a health and safety policy that states that “people are our most valuable asset”.

ƒLack of confidence in management - if workers do not trust management to make sound decisions about the direction of the organisation and the methods used, then they will not engage in initiatives started by management.

Lack of leadership - people in organisations need to see that people in management positions are showing clear leadership with regards to health and safety. If no managers are clearly showing leadership and indicating the way forward, then workers will not be able to make their own way. Clear leadership, demonstrated by clear decision making as to the way forward, coupled with action will show others where to head.ƒ

Lack of resources - health and safety cost money. If safety is not adequately resourced in terms of money and personnel then positive improvements will be hard to achieve. An example would be a health and safety budget being cut to achieve a short-term financial target, resulting in the loss of a part-time safety officer.ƒ

Lack of management commitment - in the absence of senior management commitment, resources and attention will not be paid to health and safety. Priorities will lie elsewhere and others within the organisation will respond accordingly. It is only with clear commitment from senior management that organisations can hope to make positive improvements to their safety culture. For example, if senior managers are heard to belittle and denigrate health and safety in meetings, this will send a negative message to middle and junior staff.

ƒPoor communications - in the absence of clearly communicated policies and decision making, people will not be subject to the positive influence of their organisation. They will be left to make their own minds up about how important health and safety is. If communications are clear, then they will know what the organisation is thinking and what the organisation is doing to improve health and safety. Examples would be notice boards, team briefings and management meeting minutes which do not feature any health and safety element.

Question 26

(a)Explain the reasons why an organisation should establish mechanisms for effective consultation with employees on health and safety matters. (b)Outline a range of both formal and informal consultation mechanisms that could contribute to effective worker consultation. (6)

Answer 26

(a)
Reasons:Effective consultation arrangements with employees can result in a number of benefits relating to health and safety matters in the workplace. These include the development of ownership of safety measures by employees and an improved perception of the value and importance of health and safety. There is also the opportunity for the input of employee knowledge to ensure more workable improvements and solutions to health and safety problems. Finally, effective consultation encourages the submission of improvement ideas by employees.

(b)
A key formal consultation arrangement is the establishing of a health and safety committee. Another essential arrangement is consultation with safety representatives. These may be trade-union-appointed representatives or elected representatives. Planned direct consultation can take place at departmental meetings or team briefings. Less formal consultation can also take place during risk assessments or accident investigations.Other informal consultation arrangements include day-to-day meetings with leaders and employees, tool box talks, safety circles or improvement groups, staff appraisals and questionnaires or suggestion schemes.

Question 27

The senior management of an organisation wishes to introduce a number of new, safer working procedures but has met with resistance from the workforce. Outline the steps that managers could take to gain the support and commitment of staff when introducing the changes. (10)

Answer 27

The first step to gain support and commitment from the staff should be to find out what the reasons for resistance are. Might there be fear of redundancy, de-skilling or simply a general dislike of any type of change? The most important requirement is to effectively consult with the workforce. This could be through formal means; such as the safety committee, or more informally; through day-to-day meetings with leaders and employees, tool box talks, safety circles or improvement groups. A steady, step-by-step approach with trials and pilots of the proposed changes will ease the introduction, as will clear explanations of any proposed changes and the reasons for those changes. It will be important to actively involve the workforce in the proposals, take on board suggestions and offer training in the new methods. It will also be valuable to demonstrate the benefits of change, such as improved accident rates and production rates. A final part of the process should be continuing demonstration of senior management commitment and regular review of the changes to learn from any mistakes.

Question 28

A manufacturing company is about to embark on a process of organisational change that is intended to reduce costs and increase productivity. As planned, the change will lead to a smaller workforce, a flatter management structure, enlarged responsibilities for the remaining staff, outsourcing of most maintenance tasks, increased use of automated processes and the need for some employees to be multi-skilled.

Review the elements of a strategy designed to ensure that the company maintains its current high standards of health and safety, and its positive health and safety culture, both during and after the change.

Answer 28

The strategy should commence with the organisation making a definite statement of safety objectives as part of the change process so that the policy regarding health and safety during the change is well understood. It should be clear that plans will be amended if it is identified that the change process is adversely affecting health and safety.

There should be senior managers identified with clear responsibilities for managing safety during the change and performance measures identified and set, against which the impact of the change can be measured. To maintain the health and safety culture there should be regular consultation at all levels in the organisation and employees and their representatives should be involved in working groups dealing with the change. In this way the organisation can utilise employee experience and also encourage ownership of the change process.

In addition, there should be regular communication of plans and progress. The planned change will render current risk assessments invalid and therefore a programme of risk assessment revision will need to be undertaken with full involvement of employees. The new roles will require mapping of job skills and experience and also an assessment of training needs

Because the proposed change will result in a much smaller workforce, this will lead to loss of informal knowledge and process experience which will need to be identified and preserved before employees are made redundant

The move to outsourcing will lead to increased use of third parties and contractors, and therefore these new risks will need to be managed, and also consideration given to contractor competence

The proposed changes will be stressful for the workforce and therefore steps need to be taken to mitigate employee anxiety by regular and honest communication, help with job replacement and an open approach to redundancy. It will also be important not to rush through the changes and to allow adequate time and resources for training and implementation of the new structure

Finally safety performance should be monitored during and after the change and there should also be regular review of the process and its safety implications

Question 29

The refurbishment of an organisation’s offices will involve the services of several different trades from a number of small local companies and is to be completed while the building is occupied. An interior designer specialising in commercial properties will manage the project.(a)Outline the criteria that should be used when selecting contractors to undertake their part of the project. (6)(b)Outline the organisational measures that the project manager may need to consider in order to ensure the health and safety of office personnel during the work.You are not required to consider the specific risks associated with the work.

Answer 29

The criteria to be considered when selecting a competent building contractor are fairly straightforward and would include:
ƒPrevious experience with this type of work.
ƒReputation with previous/current clients (obtained by taking up references).

ƒContent and quality of health and safety policy document and risk assessments.

ƒLevel of training and competence of staff.

ƒAccident and enforcement history (accident statistics going back over 3-5 years; enforcement notices and prosecutions).

ƒMembership of relevant professional bodies.

ƒEquipment and statutory examination records.

ƒExamples of risk assessment and method statements for work carried out.

(b)The organisational measures that may need to be considered to ensure safety of office staff during the work:

ƒClear agreement on work schedules and timescales that are then clearly communicated to all contractors and the office staff.

ƒInduction issues for contractors - so that they understand the implications of their work for office staff.ƒSecurity procedures such as signing in/out.

ƒAccident reporting procedures - so that in the event of an incident involving office staff, the project manager is informed immediately.

ƒClear communication and co-ordination on the means of escape that have to be maintained to ensure office worker safety as the project progresses.

ƒProcedures to be followed in the event of an emergency.

ƒInformation on hazards in the building (e.g. utilities and asbestos location/presence) that not only present a hazard to contractors, but also present a hazard (if disturbed) to office workers.

ƒArrangements for delivery and storage of materials - so as not to interfere with office worker access and egress or emergency escape routes.ƒRemoval of waste that may pose a hazard to office workers.

ƒInformation on parts of the building where access might be temporarily restricted.

Question 30

(a) Describe the indicators and measures that could be used to assess the health and safety culture of an organisation.
(b) Describe the organisational factors that may influence the success of an attempt to improve an organisation’s health and safety culture.

Answer 30

(a)The indicators and measures that could be used to assess the health and safety culture of an organisation would include:
ƒAttitudes towards health and safety by workers/managers and the acceptance of health and safety responsibilities. This might be assessed by questionnaire or interview.
ƒThe extent of communication on health and safety within the organisation. This might be assessed by viewing all of the various forms of communication that are apparent.
ƒThe integration of health and safety into other management functions (e.g. purchasing). This might be assessed by reference to policy and procedure documentation and by interview.
ƒThe influence of health and safety on management decision-making. This might be assessed by reviewing management meeting minutes and by interview.ƒThe effectiveness and composition of the safety committee. This could be assessed by viewing meeting minutes and by interview.
ƒThe status of the Safety Adviser. This could be assessed by examining the position of the safety adviser within the organisation and by reference to salary.ƒThe relationship with the enforcement agencies.ƒThe quality of the health and safety policy and its effectiveness. This might be assessed by reading policy documentation and by audit.

Reference to health and safety in the organisation’s annual report.ƒOther measures might include the standard reactive monitoring data, such as lost time accidents, etc. though these are fairly limited in the context of assessing safety culture.

(b)
The factors that may influence the success of an attempt to improve an organisation’s health and safety culture would include:ƒThe industrial relations (IR) climate within the organisation. If this is good, then achieving consensus and buy-in will be fairly easy. If IR is poor, then certain groups of workers may not engage with attempts to improve the culture and may even deliberately sabotage such attempts.ƒThe confidence of the workforce in their management’s ability to control risks. If management have the trust of the workforce in this respect then workers are more likely to listen to and respond to improvement programmes.ƒManagement commitment to health and safety. If commitment is seen to be demonstrated, then those workers who support any improvement programmes have ammunition to win the argument. If management commitment does not exist, or is not seen to exist, then those arguments will be lost.ƒThe resources and expertise devoted to health and safety. Lack of resource handicaps any improvement programme. Good resourcing and the presence of the right people in the right positions will allow the best chance of success.

Question 31

Outline how safety tours could contribute to improving health and safety performance and to improving health and safety culture within a company. Discussion of the specific health and safety requirements, problems or standards that such tours may address, is not required.(10)

Answer 31

Safety tours can contribute to improving health and safety performance and the culture, as they should be used to identify good and poor health and safety behaviours on the shop floor of the organisation. This information can be used in a simple manner to trend on performance against set behaviours via a performance feedback sheet, such as PPE being worn v. not worn – has it improved since last time or got worse?

The tours can be used to target new understanding or compliance with new initiatives and programmes the company introduces and is an effective way of engaging the workforce across an organisation to support these. The actions raised should be solved locally, visually and quickly, which demonstrates leadership and commitment of the company and enables best practice sharing. If the safety tours are carried out by managers, they can be an effective demonstration of management commitment to safety; however, this does require action to be taken as a result of the tour.

Question 32

A useful definition of the word ‘perception’ is “the process by which people interpret the information that they take in through their various senses”.Outline a range of factors that could affect the way that people perceive hazards in workplaces. (10)

Answer 32

The range of factors that might affect how people perceive hazards in the workplace are mostly factors associated with the person themselves. These personal factors would include issues such as:

• The effects of fatigue. A tired person is less likely to take note of sensory information that an alert person would detect early.
• Drugs and alcohol. These have an obvious effect on mental processes and, in some instances, will be psycho-active and therefore directly interfere with the processing of sensory information.
• Education and training. A trained person will know the meaning of various sensory inputs, will recognize their importance, and act accordingly. An untrained, poorly educated person may not make the same associations between sensory input and hazards.
• Experience. Inexperienced workers often fail to recognize hazards for what they are and underestimate the risk associated with hazards precisely because they lack experience. More experienced workers do not fall into the same trap.
• Aptitude. Some individuals will have an innate ability to respond to sensory stimuli in an appropriate manner.
• IQ. A worker with low IQ may struggle to correctly perceive the level of risk associated with a particular hazard, particularly if the hazard is not visible in nature. A person with high IQ may be better able to interpret sensory information and translate that into hazard awareness.
• Environmental factors may interfere with a worker’s ability to perceive hazards in the workplace.
• Factors such as low light levels, dust, noise and extremes of temperature can have an effect on hazard perception. This is not only due to direct interference with the senses themselves, but also to the psychological influence of environmental extremes.
• Any form of sensory impairment will have an obvious impact on perception of hazards. A partially sighted worker may not be able to see hazards to avoid them; a colour-blind worker may mistake red and green indicator lights

Question 33

Outline the organisational and behavioural factors that may lead new employees to disregard instructions given during health and safety induction training. (10)

Answer 33

Organisational factors that might lead new employees to disregard instructions given during induction training might include:

-The employee selection process, whereby poor recruitment and selection processes allow employees with poor attitude, intelligence and behaviour patterns into the workplace.
-A poor induction process that fails to engage the employees, especially if the training provided is not applicable to actual practice in the workplace.
-The absence of refresher training.
-A lack of awareness on the part of experienced workers for the safety of new starters.
-Peer group pressure coming to play on new starters forcing them to disregard instructions so as to fit in with their newly acquired peer group.
-Poor levels of supervision such that inappropriate behaviour is not detected or challenged early.
-Poor safety culture (including lack of management commitment) within the organisation, which will be perceived by new starters early on.
The behavioural factors that might lead to employees disregarding instructions given during induction training might include:
-A lack of familiarity with the working environment.
-Poor risk perception as a result of young age and/ or a lack of workplace experien Issues associated with the cultural background of the individual and consequently the beliefs and values that they bring into the workplace.
-Language issues that might arise as a result of the nationality or cultural background of the worker, their reading ability and any learning difficulties they may suffer from.
-Sensory impairments such as deafness, impaired hearing, impaired sight.
-Low IQ or poor mental capabilities leading to difficulties in understanding instructions or the true nature of hazards and risks

Question 34

3.Outline measures to improve human reliability in the workplace. (10)

Answer 34

There are many ways of improving human reliability in the context of safety

• related behaviour. If these measures are taken, then there is less likelihood that workers will break safety rules or will be subject to human error.Employee selection
• recruiting the right worker for the job is an important measure. For example, a worker with a high IQ working on a monotonous job is more likely to bend and break the rules to relieve the monotony.Training (induction, job-specific and refresher)
• in the absence of proper, effective training, workers will not know how to behave correctly and consequently will have to do what they see as best.Supervision
• it is vital that workers are supervised to an adequate level in the workplace so that non-compliance and errors are detected and corrected early.

This prevents bad habits from forming and sends a clear message to the worker: rule breaking will not be tolerated.

Demonstrable management commitment - without strong leadership workers will not feel motivated to behave correctl

Incentive schemes - if workers see some form of reward for good behaviour then they are more likely to comply with rules, etc. and they are also more likely to exercise care when performing their duties because they have a personal reason for caring about outcomes. Incentives can be financial in nature, but may have no financial value at all (e.g. employee of the month schemes).

Workplace/equipment ergonomic assessments of the workplace - it is important that the environment and the equipment and workstation of employees are designed and laid out to be as comfortable as possible and to minimise the chances of error.Job rotation is a good way of relieving monotony and boredom and maintaining some form of interest.

Allowing for appropriate rest breaks - workers do not become so excessively fatigued that decision making becomes poor (also to maximise attention span).

Good workforce communication and consultation - so that workers feel engaged in the decision-making process in the workplace and therefore feel a greater level of commitment to work.

Question 35

4.Describe what is meant by ‘skill-based’, ‘rule-based’ and ‘knowledge-based’ behaviour and explain how each of these operating levels can give rise to human error and how, in each case, such error may be prevented. Illustrate your answer with reference to practical examples and actual incidents. (20)

Answer 35

These three levels of behaviour (skill-, rule- and knowledge-based) are based on the work of Rasmussen and they underlie the basic types of human error described in the HSE guidance note HSG48: Reducing Error and Influencing Behaviour

Skill-based behaviour occurs when a person is carrying out tasks that are routine and familiar. They may be physical tasks such as pushing a button on a control panel or mental tasks such as adding a column of figures in the head. The person is not using any higher-level reasoning skills in performing the tasks - they are acting automatically. In this mode of operation, two types of human error can occur: slips and lapses. A slipoccurs when the person performs an action incorrectly. For example, an experienced crane operator attempts to lower a load slowly, but applies too much pressure to the control lever resulting in a sudden violent lowering of the load. A lapse occurs when a person omits a step in a process. For example, an experienced machine operator forgets to remove the chuck key from a grinder, resulting in the key being ejected on start-up.These types of human error, which occur when a person is behaving in skill-based mode, can be avoided by ensuring that people are not fatigued; this might require attention to shift patterns and hours of work, as well as ensuring that adequate breaks are taken. Ensuring that individuals undertake a variety of tasks may help, by avoiding complacency and reducing repetitiveness and boredom. Minimising distractions in the workplace can reduce the likelihood of lapses. The Paddington rail crash, involving a signal passed at danger, was probably caused (in part) by a skill-based error on the part of the driver who omitted to correctly recognise the danger signal. Slips and lapses can also be minimised by introducing double-checking systems into the work routine so that others check that certain actions have been carried out correctly. Supervision to detect errors is also useful.

Rule-based behaviour is more complex than skill-based behaviour. Here a person is starting to use reasoning skills with some higher-level decision making. However, because the person is familiar with the situation (or thinks they are) they have a set of options that they can choose from in order to help them decide on appropriate action to take. In short, a logical approach is made to a situation along the lines of “if A, then B”, where B is the rule to apply if situation A occurs. In this mode of operation, one type of human error can occur: rule-based mistakes.A rule-based mistake occurs when a person incorrectly applies a rule to a situation. For example, a security guard attempts to evacuate a building during a bomb-threat; they know the rule for fire is “get out and stay out” and they incorrectly apply this rule to the bomb threat situation. The correct procedure would be to stay in the building. The security guard has applied a general rule incorrectly to a situation This type of human error can be prevented by providing clear guidelines to follow for all foreseeable eventualities, by training people in correct diagnosis of problems and the rules to apply, and by practice of the rules so that they become well known. Good supervision and process design can also minimise this type of error. The Kegworth air crash was caused, in part, by rule-based mistakes on the part of the pilot (shutting down an engine that he thought was on fire, when in fact the other engine was on fire). Rule-based mistakes can also be minimised by good background training (education) so that workers are more able to recognise the risks inherent with applying simplistic, rule-based solutions to problems, and by exposing workers to rare event situations so that they become aware of times when standard rules do not apply (e.g. conducting emergency drills).

Knowledge-based behaviour occurs when a person or group of people are trouble-shooting and problem-solving. It involves higher cognitive skills, reasoning and decision making. It occurs when an unusual situation arises and the people involved have to take action and make decisions based on their knowledge and understanding of the situation rather than relying on a ‘rule of thumb’.The type of human error that occurs during this mode of operation is the knowledge-based mistake. This occurs when a person makes a mistake because they do not fully understand the situation or the system they are working on, or they lack background knowledge. For example, an electrician electrocutes themselves while fault finding on a complex electrical system because they lack the competence to correctly diagnose the problem safely. This type of human error can be minimised by ensuring that people have the right level of competence for their roles, i.e. training, background knowledge and understanding. It can also be minimised by allowing people time to think a problem through and correctly diagnose problems and solutions. If time constraints are imposed, then knowledge-based mistakes are far more likely to occur. The Chernobyl nuclear disaster was largely caused due to knowledge-based mistakes - operators made incorrect decisions during a simulation exercise because they did not have the background knowledge to correctly interpret the information being fed back to them by the reactor. Competent operators would have made different decisions. Knowledge-based mistakes can also be minimised by ensuring that workers are overseen by competent persons and that they have access to sources of advice, either within or external to the organisation

Question 36

In relation to human error:

(a) Distinguish between routine, situational and exceptional violations.
(b) Outline, with appropriate reference to actual major incidents, the factors that might promote routine violations at work.

Answer 36

(a)
A routine violation is a violation (an example of rule-breaking behaviour) that has become the normal way of working within the work group (e.g. speeding when driving in a car); it has become custom and practice to break the rule in this way.Situational violations occur because the pressures of the job encourage the rule to be broken; the procedures can’t be adhered to if the job is to be done, e.g. no PPE available, so pressure to continue without it. Situational violations are not the norm within the workplace and you would often expect workers to do the job the right way, but then they will break the rule because of some form of pressure (or perceived pressure) - if a deadline is approaching the rule breaking starts (in order to meet the deadline). Once the deadline is passed, the pressure is relieved and the proper application of the rule returns.An exceptional violation occurs when things have gone wrong (typically emergencies) and a rule is broken in an attempt to rectify the situation. As the name suggests, exceptional violations only occur in exceptional circumstances.These definitions do not have clearly defined edges and it is possible that one type can merge into another type over time. For example, a situational violation occurs, workers get away with the rule breaking (nothing bad happens) and so they are encouraged to break the rule again. Over time, standards slip and the situational violation becomes the normal way of working - it has become a routine violation

(b)
Routine violations often occur due to cutting corners to save time/energy, which is encouraged by: awkward, uncomfortable or painful working posture; excessively awkward, tiring or slow controls or equipment; difficulty in getting in or out of maintenance or operating position (posture); equipment or software which seems unduly slow to respond; high noise levels which prevent clear communication; frequent false alarms from instrumentation; instrumentation perceived to be unreliable; procedures which are hard to read or out of date; difficult to use or uncomfortable personal protective equipment; unpleasant working environments (dust, fumes, extreme heat/cold, etc.); inappropriate reward/incentive schemes; work overload/lack of resources.In addition, there are the following factors: perception that rules are too restrictive/impractical/unnecessary (particularly true where there has been lack of consultation in the drawing-up of rules); belief that the rules no longer apply; lack of enforcement of the rules (e.g. through lack of supervision/monitoring/management commitment - even sanctioned by management “turning a blind eye” in order to get the job done); or new workers starting a job where routine violations are the norm and not realising this is not the correct way of working (may be due to culture/peer pressure or lack of training). Examples could include Herald of Free Enterprise capsize (bow doors left open), Piper Alpha (permit procedures

Question 37

Outline the design features of both controls and displays on the control panel of complex process machinery that could reduce the likelihood of operator error.

Answer 37

It is important, during the design of control panels for industrial equipment, to consider the possibility of human error. Equipment operators may be subject to human error, they may commit skill-based errors (slips and lapses) and they may make mistakes (both rule-based and knowledge-based).

These errors might result in highly undesirable consequences and therefore must be prevented. This can be done by careful design of controls (those parts of the control panel that an operator has to interact with to make changes to the operation of the equipment) and displays (those parts of the panel that deliver information to the operator about the status of the equipment).

Desirable features of controls might include:

ƒMinimise the number needed so as to avoid operator confusion.

ƒPlace controls in positions where they are easily operated.

ƒEnsure that controls are ordered logically (e.g. in such a way that the operation of the controls follows the logical order of the process being controlled).

ƒDesign controls so that they require positive action in order to be operated and cannot be operated accidentally or knocked. For example, a hand brake of a car cannot be released simply by pushing down on the lever.

ƒEnsure that feedback is available to the operator to indicate successful operation of the control.

ƒObey any stereotyping/conventions that might already exist for that type of control. For example, switches up for off, down for on; knobs turn clockwise for increase, etc.

ƒIt may be possible and desirable to position controls next to corresponding displays. For example, if a knob alters temperature it might be desirable to site the knob next to the temperature readout.

ƒEmergency controls should be prominent and distinctive so that they are easy to see and activate. They might be positioned near to the operator’s position so that they are within easy reach in the event of emergency.

ƒControls that have to be operated frequently might be positioned close to the operator for ease of access, while those that are used infrequently might be positioned further away.

ƒControls might be laid out in an arc around the operator so that they can all be activated without the need to over-reach.

ƒControls that require force to operate should be power or servo assisted.

ƒControls must not be overly sensitive; minor changes to the control should not result in excessive changes to the parameter being controlled.

Desirable features of displays might include the following:

ƒDisplays must be visible to the operator from their normal operating position. They must also be large enough to be easily visible to the operator.

ƒThey must be appropriately labelled, so that the parameter they are displaying is clear to the operator; this might require the use of pictograms (which might also help overcome language barriers).

ƒThe positioning of safety-critical displays must be carefully selected so that they are in the operator’s normal line of sight and in a commanding position.

ƒAgain, any conventions/stereotyping that exist should be recognised and used. For example, colours on dials relating to danger and safe conditions would normally use green for safe, red for danger. Dials should all increase the same way, normally clockwise.

ƒCareful selection of analogue vs digital displays should be made. There are times when a digital readout is perfectly acceptable and desirable. There are other times when analogue is preferred since the position of the needle on an analogue dial can be determined by a quick glance that does not require the accurate reading of numbers.

ƒDisplays must be carefully placed and lit so as to avoid glare.

ƒDuplication of adjacent displays should be avoided in some instances where accidentally reading the wrong display might end in disaste