Safety and Health Management System
Frequently Asked Questions
What is a Safety and Health Management System?
A safety and health management system means the part of the Organisation's management system which covers:
- the health and safety work organisation and policy in a company
- the planning process for accident and ill health prevention
- the line management responsibilities and
- the practices, procedures and resources for developing and implementing, reviewing and maintaining the occupational safety and health policy.
The system should cover the entire gambit of an employer's occupational health and safety organisation. The key elements of a successful safety and health management system are:
1. Policy and commitment
The workplace should prepare an occupational safety and health policy programme as part of the preparation of the Safety Statement required by Section 20 of the Safety, Health and Welfare at Work Act 2005. Effective safety and health policies should set a clear direction for the organisation to follow. They will contribute to all aspects of business performance as part of a demonstrable commitment to continuous improvement. Responsibilities to people and the working environment will be met in a way that fulfils the spirit and letter of the law. Cost-effective approaches to preserving and developing human and physical resources will reduce financial losses and liabilities. In a wider context, stakeholders' expectations, whether they are shareholders, employees or their representatives, customers or society at large, can be met.
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The workplace should formulate a plan to fulfil its safety and health policy as set out in the Safety Statement. An effective management structure and arrangements should be put in place for delivering the policy. Safety and health objectives and targets should be set for all managers and employees.
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3. Implementation and operation
For effective implementation, organisations should develop the capabilities and support mechanisms necessary to achieve the safety and health policy, objectives and targets. All staff should be motivated and empowered to work safely and to protect their long-term health, not simply to avoid accidents. These arrangements should be:
- underpinned by effective staff involvement and participation through appropriate consultation, the use of the safety committee where it exists and the safety representation system and,
- sustained by effective communication and the promotion of competence, which allows all employees and their representatives to make a responsible and informed contribution to the safety and health effort.
There should be a planned and systematic approach to implementing the safety and health policy through an effective safety and health management system. The aim is to minimise risks. Risk Assessment methods should be used to determine priorities and set objectives for eliminating hazards and reducing risks. Wherever possible, risks should be eliminated through the selection and design of facilities, equipment and processes. If risks cannot be eliminated, they should be minimised by the use of physical controls and safe systems of work or, as a last resort, through the provision of PPE. Performance standards should be established and used for measuring achievement. Specific actions to promote a positive safety and health culture should be identified. There should be a shared common understanding of the organisation‘s vision, values and beliefs on health and safety. The visible and active leadership of senior managers fosters a positive safety and health culture.
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4. Measuring performance
The organisation should measure, monitor and evaluate safety and health performance. Performance can be measured against agreed standards to reveal when and where improvement is needed. Active self-monitoring reveals how effectively the safety and health management system is functioning. Self-monitoring looks at both hardware (premises, plant and substances) and software (people, procedures and systems, including individual behaviour and performance). If controls fail, reactive monitoring should find out why they failed, by investigating the accidents, ill health or incidents, which could have caused harm or loss. The objectives of active and reactive monitoring are:
- to determine the immediate causes of substandard performance
- to identify any underlying causes and implications for the design and operation of the safety and health management system.
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5. Auditing and reviewing performance
The organisation should review and improve its safety and health management system continuously, so that its overall safety and health performance improves constantly. The organisation can learn from relevant experience and apply the lessons. There should be a systematic review of performance based on data from monitoring and from independent audits of the whole safety and health management system. These form the basis of complying with the organisation’s responsibilities under the 2005 Act and other statutory provisions. There should be a strong commitment to continuous improvement involving the development of policies, systems and techniques of risk control. Performance should be assessed by:
- internal reference to key performance indicators
- external comparison with the performance of business competitors and best practice in the organisation’s employment sector.
Many companies now report on how well they have performed on worker safety and health in their annual reports and how they have fulfilled their responsibilities with regard to preparing and implementing their Safety Statements. In addition, employers have greater responsibilities under Section 80 of the 2005 Act on ‘Liability of Directors and Officers of Undertakings’ that requires them to be in a position to prove they have pro-actively managed the safety and health of their workers. Data from this ‘Auditing and reviewing performance’ process should be used for these purposes.
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What issues should a review of the safety and health management system cover?
An organisation should carry out an initial review of the safety and health management system, and follow this up with periodic reviews. The initial review should compare existing safety and health practice with:
- the requirements of safety and health legislation
- the provisions set out in the organisation’s Safety Statement
- safety and health guidance in the organisation
- existing authoritative and published safety and health guidance
- best practice in the organisation’s employment sector
The following checklist may be used for the review
- Is the Safety Statement clear and concise so that it can be read and understood by those who may be at risk?
- Is the Safety Statement available at the workplace to which it relates and are workers given relevant extracts where they are at specific risk?
- Is the overall safety and health policy of the organisation and the internal structure for implementing it adequate, e.g. are responsibilities of named persons clearly outlined?
- Does the Safety Statement contain a systematic identification of hazards and an assessment of risks for the workplace(s) it covers?
- Are Risk Assessments being carried out on a regular basis as risks change and are the necessary improvements made to keep the safety and health management system up to date?
- Are the necessary safety control measures required for a safe workplace identified and implemented, e.g. the provision of safe access and egress, good housekeeping, clear passageways and internal traffic control?
- Are written safe procedures for those operations that require them available, e.g. for routine processing and ancillary activities, handling and using chemicals, preventive maintenance, plant and equipment breakdown maintenance, accident and ill-health investigations, emergency planning, assessment of personal protective equipment (PPE) requirements?
- Are procedures available for monitoring the implementation of safety systems and control measures, e.g. are safety audits being carried out?
- Is safety and health training being carried out and does the training give adequate information to workers on risks they might be exposed to?
- Is the impact of this training and the level of understanding of the information assessed by anyone?
- Do safety consultation, employee participation and representation procedures exist and are these procedures effective, e.g. is there good co-operation between employer, managers and employees on safety and health issues at the workplace? Is there a safety committee in existence and if so does it comply with the 2005 Act requirements? Are safety committee meetings constructive with meeting reports and follow-up action lists? Is the safety representative or representatives involved at every stage of the safety consultation process?
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A Safety Statement should have a safety and health policy incorporated into it. What is this policy?
A safety and health policy is a written document which recognises that safety and health is an integral part of the organisation’s business performance. It is a statement by the organisation of it’s intentions and approach in relation to it’s overall safety and health performance and provides a framework for action, and for the setting of its safety and health objectives and targets. The safety and health policy must:
- be appropriate to the hazards and risks of the organisation’s work activities and include a commitment to protect, so far as is reasonably practicable, its employees and others, such as contractors and members of the public, from safety and health risks associated with its activities.
- include a commitment to comply with relevant safety and health legislation, Codes of Practice and guidelines, as a minimum.
- provide a framework for measuring performance and ensuring continuous improvement by setting, auditing and reviewing safety and health objectives and targets.
- be documented, understood, implemented and maintained at all levels of the organisation.
- clearly place the management of safety and health as a prime responsibility of line management from the most senior executive level to first-line supervisory level.
- cover employee safety and health consultation, safety committee meetings where they exist, worker participation and safety representation and includes a commitment to provide appropriate resources to implement the policy.
- provide for employee co-operation and compliance with safety rules and procedures.
Organisations achieving high standards of safety and health develop policies that recognise the:
- contribution that safety and health can make to business performance by preserving and developing human and physical resources, by reducing costs and liabilities, and by expressing corporate responsibility.
- need for leaders to develop appropriate organisational structures and a culture that supports risk control and secures the full participation of all members of the organisation.
- requirement to resource and plan policy implementation adequately.
- necessity of approaching injury, ill health and loss prevention by systematically identifying hazards, assessing and controlling risks.
- need for the organisation to develop an understanding of risks and risk control and to be responsive to internal and external change.
- requirement to scrutinise and review performance to learn from experience.
- connection between quality, the environment, safety and health, and good management practice.
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What critical safety and health issues should be addressed, and allocated adequate resources, in the safety and health policy?
Critical safety and health issues, which should be addressed and allocated resources, in the safety and health policy, include the:
- design, provision and maintenance of a safe place of work for all employees
- design, provision and maintenance of safe means of access to and egress from each part of the workplace
- design, provision and maintenance of any article, plant, equipment or machinery for use at work in a safe manner, provision of systems of work that are planned, organised, performed, maintained or revised, so as to be safe, particularly for safety critical process operations or services
- performance of ongoing hazard identification and Risk Assessments, and compliance with the general principles of prevention as set out in the legislation
- provision and maintenance of welfare facilities and PPE
- preparation of emergency plans and the provision of first-aid training
- reporting of accidents and dangerous occurrences to the Authority and their investigation
- provision and dissemination of safety and health information, instruction, training and supervision as required
- operation of safety and health consultation, employee participation and safety representation programmes
- review and keeping up-to-date the safety and health policy in order to prevent adverse effects on the safety and health of employees from changing processes, procedures and conditions in the workplace
- appointment of people responsible for keeping safety and health control systems in place and making them aware of their responsibilities
- establishment of monitoring arrangements, including safety and health inspections and audits, which should be used by the employer to ensure ongoing compliance with legal duties, responsibilities and controls
- development of in-house safety and health competence
- employment of external safety and health experts as required
- use of standards, Codes of Practice, guidelines or industry practices
- co-operation required from employees and disciplinary procedures for non-compliance.
However, this list is not exhaustive and the critical safety and health issues that could be covered by the policy will depend on the risks in the organisation. If the above issues are adequately covered elsewhere in the Safety Statement or in the safety and health management system, they might need only to be referred to in the safety and health policy. Backup documentation may also be referred to in the policy.
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Can I get an example of a safety and health policy anywhere?
Safety and health policies are specific to each individual organisation The content of the policy of an organisation should be based on the hazards and risks present in the organisation and should reflect the fact that systematic hazard identification and risk assessment have been undertaken. As a minimum, the policy should contain a commitment that safety and health legislation will be complied with and should specify those responsible for implementing the policy at all levels in the organisation and define their responsibilities. Employees’ responsibilities should also be addressed. An organisation’s policy declaration may be as follows:
To all employees:
As your employer, we are required to comply with all safety and health legislation that applies to this company. With this in mind we have carried out Risk Assessments of all our key operations and processes in all the workplaces we control. We have discussed these Risk Assessments with all relevant employees and worked with the safety committee in preparing this Safety Statement.
This statement sets out the safety and health measures we are implementing to protect everyone who works here.
The Board of ABC Ltd has endorsed this statement and gave me the responsibility to implement it. I am committed to ensuring that the safety and health measures set out in our Safety Statement are met.
John Kelly, Safety and Health Manager, will give advice and information on how to comply with this Safety Statement but everyone, especially if you are in a management or supervisory position, is responsible for ensuring compliance where they work.
We expect all employees to co-operate with us so that we can achieve our target of avoiding accidents. Consultation on safety and health matters, between senior managers and all employees, will be carried out through the safety committee, which you have selected.
You must play your part under the Safety Statement. Comply with all the safety and health rules for your area. Work safely and think of others as you do. Know and understand the Risk Assessments for your area. Report safety and health problems to your supervisor. Know who your safety representative is and contact him or her with any safety and health enquiries you may have.
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What are the responsibilities of management regarding the implementation of safety and health in the organisation?
Responsibility for safety and health management ultimately rests with the employer. This responsibility is normally delegated to executive directors, senior managers, line managers, supervisors and employees. Each person’s authority and duties should be clearly defined, documented and communicated to them. The organisational and reporting structure for implementing these duties should be illustrated in an in-house organisational chart. In addition each director on the organisation’s board needs to accept their responsibilities in providing safety and health commitment and leadership by:
- ensuring that each members’ actions and decisions at board level always reinforce the message in the organisation’s Safety Statement
- preventing a mismatch between individual board members attitudes, behaviour or decisions and the organisation’s Safety Statement so as not to undermine workers belief in maintaining good safety and health standards.
Accidents, ill health and incidents are seldom random events. They generally arise from failures of control and involve multiple contributory elements. The immediate cause may be a human or technical failure, but such events usually arise from organisational failings, which are the responsibility of management. Successful safety and health management systems aim to utilise the strengths of managers and other employees. The organisation needs to understand how human factors affect safety and health performance. Senior executive directors or other senior management controlling body members and executive senior managers are primarily responsible for safety and health management in the organisation. These people need to ensure that all their decisions reflect their safety and health intentions, as articulated in the Safety Statement, which should cover:
- the appointment of someone at senior management level with executive responsibility, accountability and authority for the development, implementation, periodic review and evaluation of their safety and health management system
- the safety and health ramifications of investment in new plant, premises, processes or products. For example such changes could introduce:
- new materials - are they toxic or flammable, do they pose new risks to employees, neighbours or the public and how will any new risks be controlled?
- new work practices - what are the new risks and are managers and supervisors competent to induct workers in the new practices?
- new people - do they need safety and health training and are they sufficiently competent to do the job safely?
- only engaging contractors to do new or ongoing projects that reinforce rather than damage the organisation’s safety and health policies
- recognising their continuing responsibility for safety and health even when work is contracted out
- providing their customers with the necessary safety and health precautions when supplying them with articles, substances or services
- being aware that although safety and health responsibilities can and should be delegated, legal responsibility for safety and health still rests with the employer.
Senior managers responsibilities include:
- preparing safety and health policies and consulting employees, including the safety committee where it exists, and the safety representative, as appropriate
- devising safety and health strategies for key high risks
- setting safety and health objectives and targets for employees
- devising plans to implement the safety and health policy
- ensuring that appropriate organisational structures are in place
- identifying and allocating resources for safety and health
- ensuring that the safety and health policy is effectively implemented and checking whether objectives and targets have been met
- reviewing the effectiveness of the safety and health management system
- implementing any necessary improvements derived from carrying out Risk Assessments
- giving all personnel the authority necessary to carry out individual safety and health responsibilities
- devising appropriate arrangements whereby employees are held accountable for discharging their responsibilities
- establishing clear and unambiguous reporting relationships
- devising job descriptions that include safety and health responsibilities
- incorporating safety and health performance in the appraisal system where personal appraisal systems exist
- developing safety and health cultures in project teams and team working situations.
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How can an organisation control safety and health aspects of contractors’ work?
Although organisations routinely contract out either all or parts of their work activities, they may still retain some of the legal responsibility for health and safety, particularly if they directly control how this work is done. For this reason, the organisation should establish and maintain procedures for controlling the safety and health aspects of contractor work. These should include:
- pre-planning for medium or long-term contracts. This will involve carrying out a full safety and health pre-qualification procedure; for short-term contracts, safety and health aspects should be suitably checked by questionnaire or review
- ensuring the contractor has prepared Risk Assessments and an up-to-date Safety Statement, which are specirfic for the project to be undertaken
- defining responsibility for and setting up communication links between appropriate levels of the organisation and the contractor before work starts and throughout the contract
- who is responsible for developing and providing site safety rules and method statements
- providing safety and health training and induction of contractor personnel, where necessary, before work begins
- monitoring safety and health aspects of contractor activities on site
- establishing procedures for communication of accidents and incidents involving the contractor‘s personnel
Additionally, it is also necessary for organisations to check the ability of contractors where they work close to, or in collaboration with, direct employees or with other contractor's employees. Such arrangements should cover the:
- recruitment and placement procedures that ensure employees (including managers) have the necessary physical and mental abilities to do their jobs or can acquire them through training and experience. This may require individual fitness assessments by medical examination and tests of physical fitness or aptitudes and abilities where work-associated risks require it
- systems to identify safety and health training needs arising from recruitment, changes in staff, plant, substances, technology, processes or working practices
- training documentation as appropriate to suit the size and activity of the organisation
- refresher training to maintain or enhance competence, to include where necessary contractors‘ employees, self-employed people or temporary workers who are working in the organisation
- communication systems and resources made available to ensure work is co-ordinated safely and the risk of accidents are minimised
- arrangements to ensure competent cover for staff absences, especially for staff with critical safety and health responsibilities
- general health promotion and surveillance schemes that contribute to the maintenance of general health and fitness; this may include assessments of fitness for work, rehabilitation, job adaptation following injury or ill-health, or a policy on testing employees for drugs or alcohol abuse
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Effective safety and health management includes effective emergency planning. What should this cover?
The organisation should establish and maintain procedures to respond to accidents and emergency situations, and to prevent and minimise the safety and health impacts associated with them. This is required by Section 11 of the Safety, Health and Welfare at Work Act 2005. Emergency planning should cover:
- the development of emergency plans
- the testing and rehearsing of these plans and related equipment, including fire fighting equipment and fire alarms
- training personnel on what to do in the event of an emergency, particularly those people who have to carry out duties (e.g. fire-fighting teams, first- aiders)
- advising people working or living near the installation about what they should do in the event of an emergency
- familiarising the emergency services with the facilities at the organisation so that they know what to expect in the event of an emergency.
The emergency plan itself should include:
- details on the installation, availability and testing of suitable warning and alarm systems
- details of emergency scenarios that might occur, including the means for dealing with these scenarios
- the emergency procedures in the organisation, including the responsibilities of key personnel, procedures for fire-fighting and evacuation of all personnel on site and first-aid requirements
- details of emergency services (e.g. fire brigade, ambulance services, spill clean-up services) and the contact arrangements for these services
- internal and external communications plans
- training plans and testing for effectiveness
- details on the availability of emergency rescue equipment and its maintenance log.
The organisation should periodically test, review and revise its emergency preparedness and response procedures where necessary, in particular after the occurrence of accidents or emergency situations. The emergency plan should dovetail with the Safety Statement as required by Section 20 of the 2005 Act. Major accident hazard sites covered by the EU COMAH Regulations, need to have emergency plans in place to cover major accidents involving chemicals. Details of what is required are covered at Control of Major Accident Hazards on this website.
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What key questions should an employer ask her/himself to determine the adequacy of safety and health management in the organisation?
The following are some key questions for employers to assist in determining the adequacy of their safety and health management in the organisation:
- Does your executive board of directors or senior management team ensure all their decisions reflect the safety and health intentions in your Safety Statement?
- Does your executive board of directors or senior management team recognise the need to involve all staff in issues that affect their safety and health?
- Do your directors and senior managers provide daily safety and health leadership in the organisation?
- Do you have an agreed safety and health policy? Is it written into your Safety Statement?
- Have you allocated responsibilities for safety and health to specific people - are they clear on what they have to do and are they held accountable?
- Is safety and health always considered before any new work is started or work equipment is bought?
- Did you consult and involve your staff and your safety representatives effectively?
- Have you identified the hazards and assessed the risks to your own staff, to others and to the public in the workplaces you control?
- Do you set standards for the premises, plant, substances, procedures and people you control or the products you produce? Are these standards in place and the risks effectively controlled?
- Do you have an emergency plan to deal with serious or imminent danger, e.g. fires, process deviations, gas leaks, the effects of poor weather, floods etc?
- Does your staff have sufficient information about the risks they are exposed to and the preventive measures they must take?
- Do you have the right levels of safety and health expertise? Are your employees properly trained and do they attend the training provided by you?
- Do you need specialist safety and health advice from outside and if so have you arranged to obtain it?
- Does all your staff accept their responsibilities under safety and health law?
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How can the safety and health management system be monitored?
It should be a line-management responsibility to monitor safety and health performance against predetermined plans and standards. Monitoring reinforces management’s commitment to safety and health objectives in general and helps to develop a positive safety and health culture by rewarding positive work done to control risk. Two types of monitoring are required:
- Active Systems, that monitor the design, development, installation and operation of management arrangements, safety systems and workplace precautions.
- Reactive Systems, that monitor accidents, ill health, incidents and other evidence of deficient safety and health performance.
1. Active monitoring
Every organisation should collect information to investigate the causes of substandard performance or conditions adequately. Documented procedures for carrying out these activities on a regular basis for key operations should be established and maintained. The monitoring system should include:
- identification of the appropriate data to be collected and accuracy of the results required
- monitoring of the achievement of specific plans, set performances criteria and objectives
- installation of the requisite monitoring equipment and assessment of its accuracy and reliability
- calibration and regular maintenance of this equipment together with documented records of both the procedures involved and the results obtained
- analysis and records of the monitoring data collected and documented actions to be taken when results breach performance criteria
- evaluation of all the data as part of the safety and health management review
- documented procedures for reviewing the monitoring and safety and health implications of forthcoming changes to work systems.
Techniques that should be used for active measurement of the safety and health management system include:
- systematic inspections of workplace processes or services to monitor specific objectives, e.g. weekly, monthly or quarterly reports
- systematic review of the organisation’s Risk Assessments to determine whether they are functioning as intended or need to be updated, and are the necessary improvements being implemented
- plant or machinery inspections, e.g. statutory plant inspections and certification
- environmental sampling for dusts, chemical fumes, noise or biological agents
- analysis of safety and health management system records.
2. Reactive monitoring
A system of internal reporting of all accidents (which includes ill health cases) and incidents of non-compliance with the safety and health management system should be set up so that the experience gained may be used to improve the management system. The organisation should encourage an open and positive approach to reporting and follow-up and should also put in place a system of ensuring that reporting requirements are met.
The organisation should establish procedures for investigating accidents and incidents to identify their causes, including possible deficiencies in the safety and health management system. Those responsible for investigating accidents, and incidents should be identified and the investigation should include plans for corrective action, which incorporate measures for:
- restoring compliance as quickly as possible
- preventing recurrence
- evaluating and mitigating any adverse safety and health effects
- reviewing the Risk Assessments to which the accident relates
- assessing the effects of the proposed remedial measures.
These techniques are explained in more detail in Appendix D of theAuthority's Guidance Workplace Safety and Health Management.
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Should the management of safety and health be audited in addition to monitoring performance?
Monitoring provides the information to let the organisation review activities and decide how to improve performance. Auditing and performance review are the final steps in the safety and health management control cycle. They constitute the ‘feedback loop’ that enables an organisation to reinforce, maintain and develop its ability to reduce risks to the fullest extent and to ensure the continued effectiveness of its safety and health management system. Audits, by the organisation’s own staff or by external bodies, complement monitoring activities by looking to see if the safety and health management systems are actually achieving the right results. Combine the results from measuring performance with information from audits to improve the organisation’s overall approach to safety and health management.
The organisation should establish and maintain a programme and procedures for periodic safety and health management system audits to be carried out. This enables a critical appraisal of all the elements of the safety and health management system to be made. Auditing is the structured process of collecting independent information on the efficiency, effectiveness and reliability of the total safety and health management system and drawing up plans for corrective action. These audits should be carried out in addition to routine monitoring, inspection and surveillance of the safety and health management system. The purpose of these audits is to ensure the continued suitability, adequacy and effectiveness of the safety and health management system. The audit process should ensure that the necessary information is collected to allow management to carry out this evaluation adequately.
The organisation should establish and maintain audit records consistent with the safety and health management system records. Their retention times should be established and must comply with legal requirements.
Further information on setting up and operating a safety and health management system audit is given in Appendix E of the Authority's Workplace Safety and Health Management.
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What should be contained in the system audit protocols and procedures?
The protocols and procedures for the audit on the health and safety management system should include the following:
- the allocation of resources to the process
- personnel requirements, including that of the audit team, i.e. competence required for auditors (auditors should have the appropriate training and skills so that they can assess physical, human and other factors and the use of procedures as well as documents or records - wherever possible, auditors should be independent of the activity being audited and include support from a wider range of specialists if necessary)
- the methodologies for conducting and documenting the audits, which may include checklists, questionnaires, interviews, measurement and direct observation
- the procedures for reporting audit findings to those responsible to facilitate timely corrective action and improvement
- a system for auditing and tracking the implementation of audit recommendations to include addressing the possible need for changes to safety and health policy, objectives and other elements of the safety and health management system.
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What key questions should an employer ask her/himself when measuring, reviewing and auditing their safety and health performance?
The key questions that an employer should ask when measuring, reviewing and auditing their safety and health performance are:
- Do you know how well you perform in safety and health?
- Are your executive board, your directors and senior management team kept informed of your safety and health performance and do you report on this performance in your annual report?
- How do you know if you are meeting your own objectives and standards for safety and health? Are your controls for risks good enough?
- How do you know you are complying with the safety and health laws that affect your business?
- Do your accident or incident investigations get to all the underlying causes - or do they stop when you find the first person that has made a mistake?
- Do you have accurate records of injuries, ill health, bullying complaints and accidental loss?
- Do you report on safety and health failures to your board and your directors?
- How do you learn from your mistakes and your successes?
- Do you carry out safety and health audits at least annually? If you do, what action do you take on audit findings?
- Do the audits involve staff at all levels? Do you involve your safety representative and safety committee, where it exists, in the audits?
- When did you last review your Safety Statement and your safety and health performance?
- Does your executive board of Directors or senior management team review your safety and health performance and ensure safety and health risk management systems are in place and remain effective?
- Has your executive board and your Directors or senior management team appointed someone at Director level to ensure safety and health risk management issues are properly addressed and is this person competent to do so?
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How does the employer train staff to ensure they have the skills, knowledge and attitudes to make them competent in the safety and health aspects of their work?
Under Section 10 of the Safety, Health and Welfare at Work Act 2005, employers must provide their employees with the instruction and training necessary to ensure their safety and health. There are specific training obligations for employees involved in the safety consultation and safety representation processes. Safety and health training must form part of the training of all people who work at the workplace. Training helps people acquire the skills, knowledge and attitudes to make them competent in the safety and health aspects of their work. It includes formal off-the-job training, instruction to individuals and groups, and on-the-job coaching and counselling. However, training is not a substitute for proper risk control, for example to compensate for poorly designed plant or inadequate workstations. The key to effective training is to understand job requirements and individual abilities.
In order to train staff to ensure they obtain the necessary skills, knowledge and attitudes to make them competent in the safety and health aspects of their work, it is important to identify appropriate training objectives and methods by first identifying the training needs. Training needs may be organisational, job-related and individual:
1. Organisational needs: Everyone in the organisation should know about the organisation‘s Safety Statement and the philosophy underlying it and the structure and systems for delivering the policy. Employees should also know which parts of the systems are relevant to them, to understand the major risks in the organisation‘s activities and how they are controlled.
2. Job-related needs: These fall into two main types - management needs and non-management needs.
Management needs include:
- leadership skills
- communication skills
- techniques of safety and health management
- training, instruction, coaching and problem - solving skills relevant to safety and health
- understanding of the risks in a manager's area of responsibility
- knowledge of relevant legislation and appropriate methods of control, including risk assessment
- knowledge of the organisation‘s planning, measuring, reviewing and auditing arrangements
- awareness of the financial and economic benefits of good safety and health performance.
Non-management needs include:
- an overview of safety and health principles
- detailed knowledge of the safety and health arrangements relevant to an individual‘s job
- communication and problem-solving skills to encourage effective participation in safety and health activities.
3. Individual needs: Individual needs are generally identified through performance appraisal. They may also arise because an individual has not absorbed formal job training or information provided as part of their induction. Training needs vary over time, and assessments should cover:
- induction of new starters, including part-time and temporary workers
- maintaining or updating the performance of established employees, especially if they may be involved in critical emergency procedures
- job changes, promotion or when someone has to deputise
- introduction of new equipment or technology
- follow-up action after an incident investigation.
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How does an organisation ensure it has access to sufficient safety and health knowledge, skills and/or experience to identify and manage safety and health risks effectively?
Organisations should ensure they have access to sufficient safety and health knowledge, skills or experience to identify and manage safety and health risks effectively, and to set appropriate objectives by:
- training managers to a sufficient level of competence to be able to manage their activities safely and keep up to date with developments in safety and health
- employing appropriate safety and health professionals as part of the management team to advise the organisation on relevant safety and health matters
- acquiring the necessary skills and advice from external providers as required.
Whichever method or combination of these methods is chosen by an organisation it does not relieve the employer and the management of the organisation from their legal responsibilities to ensure a safe workplace.
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What is the role of the safety and health advisor?
Safety and health advisers should have the status and competence to advise management and employees with authority and independence. By virtue of the definition of ‘competent person’ under the 2005 Act, they must possess sufficient training, experience and knowledge appropriate to the work to be done. They should be capable of advising on:
- formulating and developing safety and health policies, not just for existing activities but also with respect to new acquisitions or processes
- promoting a positive safety and health culture in the organisation and securing the effective implementation of safety and health policy
- planning for safety and health, including the setting of realistic short and long term objectives, deciding priorities and establishing adequate systems and performance standards
- day-to-day implementation and monitoring of policy and plans, including accident and incident investigation, reporting and analysis
- reviewing performance and auditing the whole safety and health management system.
To do this properly, safety and health advisers should:
- be properly trained by reputable organisations or be individuals who are suitably qualified; having membership of recognised professional safety and health bodies such as IOSH or BOHS and having a qualification to at least Diploma level in a recognised third-level safety and health course will offer routes for demonstrating competence
- maintain adequate information systems on topics including safety and health law, safety and health management and technical advances
- demonstrate the ability to interpret the law in the context of the organisation
- be involved in establishing organisational arrangements, systems and risk - control standards relating to hardware and human performance, by advising line management on matters such as legal and technical standards
- establish and maintain procedures for reporting, investigating, recording and analysing accidents and incidents
- establish and maintain procedures, including monitoring and other means such as review and auditing, to ensure that senior managers get a true picture of how well safety and health is being managed (where a benchmarking role may be especially valuable)
- present their advice independently and effectively.
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Key information to be covered in accident, ill-health and incident reports include:
1. The event:
- Details of any injured person, including age, sex, experience, training, etc.
- A description of the circumstances, including the place, time of day and conditions.
Details of the event, including:
- any actions which led directly to the event
- the direct causes of any injuries, ill-health or other loss
- the immediate causes of the event
- the underlying causes, e.g. failures in workplace precautions, risk control systems or management arrangements
- Details of the outcomes, including in particular:
- the nature of the outcome for example, injuries or ill-health to employees or members of the public; damage to property; process disruptions; emissions to the environment; creation of hazards
- the severity of the harm caused, including injuries, ill-health and losses
- the immediate management response to the situation and its adequacy, i.e.
Was it dealt with promptly?
Were continuing risks dealt with promptly and adequately? Was the first-aid response adequate?
Were emergency procedures followed?
- whether the event was preventable and if so how.
2. The potential consequences:
- What was the worst that could have happened?
- What prevented the worst from happening?
- How often could such an event occur (the ‘Recurrence Potential’)?
- What was the worst injury or damage, which could have resulted (the ‘Severity Potential’)?
- How many people could the event have affected (the 'Population Potential')?
- Prioritised actions with responsibilities and targets for completion
- Whether the risk assessments need to be reviewed and the safety statement updated.
4. Learning from and communicating results from investigations:
The organisation, having learnt from its investigations, should:
- identify root causes in the safety and health and general management of the organisation
- communicate findings and recommendations to all relevant parties
- include relevant findings and recommendations from investigations in the continuing safety and health review process.
5. Cautions in using accident and ill health data:
Accident and ill health data are important, as they are a direct indicator of safety and health performance. However, some cautions relating to their use are:
- most organisations have too few injury accidents or cases of work-related ill health to distinguish real trends from random effects.
- if more work is done by the same number of people in the same time, increased workload alone may account for an increase in accident rates.
- the length of absence from work attributed to injury or work-related ill health may be influenced by factors other than the severity of injury or occupational ill health. Such factors can include poor morale, monotonous work, stressful working conditions, poor management / employee relations and local advice or traditions.
- accidents are often under-reported, and occasionally over-reported. Levels of reporting can change. They can improve as a result of increased workforce awareness and better reporting and recording systems.
- a time delay can occur between safety and health management system failures and harmful effects. Moreover, many occupational diseases have long latent periods. Management should not wait for harm to occur before judging whether safety and health management systems are working.
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