Safety, Health and Environmental Auditing

A Practical Guide, Second Edition

Simon Watson Pain

• Publisher: CRC Press
• Year: 2018
• ISBN:
  9781351366823
• Edition: 2
• Topic: Technology & Engineering
• Subtopic: Industrial Engineering
• Index: Technology & Engineering

This new edition builds on the success of the first edition. It has been enhanced to embrace new topics including Due Dilgence, EHS Auditing, Process Safety, Auditing, and a chapter summarizing auditing with the relevant ISO standards. The rest of the book has been updated to fit with the guidance and requirements set out with the changes in the ISO standards. The goal of this book remains the same, to provide a "down to earth" guidance for managers and specialists in organizations who are committed to improving their safety, health and environmental performance, but are not sure where to start or do not wish to employ consultants to do this for them. They do it themselves using this book.

Electronic software and additional materials available upon request.

Features

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• Integrates the concepts of safety health and environmental auditing into a common approach of "loss prevention"
• Provides an audit protocol for 60 aspects of safety, health, and environmental management
• Presents a summary of the requirements of ISO 9001 and ISO 14001 to auditing
• Introduces the novel and unique concept of Auditing Convergence
• Offers a simple auditing software (The Plaudit II audit process) in an electronic program which no other book on this topic can offer
  

1	Elements of a Good Safety, Health and Environmental System

A ‘system’ is ‘an environment exploiting, restricting and repressing individuals’. So claims the Collins Concise Dictionary. Surely this cannot be the intention of safety, occupational health and environmental systems? Perhaps a more appropriate definition would be ‘a way of doing things’. However, Collins is right in suggesting that systems may not necessarily be a help; they can on occasion be a hindrance. We have all experienced the uniformed official who insists on rigidly applying outdated rules with the claim that ‘it is more than his job’s worth not to comply!’ Nevertheless, systems are needed in organisations, whether they cover the control of finances, the payment of employees, the purchase of goods, the control of product quality or the application of safety, health and environmental (SHE) standards. Although we may sometimes doubt it, systems are created to simplify activities that are repeated and are essential to the purpose of the organisation. They are intended to ensure that we benefit from the learning and experience of others, so that we do not all have to go back and reinvent the activity from first principles. Even when formal systems do not exist, it is human nature for us to want to make things easy for ourselves, so we often tend to devise our own way of doing things.

The role of the system in collating experience and learning is an essential component when systems are intended to prevent harm occurring to people or the environment around us. This is why the application of systems to SHE protection is of such importance and explains the recent explosion in regulatory controls in this area from governments around the world. Indeed, governmental controls are now so complex that new systems have to be introduced to try and simplify the previous systems. It is hardly surprising that Collins defines these systems as restricting and repressing individuals.

The problem with any system is that it tends to start to deteriorate from the first day it is introduced. This can be through ignorance, oversight or wilful disregard. Ignorance is fundamentally a communication and training issue, and wilful disregard is arguably a disciplinary matter, but probably the biggest barrier to the successful application of systems in the SHE area is oversight. Oversight, or the inability to anticipate adverse consequences, is one of the most common causes of harm to people and their surroundings. So often it is done with the best of intentions. No one intentionally crashes his or her car into a brick wall. It may happen because of a desire to get home on time. That is a creditable enough intention, but all too often the best intention ends in tragedy because people don’t think about the consequences of driving around a corner too fast, ignoring the driving safety control systems of speed limits or failing to make allowances for tyre condition or adverse weather.

Systems exist in all walks of life, and there is ample evidence that they deteriorate with time unless they are properly managed and controlled. The people who are to operate the system need to know what is expected of them. The requirement should be written down in a clear and concise manner and then this should be effectively communicated to the individuals concerned through training. The system should appear to be sensible and logical to the people involved. If a system appears to be illogical, then there will be a natural tendency for people to devise an alternative approach that they consider to be more appropriate. Ideally, the system should be developed by one or more of the people who will have to operate it and certainly not by some remote bureaucrat who never leaves the sheltered cloisters of his or her own office. When people have been trained in the system, their knowledge of the requirement should then be checked to ensure a thorough understanding before they are asked to apply it. Records should be maintained to confirm that users have been trained in the system and to identify when refresher training will be required. Even then, with a sensible logical system and trained operatives, the survival of the system is not assured unless it is properly managed. Most systems fail quite quickly, usually within 6 to 9 months, unless people are reminded of the need (i.e. an accident happens and reinforces the need for a safety system) or management ensures compliance with the system through some process of checking or auditing.

Regrettably, the effort required by management to ensure compliance to SHE management systems is not always seen as a top priority when more pressing problems arise. Often it is only after some accident or injury occurs that the investigating team goes back to the safety instructions and finds to its relief that the injured party had transgressed some detailed sub-clause in the dusty document. Management feels vindicated and the poor wretch is given a summary dressing down to add to his or her physical ailments. Perhaps if a little more thought were given, the management team might recognise that it had also failed in its task of ensuring compliance with the safety procedure. Managers are well advised to remember that they have a ‘duty of care’ towards their employees and that the regulatory authorities are likely to want to know as part of their investigation exactly what steps management took to ensure compliance with both regulatory and its own internal safety procedures. The mere existence of a written procedure does not confirm that there was necessarily an effective system in place. In fact, the existence of an injury almost immediately suggests that management has failed in its duty of care. It is now well understood by experienced incident investigators that the immediate causes of an incident are rarely the real underlying cause of the event. Frequently, the immediate causes relate to the period in the few minutes prior to the incident. The underlying causes go back much farther in time and often have roots in management’s lack of control over a prolonged period and the failure to have robust SHE systems in place.

The consequences of failures in safety are often all too immediate because often someone gets hurt, but system failures in protecting employees’ health from exposure to asbestos dust may not be realised for 40 years, and failures in environmental controls to prevent land contamination may not result in observable consequences for even longer. Compliance with such environmental and occupational health protection systems is particularly difficult as responsible parties may consider that the risk of the consequences coming back to haunt them within their career span is so small as to be worth taking a chance.

Leaders in the field of industrial loss prevention all advocate for the same three elements of a safe and healthy working environment. These I shall refer to as the ‘three Ps’ and are ‘people’, ‘procedures’ and ‘plant’. Taking these in reverse order, let us consider ‘plant’ first. Plant or operating equipment needs to be of adequate standard in order to achieve a good safety and health record for the workforce and its neighbours. Work equipment should be properly designed to be safe to use and should have been subject to an appropriate form of risk assessment. Often, plant and equipment has the potential to deteriorate with age, and so the standards of maintenance and upkeep are critical. ‘Procedures’ should be established to ensure that potentially hazardous equipment remains safe to use and in a condition that will not cause harm to the environment. These critical elements of plant and equipment maintenance are known as SHE assurance and are an important part of corporate governance. However perfectly designed and maintained plant and equipment may be, it cannot alone ensure that no harm occurs. Equipment is used and operated by people, and people are notoriously unreliable. The use of equipment should be controlled by the second of the three Ps: namely, ‘procedures’. In the late 1980s, when the International Quality Standard series ISO 9000 was first being implemented on a large scale, many companies made the mistake of believing that everything could be controlled by procedures and instructions. Every eventuality was considered and the tropical rainforests disappeared overnight in a mountain of procedural bibles. The main problem was that the sheer volume of procedures was unmanageable, and they were rarely used and never revised. It is now recognised that you cannot ‘proceduralise’ every aspect of life and that the procedures should relate to the important and generic activities. The application of good and well-maintained procedures allows a step change improvement in SHE performance, compared with relying only on a well-designed and well-maintained plant.

To achieve world-class performance in SHE management, we require the involvement not just of engineers, designers and managers but also the proactive involvement of all employees. Employees must become responsible for not just their own safety but also that of their workmates; they should in effect become ‘their brother’s keeper’. Experience in hazard recognition training demonstrates to me that people will identify more hazards when pooling their ideas and working as a team than any one individual will do when working alone. Consequently, to have an effective loss prevention system requires attention to the plant, the procedures and the people.

The scope of a loss prevention audit may cover any combination of safety and occupational health and environmental protection. It is logical to attempt to combine these three issues as they all relate to harm to individuals, groups of individuals or the environment. They are all issues of ‘loss prevention’. Safety harm, in the form of injuries, usually arises as a result of acute effects and is often short term and reversible (except in the case of fatalities), whereas occupational illness usually relates to long-term exposure and results in chronic effects. However, the underlying causes for both sets of consequences can be the same. Audits often need to pay particular attention to health hazards or environmental effects because the consequences are not immediate and therefore may be less obvious to the worker. Unfortunately, because of the size of the task, the danger of attempting to cover all aspects of health, safety and environmental control within a single audit is that the audit either becomes unwieldy or at the other extreme may become superficial in its individual elements. This problem of superficiality is the greatest practical problem facing the health and safety auditor today. Superficiality not only discredits the outcome of an individual audit but may bestow a feeling of inappropriate ‘comfort’ when this may not be fully justified.

2	Management Systems

According to estimates by the International Labor Office (ILO), the number of job-related accidents and illnesses annually claims more than 2.3 million lives worldwide, and this number appears to be rising because of rapid industrialisation in some developing countries. The assessment also indicates that the risk of occupational illness has become by far the most prevalent danger faced by people at work—accounting for 2 million annual work-related deaths and outpacing fatal accidents by nearly six to one.

The ILO found that in addition to work-related deaths, each year there are some 268 million nonfatal workplace accidents in which the victims miss at least 3 days of work as well as 160 million new cases of work-related illness. To put this into perspective, this is like saying that every man, woman and child in the United States will have a work-related injury every year! Injuries, illnesses and environmental incidents are costly not only to the world’s economy, but also to workers, their families and our surroundings.

In many countries, company directors, managers and employees can now be held personally liable for failure to control health and safety. Increasingly, managers are held criminally liable when things go wrong, and so there is an increasing tendency for organisations to document their safety systems. Of course, a mere written procedure does nothing in itself to reduce the risk of harm to employees; it is merely a statement of intent. To translate such a statement into meaningful action requires some sort of management activity. To ensure that this action is properly sustained requires monitoring by the management team. The level of informality or formality of the system will depend on the nature of the enterprise and the risks associated with it. The essential starting point is to consider SHE management as a key business process. The board or senior management of the organisation should set down its basic requirements in the areas of SHE protection in the form of a policy statement, which should be made available to all employees. The policy should state the organisation’s position on SHE matters and how all the employees will be expected to comply with them. It should also state the arrangements and responsibilities within the organisation for implementation of that policy. The policy should influence all the organisation’s activities, including the selection of people, equipment and materials, the way work is done and how goods are designed and services are provided.

In summary, the policy should

•Be a clear written statement of the organisation’s position relating to loss control in safety, health and the environment

•Identify who is responsible for SHE performance

•Identify the sources of expert SHE knowledge

•Be signed by the most senior person(s) in the organisation

•Be prominently displayed in an up-to-date form

•Be communicated in clear and concise terms to everyone within the organisation

The existence of an up-to-date policy statement is a clear indication that the management team considers safety, health and environmental loss prevention to be a key issue for the organisation. However, as stated previously, the existence of such a statement does not avoid accidents happening. To make the policy effective, it is necessary to get the employees involved and committed. Creating positive loss prevention behaviour among the staff needs to be properly managed. First, people need to know how they are expected to behave in the organisation, what tasks they are required to do, and how, where and when they should do them. It is the responsibility of management to set the standards of behaviour that are required, with a view to controlling the risks to employees, customers, neighbours and the environment. Many industry standards already exist, and in some cases, it is appropriate to adopt these. In other cases, it will be necessary for the organisation to develop its own standards or requirements. Either way, the standards should identify the basic management requirements for loss prevention, but they must be documented, measurable, achievable and realistic if they are to be effectively adopted.

Organisations wishing to develop their own standards should consider these areas of their operations for application of those standards:

•Premises and workplace

•Assets design and procurement

•Substance control and material hazards

•Transport and distribution

•Storage and warehousing

•Task design and risk assessment (safe systems of work)

•Training requirements

•Continuous improvement plans

•Product safety

•Regulatory compliance...