Safety Management Systems

CODE OF PRACTICE ON SAFETY MANAGEMENT 1
CODE OF PRACTICE
On
Safety Management
Occupational Safety and Health Branch
Labour Department
CODE OF PRACTICE ON SAFETY MANAGEMENT
2
This C ode of Practice is prepared by the
O ccupational Safety and H ealth B ranch
Labour D epartm ent
First edition A pril 2002
This C ode of Practice is issued free of charge and can be obtained from offices of the
O ccupational Safety and H ealth B ranch. Its contents can also be dow nloaded from the
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Internet. For enquiries about addresses and telephone num bers of the offices, please contact
us through telephone 2559 2297.
This C ode of Practice m ay be freely reproduced except for advertising, endorsem ent or
com m ercial purposes. Please acknow ledge the source as "C ode of Practice on Safety
M anagem ent", published by the Labour D epartm ent.
Page
1. INTRODUCTION 6
2. INTERPRETATION 8
3. RESPONSIBILITIES OF PROPRIETORS AND CONTRACTORS 11
4. DEVELOPING, IMPLEMENTING AND MAINTAINING A SAFETY 18
MANAGEMENT SYSTEM
4.1 H ow to develop a safety m anagem ent system ? 18
4.2 H ow to im plem ent a safety m anagem ent system ? 23
4.3 H ow to m aintain a safety m anagem ent system ? 25
4.4 M anagem ent m odel to develop, im plem ent and m aintain a safety 27
m anagem ent system
4.5 A pplication of the m anagem ent m odel to individual elem ents of a 28
safety m anagem ent system
4.6 A pplication of the m anagem ent m odel to safety audits or safety 29
review s
5. THE ELEMENTS OF A SAFETY MANAGEMENT SYSTEM 30
5.1 A safety policy w hich states the com m itm ent of the proprietor 31
or contractor to safety and health at w ork
5.2 A structure to assure im plem entation of the com m itm ent to safety 34
and health at w ork
5.3 Training to equip personnel w ith know ledge to w ork safely and 40
w ithout risk to health
5.4 In-house safety rules to provide instruction for achieving safety 45
m anagem ent objectives
5.5 A program m e of inspection to identify hazardous conditions and 47
for the rectification of any such conditions at regular intervals or
as appropriate
C O N TEN TS
4
5.6 A program m e to identify hazardous exposure or the risk of such 50
exposure to the w orkers and to provide suitable personal
protective equipm ent as a last resort w here engineering
control m ethods are not feasible
5.7 Investigation of accidents or incidents to find out the cause of any 54
accident or incident and to develop prom pt arrangem ents
to prevent recurrence
5.8 Em ergency preparedness to develop, com m unicate and execute 58
plans prescribing the effective m anagem ent of em ergency situations
5.9 Evaluation, selection and control of sub-contractors to ensure that 60
sub-contractors are fully aw are of their safety obligations and
are in fact m eeting them
5.10 Safety com m ittees 65
5.11 Evaluation of job related hazards or potential hazards 70
and developm ent of safety procedures
5.12 Prom otion, developm ent and m aintenance of safety 77
and health aw areness in a w orkplace
5.13 A program m e for accident control and elim ination of hazards 79
before exposing w orkers to any adverse w ork environm ent
5.14 A program m e to protect w orkers from occupational health hazards 83
6. SAFETY AUDIT 88
6.1 W hat is a "Safety A udit" ? 88
6.2 The appointm ent of a registered safety auditor to conduct a safety 92
audit
6.3 A ssistance, facilities and inform ation to be provided for the purposes 96
of safety audit
6.4 Things to observe w hen the safety auditor is an em ployee of the 99
proprietor or contractor
6.5 A ctions to be taken on safety audit report 100
6.6 O bligation to produce safety audit report or plan for inspection 103
7. SAFETY REVIEW 104
7.1 W hat is a "Safety R eview "? 104
7.2 The appointm ent of a safety review officer to conduct a safety review 108
7.3 A ssistance, facilities and inform ation to be provided for the 111
purposes of safety review
7.4 Things to observe w hen the safety review officer is an em ployee of 114
the proprietor or contractor
7.5 A ction to be taken on safety review report 115
7.6 O bligation to produce safety review report or plan for inspection 118
REFERENCES 119
USEFUL INFORMATION 122
6
In 1995, the G overnm ent conducted a com prehensive review of industrial safety
w ith a view to m apping out H ong K ong's long-term safety strategies. The R eview
concluded that for H ong K ong to achieve high standards of safety and health at
w ork, enterp rises m ust em b race self-reg ulation and safety m anag em ent. The
R eview recom m end ed that the G overnm ent should p rovid e a fram ew ork w ithin
w hich self-reg ulation w as to b e achieved throug h a com p any system of safety
m anag em ent.
A gainst this background, the G overnm ent has introduced a safety m anagem ent
system consisting of 14 elem ents. It has prom oted the system through launching
pilot schem es, publishing an O ccupational Safety C harter, organising sem inars
and p rom otional visits, and issuing a G uid e to S afety M anag em ent.
This system is now enshrined in the Factories and Industrial U ndertakings (Safety
M a n a g e m e n t) R e g u la tio n [h e re in a fte r c a lle d "th e S a fe ty M a n a g e m e n t
R eg ulation"] p assed on 24 N ovem b er 1999.
U nder the Safety M anagem ent R egulation, proprietors or contractors of certain
ind ustrial und ertaking s are req uired to d evelop , im p lem ent and m aintain in
resp ect of the und ertaking s a safety m anag em ent system w hich contains a
num b er of key p rocess elem ents. They are also req uired to have the system
reg ularly aud ited or review ed .
This C od e of P ractice on S afety M anag em ent [hereinafter called the C O P ] is a
C ode of Practice issued by the C om m issioner for Labour under section 7A (1) of
the Factories and Industrial U ndertakings O rdinance (C ap. 59). It aim s to provide
p ractical g uid ance for p rop rietors and contractors of relevant ind ustrial
und ertaking s to com p ly w ith the aforesaid leg al req uirem ents. It sets out, in
Part 4, how proprietors or contractors should develop, im plem ent and m aintain
a safety m anagem ent system . It provides, in Part 5, practical guidance in respect
of the 14 elem ents of a safety m anag em ent system . It also p rovid es, in P art 6
and P art 7, p ractical g uid ance on safety aud its and safety review s.
First and forem ost, how ever, p rop rietors and contractors should refer to P art 3
of this C O P for p ractical g uid ance on their level and scop e of resp onsib ilities
und er the S afety M anag em ent R eg ulation in relation to their ind ustrial
und ertaking s' size of em p loym ent and the value of w ork und ertaken.
1.IN TR O D U C TIO N
This C O P has a special legal status. A lthough failure to observe any guidance given in
this C O P is not in itself an offence, that failure m ay be taken by a court in crim inal
proceedings as a relevant factor in determ ining w hether or not a person has breached
any of the provisions of the Safety M anagem ent R egulation to w hich the guidance
relates.
The statutory provisions referred to or quoted in this C O P are those in force on
1 A pril 2002.
Introduction
8
In this C O P, unless the context otherw ise requires -
"construction site" (!) m eans a p lace w here construction w ork is
undertaken and also any area in the im m ediate vicinity of any such place w hich
is used for the storage of m aterials or plant used or intended to be used for the
purpose of the construction w ork;
"copy" (), in relation to any docum ent, includes the original of the docum ent;
"designated undertaking" (!) m eans an industrial undertaking involving any
of the follow ing activities -
(a) the generation, transform ation and transm ission of electricity;
(b) the generation and transm ission of tow n gas, or liquefied petroleum gas,
w ithin the m eaning of section 2 of the G as Safety O rdinance (C ap. 51); or
(c) container handling;
"hazard"* () m eans a source or a situation w ith a potential for harm in term s of
hum an injury or ill-health, dam age to property, dam age to the environm ent, or a
com bination of these;
"ill-health"* (!) m eans ill-health that is judged to have been caused by or
m ade w orse by a person's w ork activity or w ork environm ent;
"incident"* () m eans an unplanned event w hich has the potential to lead to
accident;
"registered" () m eans registered under section 6(1) of the Safety M anagem ent
R egulation as a safety auditor or schem e operator;
"registered safety auditor" (!"#$) m eans a person registered as a safety
auditor;
"registered scheme operator" (!"#$) m eans a person registered as a
schem e operator;
"relevant industrial undertaking" (!"#), in relation to a p rop rietor or
contractor specified in Schedule 3 of the Safety M anagem ent R egulation, m eans the
industrial undertaking specified in that Schedule (and how soever w orded) in
connection w ith the proprietor or contractor, as the case m ay be;
"risk"* (!") m eans the com b ination of the likelihood and conseq uence
of a sp ecified hazard ous event occurring ;
2.IN TER PR ETATIO N
Interpretation
"risk assessment"* (!) m eans the overall p rocess of estim ating the
m agnitude of risk and deciding w hether or not the risk is tolerable. It also
includ es the p rocess of recog nizing that a hazard exists and d efining its
characteristics;
"risk control"* (!) m e a n s th e o ve ra ll p ro c e ss o f d e ve lo p in g ,
im p lem enting and m aintaining the safety p roced ures and risk control
m easures. It also includes the review of the safety procedures and risk control
m easures;
"safety audit" (!) m eans an arrangem ent for -
(a) c o lle c tin g , a sse ssin g a n d ve rifyin g inform ation on the efficiency,
effectiveness and reliability of a safety m anagem ent system (including the
elem ents specified in Schedule 4 of the Safety M anagem ent R eg ulation
contained in the system ); and
(b) considering im provem ents to the system ;
"safety audit report" (!"#) m eans a rep ort com p iled b y a reg istered
safety aud itor after the com p letion of a safety aud it;
"safety auditor" (!") m eans a p erson w ho cond ucts or p rop oses to
cond uct safety aud its;
"safety committee" (!") m e a n s a sa fe ty c o m m itte e e sta b lish e d
under section 10 of the Safety M anagem ent R egulation;
"safety management" (!) m eans the m anagem ent functions connected w ith
the carrying on of an industrial undertaking that relate to the safety of personnel
in the undertaking, including -
(a) the planning, developing, organizing and im plem enting of a safety policy;
and
(b) the m easuring, auditing or review ing of the perform ance of those functions;
"safety management system" (!"#)m eans a system w hich p rovid es
safety m anag em ent in an ind ustrial und ertaking ;
10
"safety plan" *(!) m eans a plan for carrying out a safety policy;
"safety review" (!) m eans an arrang em ent for -
(a) review ing the effectiveness of a safety m anag em ent system (includ ing
th e elem ents sp ecified in S ched ule 4 of the S afety M anag em ent
R eg ulation contained in the system ); and
(b) considering im provem ents to the effectiveness of the system ;
"safety review officer" (!") m eans a person w ho is appointed to conduct a
safety review under section 19(1) (a) of the Safety M anagem ent R egulation;
"safety review report" (!"#) m eans a report com piled by a safety review
officer after the com pletion of a safety review ;
"scheme" () m eans a schem e to train persons to be safety auditors;
"scheme operator" (!") m eans a p erson w ho op erates or p rop oses to
op erate a schem e;
"shipyard" () m eans any yard or dry dock (including the precincts thereof) in
w hich ship s or vessels, except ships or vessels afloat, are constructed,
reconstructed, m aintained, repaired, refitted, finished or broken up.
N ote : The ab ove term s, excep t those m arked w ith "*", are g iven the
m eaning s as stip ulated und er section 2 of the S afety M anag em ent
R eg ulation.
Interpretation
PART 1
1. A contractor in relation to construction w ork having an aggregate of 100 or
m ore w orkers in a day w orking in a single construction site.
2. A contractor in relation to construction w ork w ith a contract value of $100
m illion or m ore.
3. A proprietor of a shipyard business having an aggregate of 100 or m ore
w orkers in a day w orking in a single shipyard.
4. A proprietor of a factory having an aggregate of 100 or m ore w orkers
in a d ay w orking in a sing le factory.
5. A proprietor of a designated undertaking having an aggregate of 100
or m ore w orkers in a d ay w orking in a sing le w orkp lace.
PART 2
m ore but less than 100 w orkers in a day w orking in a single construction
site.
2. A proprietor of a shipyard business having an aggregate of 50 or m ore but
less than 100 w orkers in a day w orking in a single shipyard.
3. A p rop rietor of a factory having an ag g reg ate of 50 or m ore b ut less
than 100 w orkers in a d ay w orking in a sing le factory.
4. A p rop rietor of a d esig nated und ertaking having an ag g reg ate of 50
or m ore b ut less than 100 w orkers in a d ay w orking in a sing le
w orkp lace.
U nder the S afety M anagem ent R egulation, a proprietor or contractor specified in
Schedule 3 is required to develop, im plem ent and m aintain in respect of the relevant
industrial undertaking a safety m anagem ent system , consisting of som e or all of the elem ents
stipulated in Schedule 4.
Schedule 3 is divided into 4 parts (w ith each part containing one group of proprietors or
contractors) as follow s :
3.R ESPO N SIB ILITIES O F PR O PR IETO R S
A N D C O N TR A C TO R S
12
PART 3
m ore w orkers in a day w orking in 2 or m ore construction sites.
2. A proprietor of a shipyard business having an aggregate of 100 or m ore
w orkers in a day w orking in 2 or m ore shipyards.
3. A proprietor of a factory having an aggregate of 100 or m ore w orkers in a
day w orking in 2 or m ore factories.
4. A proprietor of a designated undertaking involving any one or m ore of the
activities sp ecified in p arag rap h (a) of the definition of designated
undertakingin section 2(1) of this R egulation, having an aggregate of 100 or
m ore w orkers in a day w orking in 2 or m ore w orkplaces.
activities specified in paragraph (b) of the definition of designated undertaking
in section 2(1) of this R egulation, having an aggregate of 100 or m ore w orkers
in a day w orking in 2 or m ore w orkplaces.
activities sp ecified in p arag rap h (c) of the definition of designated
undertakingin section 2(1) of this R egulation, having an aggregate of 100 or
m ore w orkers in a day w orking in 2 or m ore w orkplaces.
PART 4
m ore but less than 100 w orkers in a day w orking in 2 or m ore construction
sites.
2. A proprietor of a shipyard business having an aggregate of 50 or m ore but
less than 100 w orkers in a day w orking in 2 or m ore shipyards.
3. A proprietor of a factory having an aggregate of 50 or m ore but less than
100 w orkers in a day w orking in 2 or m ore factories.
activities specified in paragraph (a) of the definition of designated undertaking
in section 2(1) of this R egulation, having an aggregate of 50 or m ore but less
than 100 w orkers in a day w orking in 2 or m ore w orkplaces.
activities specified in paragraph (b) of the definition of designated undertaking
activities specified in paragraph (c) of the definition of designated undertaking
Responsibilities of Proprietors and Contractors
A proprietor or contractor specified in Part 1 or Part 3 of Schedule 3 is required by the
Safety M anagem ent R egulation to develop, im plem ent and m aintain in respect of the
relevant industrial undertaking a safety m anagem ent system w hich contains the
10 elements as stipulated in Parts 1 and 2 of Schedule 4. [Sections 8(1) and 8(3) of
the Safety M anagem ent R egulation]
A proprietor or contractor specified in Part 2 or Part 4 of Schedule 3 is required by the
Safety M anagem ent R egulation to develop, im plem ent and m aintain in respect of the
relevant industrial undertaking a safety m anagem ent system w hich contains the
8 elements listed in Part 1 of Schedule 4. [Sections 8(2) and 8(4) of the Safety
M anagem ent R egulation]
Note:
The im plem entation of the Safety M anagem ent R egulation w ill be review ed one year
after the R egulation has com e into force to decide on the appropriate tim e to bring the
rem aining 4 elem ents listed in Part 3 of Schedule 4 into operation.
14
THE SITUATION CAN BE GRAPHICALLY ILLUSTRATED BY THE FOLLOWING DIAGRAM:
Part 1
Part 2
Part 3
Part 4
LEGENDS
The proprietor or contractor shall include the elem ents contained
in this box in his safety m anagem ent system
Safety policy
1. A safety policy w hich states the com m itm ent of the proprietor or contractor to
safety and health at w ork.
Organisational structure
2. A structure to assure im plem entation of the com m itm ent to safety and health at w ork.
Safety training
3. Training to equip personnel w ith know ledge to w ork safely and w ithout risk to health.
In-house safety rules
4. In-house safety rules to provide instruction for achieving safety m anagem ent
objectives.
Inspection programme
5. A p rog ram m e of insp ection to id entify hazard ous cond itions and for the
rectification of any such conditions at regular intervals or as appropriate.
Hazard control programme
6. A program m e to identify hazardous exposure or the risk of such exposure to the
w orkers and to provide suitable personal protective equipm ent as a last resort
w here engineering control m ethods are not feasible.
Accident/incident investigation
7. Investigation of accidents or incidents to find out the cause of any accident or
incident and to develop prom pt arrangem ents to prevent recurrence.
Emergency preparedness
8. Em ergency preparedness to develop, com m unicate and execute plans
prescribing the effective m anagem ent of em ergency situations.
Evaluation, selection and control of sub-contractors
1. Evaluation, selection and control of sub-contractors to ensure that sub-
contractors are fully aw are of their safety obligations and are in fact m eeting
them .
Safety committees
2. Safety com m ittees to identify, recom m end and keep under review m easures to
im prove the safety and health at w ork.
J ob-hazard analysis
1. Evaluation of job related hazards or potential hazards and developm ent of safety
procedures.
Safety and health awareness
2. Prom otion, developm ent and m aintenance of safety and health aw areness in a
w orkplace.
Accident control and hazard elimination
3. A program m e for accident control and elim ination of hazards before exposing
w orkers to any adverse w ork environm ent.
Occupational health assurance programme
4. A program m e to protect w orkers from occupational health hazards.
N .B . see note at Page 13
16
Other related responsibilities
In addition to the duties to develop, im plem ent and m aintain a safety m anagem ent
system under the Safety M anagem ent R egulation, a proprietor or contractor specified
in Part 1 or Part 3 of Schedule 3 is also required to discharge his duties under -
(a) section 9 in relation to a safety policy
1
;
(b) sections 10 to 12 in relation to safety com m ittees
2
; and
(c) sections 13, 14, 16(1) and 17 in relation to safety audits
3
.
In addition to the duties to develop, im plem ent and m aintain a safety m anagem ent
system under the Safety M anagem ent R egulation, a proprietor or contractor specified
in Part 2 or Part 4 of Schedule 3 is also required to discharge his duties under -
(a) section 9 in relation to a safety policy
1
; and
(b) sections 19, 20, 22(1), 23 and 24(2) in relation to safety review s
4
.
Responsibilities of the proprietors, contractors and sub-contractors in a
big project
The ap p roach ad op ted in the S afety M anag em ent R eg ulation is cap ab le of
creating different layers of safety m anagem ent system s to be im plem ented in a
big enterprise or project. Therefore, a proprietor or contractor of, for exam ple,
a construction firm w hich op erates construction sites at d ifferent locations is
required to develop, im plem ent and m aintain a safety m anagem ent system both
at the enterp rise level and at the w orkp lace level w ithin its und ertaking s or
construction sites, as long as the proprietor or contractor falls w ithin Schedule 3 of the
Safety M anagem ent R egulation.
To illustrate this w ith a further exam p le, let us use the case of a joint venture,
consisting of several contracting firm s, and eng ag ed in a b ig construction
project. The joint venture should im plem ent its safety m anagem ent system and
1
R efer to Part 5.1 of the C O P concerning safety policy.
2
R efer to Part 5.10 of the C O P concerning safety com m ittee.
3
R efer to Part 6 of the C O P concerning safety audit.
4
R efer to Part 7 of the C O P concerning safety review .
run a safety com m ittee by itself w ith m em bers from the contracting firm s involved.
A t the sam e tim e, these individual contracting firm s, depending on size, should
also have their ow n safety m anag em ent system s and safety com m ittees
org anised in resp ect of the various sites of the p roject. A lso, d ep end ing on
size, in each of the resp ective p arent com p anies of these contracting firm s,
there should b e an overall safety m anag em ent system and a safety com m ittee
for overseeing the sites und er its control.
It should b e noted that sub -contractors are also req uired to set up their ow n
safety m anag em ent system s if they b elong to one of the g roup s of p rop rietors
or contractors as sp ecified in S ched ule 3.
A nyw ay, it should b e noted that com p liance w ith sub section (1), (2), (3) or (4)
of section 8 b y a p rop rietor or contractor in resp ect of a relevant ind ustrial
und ertaking sp ecified in p art 1, 2, 3 or 4 of S ched ule 3 shall not b e treated as
com p liance w ith that sub section, or another sub section of that section, b y the
p rop rietor or contractor, as the case m ay b e, in resp ect of any other relevant
ind ustrial und ertaking sp ecified in the sam e P art, or another P art, of that
S ched ule. [S ection 2(3) of the S afety M anag em ent R eg ulation]
18
A p rop rietor or contractor of a relevant ind ustrial und ertaking shall develop,
implement and maintain in respect of the relevant industrial undertaking a safety
m anagem ent system w hich contains the elem ents applicable to that undertaking.
[Section 8 of the Safety M anagem ent R egulation].
4.1 How to develop a safety management system ?
The development of a safety m anagem ent system involves planning and
developing.
4.1.1Planning
Planning is the p rocess of d eterm ining in ad vance w hat should b e
accom plished. The planning stage answ ers the questions: "W here are w e
now ?" and "W here do w e w ant to be?".
(1) A t this stage, the proprietor or contractor of a relevant industrial
undertaking is required:
(a) to identify in advance w hat safety and health objectives should
be accom plished by a safety m anagem ent system as appropriate
to the relevant industrial undertaking under the Safety M anagem ent
R egulation;
(b) to prioritise the safety and health objectives and devise the w ays
and m eans to achieve them ; and
(c) to estim ate the financial and other resource im plications arising
from the accom plishm ent of these safety and health objectives.
(2) For the purposes of 4.1.1(1) above, the proprietor or contractor should:
(a) conduct an initial status analysis to take stock of the existing
arrang em ents for m anag ing safety and health;
(b) carry out risk assessm ents to decide on priorities and objectives
for hazard elim ination and risk control;
(c) establish perform ance standards for m onitoring perform ance; and
(d) conduct periodic status analyses for the safety m anagem ent
system in operation.
4.D EVELO PIN G , IM PLEM EN TIN G A N D
M A IN TA IN IN G A SA FETY M A N A G EM EN T
SYSTEM
(3) G uid ance on how to cond uct the initial status analysis, p eriod ic
status analyses and risk assessm ents is p rovid ed as follow s -
(a) Initial status analysis
Initial status analysis is the process of finding out the current
position as regards how safety and health m atters are being
m anaged in the industrial undertaking. This should be done if
th e p ro p rie to r o r c o n tra c to r is e sta b lish in g a sa fe ty
m anagem ent system for his industrial undertaking for the first
tim e. The analysis should answ er the question of "W here are
w e now ?". The findings should be com pared w ith
- the requirem ents of relevant legislation dealing w ith safety
and health at w ork; and
- the best trade practices and trade perform ance,
to show how big the 'gap' is betw een 'w here w e are now ' and
'w here w e w ant to be'. The legal requirem ents represent the
m inim um standards to be achieved, w hereas the best trade
p ractices and trad e p erform ance p rovid e a d irection for
continuous im provem ent.
In conducting the analysis, the proprietor or contractor should
ensure that it ad eq uately covers each of the elem ents as
appropriate to him under the Safety M anagem ent R egulation.
(b) Periodic status analyses
A fter the initial status analysis, the p rop rietor or contractor
should ensure that sim ilar status analyses of the safety
m anagem ent system in operation are conducted periodically
to facilitate continuous im p rovem ent. The p rop rietor or
contractor should d efine the scop e and freq uency of the
periodic status analyses based on the needs of the relevant
ind ustrial und ertaking , having reg ard to the follow ing :
- the findings/recom m endations of safety audits or safety
review s; and
- the changes in organisational structure, legislation and
the introd uction of new technolog y.
Developing, implementing and maintaining a safety management system
20
(c) R isk assessm ent
For planning purposes, risk assessm ent is used to estim ate
an industrial undertaking's overall risk profile. The findings w ill
provide the basis for the proprietor or contractor to form ulate risk
control strategies, set out safety and health objectives, and define
standards and priorities.
The b asic step s in risk assessm ent includ e the follow ing :
(i) Identification of hazards
This is the process of identifying all significant hazards
relating to each w ork activity and considering w ho m ay be
harm ed and how harm m ay be done.
(ii) D eterm ination of risk
This is the process of m aking a subjective evaluation of the
risk associated w ith each hazard assum ing that planned or
existing controls are in p lace, and consid ering the
effectiveness of the controls and the consequences of their
failure. A lso, it is necessary to decide if the risk is tolerable.
In deciding w hether a risk is tolerable, the proprietor or
contractor has to take into account w hether the condition is
w ithin statutory lim its and/or conform to legal or internationally
recognised standards. O nly w hen these lim its and standards
are m et and the risk is at, or has been reduced to, the low est
possible level that is reasonably practicable should a risk
be considered tolerable.
A fter risk assessm ent, the follow ing actions should be taken to
elim inate or control the identified risks:
(i) D evelopm ent of safety procedures and risk control m easures
Safety procedures and risk control m easures should be
developed for risks that are not tolerable.
(ii) Im plem entation and m aintenance of safety procedures and
risk control m easures
Safety procedures and risk control m easures should be properly
and fully im plem ented. Besides, these safety procedures and
risk control m easures should be properly m aintained to ensure
their effectiveness.
(iii) R eview of safety procedures and risk control m easures
R eview is necessary w henever there is reason to suspect
that the safety p roced ures and risk control m easures
are no longer effective, or if there has been a significant
chang e in the m atters to w hich they relate.
R isk assessm ent and risk control are d iscussed in d etail in
p art 5.11 of this C O P.
(4) The proprietor or contractor should appoint a com petent person to
carry out status analyses and risk assessm ent. For these purposes, a
com petent person is a person w ho is -
(a) appointed by the proprietor or contractor to ensure that the duty
is carried out ; and
(b) by reason of substantial training and practical experience
com petent to perform the duty.
4.1.2Developing
Developing is the process of determ ining how the safety and health
objectives should be realised. The developing stage needs to answ er the
question: "H ow do w e get there?".
(1) A t this stage, the proprietor or contractor of a relevant industrial
undertaking is required to define, docum ent and endorse a safety policy
to spell out the safety and health objectives identified at the planning
stage, and ensure that the policy includes a com m itm ent to:
- achieve a high standard of occupational safety and health in
com pliance w ith legal requirem ents as the m inim um , and in
conform ity w ith the b est trad e p ractices for continuous
im provem ent;
- provide adequate resources to im plem ent the policy;
- m ake occup ational safety and health one of the p rim ary
responsibilities of line m anagem ent, from the m ost senior executive
to the first-line supervisor;
- ensure its understanding, im plem entation and m aintenance at
all levels in the organisation;
22
- ensure em p loyee involvem ent and consultation to g ain
com m itm ent to the policy and its im plem entation;
- ensure the carrying out of periodic review of the policy and the
m anagem ent system ; and
- ensure that em ployees at all levels receive appropriate training
and are com petent to carry out their duties and responsibilities.
Safety policy is discussed in detail in Part 5.1.
(2) To carry out the safety policy, the proprietor or contractor should
prepare an effective safety plan w hich sets out in specific term s:
- a clear direction and a series of actions for the relevant industrial
undertaking to follow to achieve the objectives of the safety policy;
and
- clear guidance for m anagers and w orkers to w ork together to
accom plish the objectives of the safety policy.
The safety plan should be established by the industrial undertaking's
senior m anagem ent, w ith the advice and assistance of safety and health
personnel. A s far as reasonably practicable, all levels of m anagers,
supervisors and w orkers should be involved in the developm ent of the
plan. There is no fixed rule as to how detailed or lengthy a safety plan
should be. G enerally speaking, a safety plan should spell out the safety
policy, along w ith the objectives and standards to be achieved, the
statutory and, w here appropriate, contractual obligations to be fulfilled,
the risks to be tackled and the safety procedures and m easures to be
adopted. To be effective, the plan should set out:
(a) a system of allocation of responsibilities for safety and health;
(b) the arrangem ents for the responsibilities to be discharged;
(c) the arrangem ents for carrying out each and every elem ent of the
safety m anag em ent system ap p licab le to the ind ustrial
undertaking; and
(d) the arrangem ents for m onitoring the success of the plan.
W here necessary, further details can be spelt out in safety m anuals,
m ethod statem ents, handbooks, etc. A ll m anagers, supervisors and
em p loyees should know the p lan and the role they p lay in its
im plem entation. Establishing an effective com m unication system w ithin
the organization is therefore essential.
Finally, the safety plan should be regularly review ed and, w here
necessary, m odified in the light of experience to ensure effectiveness.
4.2 How to implement a safety management system ?
The implementation of a safety m anagem ent system involves organising and
implementing.
4.2.1Organising
Organising is the process of prescribing form al relationships betw een
people and resources in the organisation to accom plish objectives. A t this
stage, the proprietor or contractor of a relevant industrial undertaking is
required:
(a) to ensure that occupational safety and health is fully integrated across
the relevant industrial undertaking and into all its activities, w hatever
the size or nature of its w ork;
(b) to set aside an adequate budget com m ensurate w ith the relevant
industrial undertaking's size and nature for im plem enting the policy
and for properly establishing and m aintaining the elem ents of the safety
m anagem ent system ;
(c) to structure the relevant industrial undertaking properly so that it can
put the safety policy and plan into practice effectively;
(d) to allocate safety and health responsibilities;
(e) to m ake arrangem ents for the form ation and operation of a safety
com m ittee, a safety departm ent/unit/group and the appointm ent of a
safety officer/advisor/director, etc.;
("safety officer" m eans a person em ployed as a safety officer in
an ind ustrial und ertaking und er the Factories and Ind ustrial
U ndertakings (Safety O fficers and Safety Supervisors) R egulations
(C ap.59, sub.leg.))
(f) to ensure all em ployees have the necessary authority to carry out their
safety and health responsibilities;
24
(g) to allocate to a p erson at the top m anag em ent level a sp ecial
responsibility for ensuring that the safety m anagem ent system is
properly im plem ented in all locations and spheres of operation w ithin
the relevant industrial undertaking;
(h) to m ake arrangem ents for the effective dissem ination of occupational
safety and health inform ation;
(i) to m ake effective arrangem ents for the provision of specialist advice
and services on occupational safety and health;
(j) to m ake effective arrangem ents for em ployees at all levels to take part
in safety and health activities; and
(k) to identify the com petencies required for em ployees at all levels and
arrange the necessary training.
4.2.2 Implementing
Implementing is the process of carrying out or putting into practice the
plans to achieve the desired objectives, w ith appropriate and adequate
control to ensure proper perform ance in accordance w ith the plans. A t this
stage, the proprietor or contractor of a relevant industrial undertaking is
required:
(a) to d eterm ine and execute op eration p lans to control the risks
id entified and to m eet the leg al req uirem ents as w ell as other
req uirem ents reg ard ing safety m anag em ent;
(b) to provide adequate and effective supervision to ensure that the policies
and plans are effectively im plem ented;
(c) to p rep are and m aintain sufficient d ocum entation to record and
m onitor the progress of the im plem entation of policies and plans; and
(d) to have em erg ency resp onse p lans in p lace for foreseeab le
em ergencies and m aintain a high level of em ergency preparedness.
4.3 How to maintain a safety management system ?
The maintenance of a safety m anagem ent system involves measuring and
auditing or reviewing, through w hich a proprietor or contractor know s w hether
the safety m anagem ent system of his relevant industrial undertaking is w orking
w ell or need s im p rovem ent, thereb y m aintaining the system in an
efficient and effective state.
4.3.1 Measuring
Measuring is the process of checking perform ance against agreed
standards to find out w hen and w here im provem ent is needed, and a m eans
of m onitoring the extent to w hich policies and objectives are being m et.
The m easuring stag e p rovid es a "feed b ack loop " for the stag es of
developm ent and im plem entation of a safety m anagem ent system and help
the relevant industrial undertaking reinforce and m aintain its ability to
reduce risks to the fullest extent and to ensure the continued efficiency,
effectiveness and reliability of the safety m anagem ent system . A t this
m easuring stage, the proprietor or contractor of a relevant industrial
(a) to carry out proactive m onitoring through, for exam ple, surveillance
and inspections covering both hardw are (i.e. prem ises, plant and
substances) and softw are (i.e. people, procedures and system s of
w ork), for the p urp ose of checking (i) com p liance w ith leg al
requirem ents and (ii) w hether the safety and health arrangem ents in
place are effective in achieving the objectives of the safety policy;
(b) to closely m onitor the safety and health perform ance of individuals,
particularly m anagers and supervisors, to see w hether they fulfil their
safety and health responsibilities ;
(c) to carry out reactive m onitoring to gauge the effectiveness of risk
control system s through, for exam ple, the m onitoring of accidents/
incid ents, near m isses, ill-health, and other safety and health
perform ance indicators;
(d) to determ ine the im m ediate causes of sub-standard perform ance and
identify the underlying causes and the im plications for the design
and operation of the safety m anagem ent system ;
(e) to rectify any sub-standard situations identified in the m onitoring
processes; and
26
(f) to continuously feed back inform ation collected from the m onitoring
processes to the developing and im plem enting stages to im prove the
safety m anagem ent system in operation.
4.3.2 Auditing or reviewing
Auditing or reviewing is carried out to assess perform ance in addition to
routine m onitoring of occupational safety and health perform ance as
described in Part 4.3.1 above. A uditing or review ing constitutes the
"feedback loop" to the planning stage w hich enables the relevant industrial
undertaking to reinforce, m aintain and develop its ability to reduce risks to
the fullest extent and to ensure the continued efficiency, effectiveness and
reliability of the safety m anag em ent system . In ad d ition, there should
b e inform ation flow ing betw een the developm ent, im plem entation and
m aintenance stages and the auditing/review ing stage so as to ensure the
correct operation of the safety m anagem ent system . A t this auditing or
review ing stag e, the p rop rietor or contractor of a relevant ind ustrial
(a) to appoint a safety auditor or safety review officer to periodically
conduct safety audits or safety review s respectively in accordance
w ith sections 13 or 19 of the Safety M anagem ent R egulation. D etails
are discussed in Part 6.2 or Part 7.2 of this C O P;
(b) to provide facilities, inform ation, etc. to the safety auditor or safety
review officer for purposes of safety audit or safety review respectively
in accordance w ith sections 14 or 20 of the Safety M anagem ent
R egulation. D etails are discussed in Parts 6.3 and 6.4, or Parts 7.3
and 7.4 of this C O P;
(c) to take necessary actions on the safety audit or safety review report
subm itted, including draw ing up a plan for im provem ents to the safety
m anagem ent system and im plem enting the plan in accordance w ith
sections 16 and 22 of the Safety M anagem ent R egulation. D etails are
discussed in Part 6.5 or Part 7.5 of this C O P; and
(d) to continuously feed back inform ation from the safety audit or review
to the planning, developing, organising and im plem enting stages to
im prove the safety m anagem ent system in operation.
4.4 Management model to develop, implement and maintain a safety
management system
The various m anagem ent functions described in Parts 4.1 to 4.3 above to
develop, implement and maintain a safety m anag em ent system can b e
graphically sum m arized by the follow ing m anagem ent m odel:
Planning
Developing
Organizing
Implementing
Measuring
Auditing / reviewing
M

M

M

M
M
M
M
M

M

M

M

M

M

M
M M
M M M
Management model
to develop, implement and maintain a safety management system
F
e
e
d
b
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k
F
e
e
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M

M
Legend
Inform ation link
C ontrol link
28
4.5 Application of the management model to individual elements of a safety
management system
The above m anagem ent m odel should be adopted not only in the development,
implementation and maintenance of a safety m anagem ent system , but also in
the development, implementation and maintenance of each and every
elem ent as sp ecified in S ched ule 4 of the S afety M anag em ent R eg ulation
constituting the system . The proprietor or contractor of a relevant industrial
undertaking should apply the m odel to all elem ents of the safety m anagem ent
system applicable to his undertaking so as to exercise effective m anagem ent of
occupational safety and health in his organisation.
For exam ple, as regards the elem ent "in-house safety rules to provide instruction
for achieving safety m anagem ent objectives", the proprietor or contractor should
first plan and develop the rules, and then organise his staff and resources to
im plem ent the rules. Furtherm ore, he should m onitor com pliance w ith the
in-house safety rules and m easure perform ance according to the set standards.
Last b ut not the least, he should ensure that safety audits or safety review s,
as the case m ay be, are conducted periodically to check the effectiveness,
efficiency and reliability of this particular elem ent. W ith the feedback from
the m easuring , aud iting or review ing stag es, the overall p erform ance of
this particular elem ent can be im proved in the next cycle of its developm ent
and im p lem entation. The p rop rietor or contractor should d ocum ent all
inform ation relating to the im p lem entation and m onitoring of the in-house
rules and reg ulations for m onitoring or review ing p urp oses.
To further illustrate the ap p lication of the m anag em ent m od el, let us look
at another exam ple regarding the elem ent "training to equip personnel w ith
know led g e to w ork safely and w ithout risk to health". The p rop rietor or
contractor should first prepare a safety training policy, setting out the training
objectives. H e should then devise a plan to im plem ent the policy and arrange for
em ployees to receive the necessary training. In addition, he should determ ine
the standards of perform ance regarding the im plem entation of the plan on
safety training. H e should m onitor and review the progress of the plan and the
effectiveness of training provided to the em ployees in accordance w ith the set
standard. H e should also ensure that periodic safety audits or safety review s, as
the case m ay be, are conducted to check the effectiveness, efficiency and
reliability of this particular elem ent. A gain, the results of the m easuring, auditing
or review ing stages w ill provide valuable feedback for im proving the overall
perform ance of this particular elem ent in its next cycle of operation. In order to
facilitate the m onitoring and review of the training plan, the proprietor or contractor
should ensure that all training program m es and the results of the evaluation of
their effectiveness, etc. are adequately and properly docum ented.
4.6 Application of the management model to safety audits or safety reviews
The m anagem ent m odel described in Part 4.4 above should also be used as a
fram ew ork for assessing the overall perform ance of a safety m anagem ent
system by w ay of conducting safety audits or safety review s.
Safety audits or safety review s should assess w hether or not the processes as
described in the m anagem ent m odel have been successfully and effectively
follow ed by the proprietor or contractor to develop, implement and maintain a
safety m anag em ent system , includ ing each of the elem ents sp ecified in
Schedule 4 of the Safety M anagem ent R egulation applicable to the relevant
industrial undertaking. B esides, safety audit or safety review should assess
w hether or not a safety m anagem ent system , including each of the elem ents in
the aforesaid Schedule 4 applicable to the relevant industrial undertaking, has
been developed, implemented and maintained in a w ay that conform s to the
standards set out in Part 5 of this C O P.
In general, the follow ing questions can be answ ered after safety audits or safety
review s:
(a) "H as the proprietor or contractor carried out effectively and efficiently
the p rocesses of planning, developing, organising, implementing
and measuring as described in this C O P in developing, implementing
and maintaining the safety m anagem ent system ?".
(b) "H as the proprietor or contractor developed, implemented and maintained
the safety m anagem ent system in accordance w ith the Safety M anagem ent
R egulation in an adequate and effective m anner by conform ing to the
standards set out in Part 5 of the C O P?".
If the answ ers to the ab ove 2 q uestions are not satisfactory or neg ative,
further im p rovem ents to the safety m anag em ent system in op eration are
necessary.
30
The 14 elem ents of a safety m anag em ent system are as follow s:
5.1 A safety policy w hich states the com m itm ent of the proprietor or contractor
to safety and health at w ork
5.2 A structure to assure im plem entation of the com m itm ent to safety and health
at w ork
5.3 Training to equip personnel w ith know ledge to w ork safely and w ithout risk
to health
5.4 In-house safety rules to provide instruction for achieving safety m anagem ent
objectives
5.5 A program m e of inspection to identify hazardous conditions and for the
rectification of any such conditions at regular intervals or as appropriate
5.6 A program m e to identify hazardous exposure or the risk of such exposure
to the w orkers and to provide suitable personal protective equipm ent as a
last resort w here engineering control m ethods are not feasible
5.7 Investigation of accidents or incidents to find out the cause of any accident
or incident and to develop prom pt arrangem ents to prevent recurrence
5.8 Em ergency preparedness to develop, com m unicate and execute plans
prescribing the effective m anagem ent of em ergency situations
5.9 E valuation, selection and control of sub -contractors to ensure that
sub-contractors are fully aw are of their safety obligations and are in fact
m eeting them
5.10 Safety com m ittees
5.11 Evaluation of job related hazards or potential hazards and developm ent of
safety procedures
5.TH E ELEM EN TS O F A SA FETY
M A N A G EM EN T SYSTEM
5.12 Prom otion, developm ent and m aintenance of safety and health aw areness
in a w orkplace
5.13 A program m e for accident control and elim ination of hazards before
exposing w orkers to any adverse w ork environm ent
5.14 A program m e to protect w orkers from occupational health hazards
Practical guidance in respect of these elem ents is given in the follow ing pages.
5.1 A safety policy which states the commitment of the proprietor or
contractor to safety and health at work
5.1.1 Safety policy
"P olicy", in b road term s, refers to the g eneral intentions, ap p roach
and objectives of an organisation together w ith the criteria and principles
on w hich actions and responses are based.
A n effective safety policy sets a clear direction for the organisation to
follow . It contributes to all aspects of business perform ance as part of a
dem onstrable com m itm ent to continuous im provem ent. The objective of
defining an industrial undertaking's safety policy is to set dow n in clear and
unam biguous term s its m anagem ent's approach and com m itm ent to safety
and health at w ork. The organisation's m ost senior m anagem ent should
define, docum ent and endorse its safety policy. The proprietor or contractor
of a relevant industrial undertaking should ensure that the policy includes a
com m itm ent to:
(a) recognise safety and health at w ork as an integral part of its business
perform ance;
(b) achieve a high level of occupational safety and health perform ance,
in com pliance w ith legal requirem ents as the m inim um ;
(c) provide adequate and appropriate resources to im plem ent the policy;
(d) m ake the m anag em ent of safety and health one of the p rim e
resp onsib ilities of m anag ers at all levels, from the m ost senior
executives dow n to the front line supervisory staff;
The 14 elements of a safety management system - (1) safety policy
32
(e) ensure its understanding, im plem entation and m aintenance at all levels
in the organisation;
(f) consult and involve em ployees so as to secure their com m itm ent to
the policy and its im plem entation;
(g) keep the policy and the m anagem ent system under periodic review
and audit/review com pliance w ith policy; and
(h) ensure that em ployees at all levels have received appropriate training
and are com petent to carry out their duties and responsibilities.
The safety p olicy should b e sp ecific and relevant to the ind ustrial
undertaking's nature of w ork. It should be able to convey (a) the general
intentions, approach and objectives of the industrial undertaking, and (b)
the criteria and principles on w hich its actions and responses are based.
5.1.2 Written policy statement
A p rop rietor or contractor of a relevant ind ustrial und ertaking shall
p rep are and revise as often as m ay b e necessary a w ritten p olicy
sta te m e n t in relation to the safety p olicy of the relevant ind ustrial
und ertaking [Section 9(1)(a) of the Safety M anagem ent R egulation].
The policy statem ent shall include: (a) a statem ent of the proprietor's or
contractor's general policy w ith regard to the safety and health of the w orkers
in the relevant ind ustrial und ertaking ; (b ) a system of allocation of
responsibilities for the carrying out of the policy; and (c) arrangem ents as to
how the responsibilities are to be executed [Section 9(2) of the Safety
M anagem ent R egulation].
It is im portant to realise that the Safety M anagem ent R egulation places the
responsibility for safety and health on the proprietor or contractor of a
relevant ind ustrial und ertaking . M any of the d uties arising from that
responsibility m ay how ever be delegated to m anagers and supervisors.
The w ritten policy statem ent should show clearly how these duties are
allocated. W hilst the overall responsibility for safety and health rests w ith
the top m anagem ent, all individuals at every level w ill have to accept
certain am ount of responsibility for carrying out the policy. W henever
possible, key individuals should be nam ed and their responsibilities defined.
It is equally im portant that em ployees at all levels in the relevant industrial
undertaking should be able to see from the statem ent how they fit into the
system , and, for exam ple, w hat their ow n duties are and to w hom they should
go for advice, to report an accident or a hazard, or to obtain first aid or other
help.
There is no rule about the appropriate length of a w ritten policy statem ent.
A sm aller firm carrying out w ork that is not especially hazardous can have a
shorter policy statem ent than that of a larger firm w ith com plicated and
hazardous processes. H ow ever, one possible approach is to set out its
safety policy in fairly general term s, and to refer the readers to other
docum ents, such as in-house safety rules, safety checklists, safety m anuals,
safety training program m es and em ergency instructions, for full details.
The proprietor or contractor of a relevant industrial undertaking shall bring
such statem ent and any revision of it to the notice of all the w orkers in the
undertaking, keep a copy of the statem ent and m ake it available for
inspection upon request by an occupational safety officer. [Sections 9(1)(b)
to 9(1)(d) of the Safety M anagem ent R egulation]
A n effective safety m anagem ent system should have a self-regulating and
self-im proving m echanism built in. This is effected by review ing the safety
policy from tim e to tim e by w ay of (a) perform ance m easurem ent and (b)
safety audits or safety review s. The proprietor or contractor shall cause the
safety policy of the relevant industrial undertaking to be review ed -
(a) not less than once in each 2 years period com m encing on the date on
w hich the proprietor or contractor first brought the w ritten policy
statem ent and any revision of it to the notice of all the w orkers in the
undertaking, and
(b) as soon as is practicable after the proprietor or contractor alters the
policy statem ent.
[Section 9(3) of the Safety M anagem ent R egulation]
Such alterations include changes to the core elem ents m entioned above
like changes in organisational structure. A review m ay also be prom pted by
changes of particulars due to internal or external factors such as changes
in technology, legislation or standards.
34
5.2 A structure to assure implementation of the commitment to safety and
health at work
A safety organisation provides the structural fram ew ork for people in the
com pany to w ork together in a coordinated m anner, based on their know ledge,
training and responsibilities, to achieve the safety and health objectives set
by the top m anagem ent. W ithin the organisation, responsibilities and relationships
should be established to prom ote a positive safety and health culture and secure
the im plem entation and continuous developm ent of the safety policy. To
p rop erly estab lish such an org anisation, there should b e a p rocess of
prescribing form al relationships am ong people and resources in the com pany
to accom plish the safety and health objectives. W ith the setting up of such an
org anisation, the g eneral safety p olicy tog ether w ith the safety plan can be
effectively and efficiently im plem ented.
5.2.1 Line organisation
In H ong K ong, m any com panies are doing a good job in m anaging their
safety and health. M ost of the success stories revolve around a line
organisation. Such organisation lays dow n direct and vertical relationships
betw een different levels w ithin the com pany and provides an effective and
efficient organisational structure for ensuring the achievem ent of safety and
health objectives. U nder such a structure, form al safety and health
responsibilities are allocated to all levels of personnel including directors,
departm ent/division/section heads, safety personnel, supervisors and
w orkers. The proprietor or contractor should ensure that every person in
the line organisation has an im portant safety and health role and that the
person should be held accountable for safety and health m atters. In this
sense, safety should be a line function for all people in the line organisation
w ith others, such as people from the safety, personnel, finance, m aterials
and engineering departm ents, etc., playing only a supportive role.
The 14 elements of a safety management system - (2) organisational structure
5.2.2 Safety office or safety department
A safety office or safety departm ent or sim ilar set-up should be established
to coordinate the im plem entation of safety plans or program m es by the line
m anagem ent. Its prim ary role is to advise the line m anagem ent on safety
and health practices, requirem ents and standards. It should not play a
"line" role to im plem ent the safety plans and program m es and certainly should
not be held accountable for the consequences of the lack of control on the
shop floor or at the site.
The safety office or safety departm ent should include the follow ing m ain
roles:
(a) To serve as a safety resource centre and in-house safety consultant.
(b) To plan and prepare safety program m es.
(c) To advise top m anagem ent and line m anagem ent on safety and health
m atters.
(d) To coordinate the im plem entation of safety plans and program m es.
(e) To m onitor the im plem entation of safety plans and program m es.
(f) To follow up corrective actions and verify the effectiveness of safety
m easures.
(g) To serve as a safety trainer.
5.2.3 Allocation of responsibilities for safety and health
It is im portant that responsibilities for safety and health should be identified
and allocated properly in a clear and logical w ay. Each m em ber of the
relevant industrial undertaking to w hich the responsibilities are allocated
should know w hat he is responsible for and to w hom he is responsible
regarding safety and health m atters. The allocation of responsibilities should
b e record ed in w riting and it should b e clearly stated that the final
responsibility for safety and health rests w ith the top m anagem ent. The top
m anagem ent m ust accept the responsibility for ensuring that safety and
health is incorporated into the running of the business. A relevant person at
the top m anagem ent level should be designated to take up this final
responsibility and accountability. Lastly, docum ents on allocation of m ajor
responsibilities for safety and health should be signed and dated by the
above person and be review ed and revised periodically to m aintain their
validity and effectiveness.
36
5.2.4 Main safety and health responsibilities of different levels of staff in the
organisation
The m ain safety and health responsibilities of different levels of staff in the
relevant industrial undertaking are set out as follow s:
(1) Senior m anagem ent
- To provide a safe and healthy w orking environm ent.
- To provide adequate resources (including financial resources),
inform ation and training.
- To provide a system of m onitoring com pliance w ith the safety
policy.
- To ensure that relevant safety and health law s are com plied w ith.
- To m aintain contact w ith in-house safety advisors or safety officers,
outsid e safety consultants, g overnm ent d ep artm ents, the
O ccupational Safety and H ealth C ouncil and other professional
bodies regarding safety and health m atters.
- To provide and m aintain a system responding to safety initiatives
from safety advisors/safety officers/ persons in charge of the safety
office, safety supervisors or w orkers, and to the safety advice
from governm ent officers.
("safety supervisor" m eans a person em ployed as a safety
supervisor in an industrial undertaking under the Factories and
Industrial U ndertakings (Safety O fficers and Safety Supervisors)
R egulations (C ap.59, sub. leg.))
- To provide an effective, efficient and on-going safety and health
prom otion program m e.
- To establish a system to identify, assess and elim inate hazards
and control risks at w ork.
- To ensure that w orkplace safety rules, procedures and m ethods
are developed, m aintained and revised.
(2) Line m anagem ent (including m anagers and supervisors)
- To assist the proprietor or contractor in the im plem entation of the
safety policy, m easures and procedures.
- To assist the proprietor or contractor in the identification of
hazards, and the evaluation and control of risks.
- To supervise w orkers to ensure safe and correct w orking procedures.
- To ensure effective consultation on safety and health m atters.
- To investigate w ork accidents and incidents.
- To p articip ate in ind uction and on-g oing safety training
program m es for w orkers.
- To respond to safety initiatives of safety advisors/safety officers/
persons in charge of the safety office, safety supervisors or
w orkers and to the safety advice from governm ent officers.
- To com m unicate effectively the hazards to w orkers and keep
abreast of current safety and health legislation and inform ation.
- To subm it periodically to senior m anagem ent statistics and
reports concerning safety and health perform ance, unless the
task is taken up by the safety office.
38
(3) W orkers
- To conduct w ork activities in com pliance w ith legal requirem ents.
- To closely follow safe w ork practices, procedures, instructions
and rules and to perform all duties in a m anner w hich ensures
the safety and health at w ork of him self and others in the
w orkplace.
- To provide feedback on the effectiveness of safety m easures
im plem ented on the shop floor.
- To contribute ideas on w ays to im prove safety.
- To report hazards to supervisor and w arn colleagues of hazards.
- To report any injury, accident or incident at w ork to supervisor.
- To participate in toolbox m eetings and other safety activities and
to attend safety training.
(4) Safety advisor, safety officer or person in charge of the safety office
A n in-house safety advisor, safety officer or person in charge of the
safety office should have the responsibility to assist the top m anagem ent
and senior m anagem ent in prom oting the safety and health of w orkers
in the relevant industrial undertaking. H is m ain duties should include
the follow ing:
- To assist in the identification of hazards and evaluation of risks at
w ork.
- To advise senior m anagem ent or line m anagem ent as to the
m easures to be taken to elim inate or control hazards.
- To assist in resolving shop floor safety and health issues.
- To cond uct safety and health insp ections to check safety
p erform ance and recom m end corrective action to senior
m anagem ent or line m anagem ent.
- To investig ate occup ational accid ents and incid ents and
recom m end rem edial m easures to prevent recurrence.
- To be w ell inform ed about w orkplace safety perform ance.
- To consult w ith senior m anagem ent, line m anagem ent and
w orkers about changes in the w orkplace w hich w ould likely affect
the safety and health at w ork of w orkers.
- To report safety perform ance regularly to the top and senior
m anagem ent and, w here appropriate, to the safety com m ittee.
(5) Safety supervisor or the assistant to the person in charge of the safety
office
The responsibility of a safety sup ervisor or an assistant to the
person in charge of the safety office should be to assist the top
m anagem ent, senior m anagem ent and the in-house safety advisor,
safety officer or person in charge of the safety office in prom oting
the safety and health of w orkers in the relevant ind ustrial
undertaking. H is m ain duties should include the follow ing:
- To assist the in-house safety advisor, safety officer or person
in charge of the safety office in carrying out his duties.
- To sup ervise w orkers' ob servance of safety stand ard s.
- To advise the senior m anagem ent or line m anagem ent as to
the ob servance b y w orkers of safety stand ard s.
- To p rom ote the safe carrying out of w ork in the w orkp lace.
- To report regularly to the in-house safety advisor, safety officer
or person in charge of the safety office on safety and health
perform ance in the w orkplace.
5.2.5 Safety committee
A proprietor or a contractor specified in Part 1 or Part 3 of Schedule 3 of the
Safety M anagem ent R egulation shall establish not less than one safety
com m ittee in his ind ustrial und ertaking [S ection 10(a) of the S afety
M anagem ent R egulation] as part of the safety organisation. Safety com m ittee
is described in detail in Part 5.10 of this C O P.
40
5.3 Training to equip personnel with knowledge to work safely and without
risk to health
Training helps people acquire the skills, know led g e and attitud es to m ake
them com petent in the safety and health aspects of their w ork. It includes
form al off-the-job training , instruction to ind ivid uals and g roup s, and on-
the-job coaching and counselling . It is help ful to integ rate the safety and
health req uirem ents of each job into the ind ivid ual job sp ecifications.
A proprietor or contractor of a relevant industrial undertaking should devise
and refine or adjust his training policy system atically, as in the self-im proving
cycle show n below :
Decide if training is necessary
Identify training needs
Formulate training objectives and methods
Conduct training programmes
Evaluate the effectiveness of training
M

M

M

M
M
M
M
M
Feedback loop to im prove
training process
The 14 elements of a safety management system - (3) safety training
5.3.1Deciding if training is necessary
Training should not b e a sub stitute for p rop er risk control to, for
exam p le, com p ensate for ineffectively g uard ed m achinery. The key
to effective training is to und erstand job req uirem ents and ind ivid ual
ab ilities.
5.3.2 Identifying training needs
To equip his w orkers w ith know ledge on w ork safety and health, the proprietor
or contractor of a relevant industrial undertaking m ust first identify w hat their
safety and health training needs are. These needs are best established as
part of an overall training needs analysis. For existing jobs, he can do the
follow ing things:
(a) C onsult job-specific accident, ill-health and incident records to see
w hat have caused losses of control and how they can be prevented;
(b) G ather inform ation from w orkers about how the w ork is done;
(c) Find out w hen w orkers are w orking, w hat they are doing and w hy
through observation and asking questions. This m ay be particularly
relevant in the case of com plex process plants w here any analysis has
to take account of all the possible consequences of hum an errors;
and
(d) C onsult w ork risk assessm ent reports.
There are three m ain types of training needs, nam ely, organisational, job-
related and individual training needs.
(1) O rganisational training needs
The proprietor or contractor of a relevant industrial undertaking should
let his w orkers know :
(a) the organisation's safety policy and the philosophy underlying it;
and
(b) the structure and system s for carrying out the policy.
42
M oreover, he should also let them know w hich parts of the system s
are relevant to them , w hat the m ajor risks are and how they are
controlled.
(2) Job-related training needs
These fall into tw o m ain categories, nam ely, m anagem ent needs and
non-m anagem ent needs.
(a) M anagem ent needs include:
(i) leadership skills;
(ii) com m unication skills;
(iii) techniques of safety m anagem ent;
(iv) training, instruction, coaching and problem -solving skills
relevant to safety and health;
(v) understanding of risks from a m anager's perspective;
(vi) know ledge of relevant legislation and appropriate m ethods
of control including risk m anagem ent; and
(vii) know ledge of the organisation's planning, m easuring, and
auditing or review ing arrangem ents.
Som e m anagers in key positions like those w ho devise and
develop the safety m anagem ent system , investigate accidents
or incidents, take part in safety audits or safety review s and
im plem ent em ergency procedures, m ay have particular needs.
(b) N on-m anagem ent needs include:
(i) an overview of safety and health principles;
(ii) detailed know ledge of the safety and health arrangem ents
relevant to an individual's job; and
(iii) com m unication and problem -solving skills to encourage
effective participation in safety and health activities.
(3) Individual training needs
Individual needs are generally identified through perform ance
appraisal. They m ay also arise in situations w here an individual
has not received form al job training or instruction as part of his
ind uction training . Training need s vary over tim e, and
assessm ents should cover:
(a) the induction courses for new starters, including part-tim e,
tem porary and im ported w orkers;
(b) the perform ance of long-term w orkers (especially those w ho
m ay be involved in critical em ergency procedures);
(c) job changes, and situations involving staff prom otion or
som eone standing in for som eone else;
(d) the introduction of new equipm ent or technology; and
(e) the follow -up actions after accident / incident investigations.
5.3.3 Formulation of training objectives and methods
B ased on job analysis and risk assessm ent, a proprietor or contractor
can set objectives and priorities for training. These can be used as the
basis for m easuring the effectiveness of training and for determ ining
w hether the w orkers have attained the desired level of proficiency. The
appropriate training m ethods can be devised according to the objectives.
5.3.4 Conducting training programmes
The proprietor or contractor should determ ine w hen and at w hat level training
should be conducted, having regard to the actual situations. H ow ever, in
no case should w orkers be m ade to shoulder the costs of training.
44
5.3.5 Evaluation of the effectiveness of training
It is necessary to m easure the effectiveness of training. Pre-testing
determ ines the needs for the program m e; post-testing evaluates how m uch
has been learned. It is im portant to assess w hether the training program m e
has effectively corrected the previously identified unsafe behaviour. It is
also of vital im portance to obtain feedback on the training program m e.
5.3.6 Maintenance of training records
M onitoring involves keep ing track of w ho has b een trained in w hat.
A ccurate records should be m aintained for all safety and health training
activities. S uch record s should , as far as reasonab ly p racticab le,
include the follow ing data:
(a) Training date and tim e;
(b) Training location;
(c) Length of training;
(d) Subject of training;
(e) C ontents of training;
(f) Trainers and their expertise;
(g) A ttendees; and
(h) Test results, if any.
5.4 In-house safety rules to provide instruction for achieving safety
management objectives
The ultim ate objective of any safety m anagem ent system is to prevent injury
and ill health in the w orkp lace. To accom p lish this it is necessary for a
proprietor or contractor of a relevant industrial undertaking to devise in-house
safety rules.
In-house safety rules cover general rules, specialised w ork rules, specialised
w ork perm its and procedures.
5.4.1General safety rules
G eneral safety rules include clear instructions to personnel in each of the
follow ing general areas:
(a) safe operation of plant, m achinery and equipm ent;
(b) m aintenance of plant, m achinery and equipm ent;
(c) proper and safe procedures for each production process, in the form
of m ethod statem ents;
(d) rules and instructions on various risk control system s including the
perm it-to-w ork system ;
(e) provision, use and m aintenance of personal protective equipm ent;
(f) rules for the provision, use and m aintenance of safe access and egress
and for traffic and plant m ovem ent;
(g) fire precautionary m easures;
(h) safe handling and m ovem ent of m aterials;
(i) safety procedures for chem ical processes and for the handling,
transporting and storage of chem icals;
(j) safety procedures for em ergency;
(k) duties and procedures for reporting hazards;
(l) duties and procedures for reporting incidents, accidents and ill-health;
and
(m ) good housekeeping of the w orkplace.
The 14 elements of a safety management system - (4) in-house safety rules
46
5.4.2 Specialised safety rules, work permits and procedures
There should be a system for the identification and establishm ent of
specialised in-house safety rules, specialised w ork rules, specialised w ork
perm its and procedures. Proprietors and contractors of relevant industrial
undertakings should refer to the follow ing:
(a) relevant legislation dealing w ith safety and health at w ork, w hich sets
the m inim um standards to follow ;
(b) C odes of practice and guidance m aterials issued by the Labour
D epartm ent on safety and health at w ork;
(c) International standards; and
(d) the best trade practice and trade perform ance.
5.4.3 Consultation and communication
In d evising in-house safety rules, the p rop rietor or contractor of a
re le va n t in d u stria l u n d e rta kin g is e n c o u ra g e d to h a ve p rio r
consultation w ith his w orkers, w here ap p rop riate. If there is a safety
com m ittee, the d etails of the safety rules can b e d iscussed in the
safety com m ittee. W ork rules and procedures should be docum ented
and com m unicated to all ap p rop riate p ersonnel in the relevant
ind ustrial und ertaking .
It m ay be that not all w orkers w ill need to know all of the detailed in-house
rules but the proprietor or contractor of a relevant industrial undertaking
should ensure that every w orker in the undertaking is clearly instructed as
to w hat rules they should follow .
5.4.4 Supervision
To ensure com pliance w ith these in-house rules, the proprietor or contractor
of a relevant industrial undertaking should exercise due diligence in the
supervision of his w orkers. M oreover, there should b e a w ritten
d iscip linary p olicy addressing violation of rules w ith details of punitive
actions like verbal w arnings, w ritten reprim ands, suspensions, dem otions
and, w here necessary, term ination. R ecognition should, on the other hand,
be given to w orkers follow ing the rules to reinforce good behaviour.
The 14 elements of a safety management system - (4) in-house safety rules
5.5 A programme of inspection to identify hazardous conditions and for
the rectification of any such conditions at regular intervals or as
appropriate
5.5.1 Inspection as an active monitoring programme
M easuring the safety and health perform ance of a relevant industrial
undertaking against predeterm ined plans and standards exposes the need
for rem ed ial action. M onitoring activities sig nalise m anag em ent
com m itm ent to safety and health objectives in general. They are an
essential part of developing a positive safety and health culture. There are
tw o types of m onitoring system s:
(a) active system s w hich m onitor the achievem ent of objectives and the
extent of com pliance w ith pre-set standards.
(b) reactive system s w hich m onitor accidents, ill health, incidents and other
evidence of deficient safety and health perform ance.
Inspection is an active m onitoring program m e.
5.5.2 Goals of inspection
A program m e for the inspection of hazardous conditions is an essential
p art of any active m onitoring p rog ram m e. It is one of the b est tools
available to identify problem s and assess their risks before accidents
and other losses occur. A p rop rietor or contractor should d evelop ,
im p lem ent and reg ularly review the insp ection p rog ram m e so as to
achieve the follow ing g oals:
(a) to identify potential problem s that are not anticipated during the
design or planning stage;
(b) to identify equipm ent deficiencies, such as problem s caused by
norm al w ear and tear and abuse or m isuse of equipm ent;
(c) to identify im proper w orker actions, m alpractices, etc.;
(d) to identify changes in processes or m aterials w hich m ay have adverse
effect on the safety and health of w orkers;
(e) to identify inadequacies in rem edial actions;
The 14 elements of a safety management system - (5) inspection programme
48
(f) to provide m anagem ent w ith inform ation to assess the organisation's
ow n safety and health perform ance; and
(g) to dem onstrate m anagem ent com m itm ent.
5.5.3 The programme of inspection
A system for inspecting w orkplace precautions is im portant in any active
m onitoring program m e. It can form part of the arrangem ents for the
p reventive m aintenance of p lant and eq uip m ent w hich m ay also b e
covered by legal requirem ents. Equipm ent in this category includes lifts,
cranes, chains, ropes, lifting tackles, pow er presses, electrical tools and
equipm ent, scaffolds, trench supports, suspended w orking platform s and
local exhaust ventilation, etc. B ut insp ections should includ e other
w orkplace precautions, such as those covering the use of prem ises, other
places of w ork and system s of w ork.
A suitable inspection program m e should take all risks into account. It should
be proportional to the hazard profile of the relevant industrial undertaking.
A n inspection should concentrate on areas w here it is likely to produce the
greatest benefit and lead to the greatest control of risk. K ey risk control
system s and related w orkplace precautions should therefore be m onitored
in g reater d etail or m ore often (or b oth) than low -risk system s or
m anagem ent arrangem ents. For exam ple, low risks m ay be dealt w ith by
g eneral insp ections every m onth or tw o covering a w id e rang e of
w orkplace precautions such as the condition of prem ises, floors, passages,
stairs, lighting, w elfare facilities and first aid. H igher risks need m ore
frequent and detailed inspections, perhaps w eekly or even, in extrem e cases,
daily or before use (for exam ple, pre-use check on plant and m achinery).
The inspection program m e should satisfy any specific legal requirem ents
and reflect the undertaking's risk priorities. Suitable schedules and
perform ance standards for the frequency and contents of inspection can
help. The schedules can be supplem ented w ith inspection form s or
checklists, both to ensure consistency in approach and to provide records
for follow -up action. The persons carrying out the inspections should have
the appropriate safety training and experience so that they are com petent
to identify the relevant hazards and evaluate the associated risks.
A properly thought-out approach to inspection w ill include:
(a) a w ell-designed inspection form to help plan and initiate rem edial
action by requiring those doing the inspection to rank any deficiencies
in order of im portance;
(b) sum m ary lists of rem edial action w ith nam es and deadlines to track
progress on im plem enting im provem ents;
(c) periodic analysis of inspection form s to identify com m on features or
trends w hich m ight reveal underlying w eaknesses in the system ; and
(d) inform ation to aid judgm ents about any changes required in the
frequency or nature of the inspection program m e.
5.5.4 Reporting and review
A p rop rietor or contractor of a relevant ind ustrial und ertaking should
keep full record s of each insp ection w ith d etails of b oth p ositive and
neg ative find ing s. S uch rep orts should b e analysed to id entify
repeated substandard situations and their underlying causes. R ecords
of insp ections should b e kep t for a p eriod of not less than 3 years.
The results of insp ections should b e b roug ht to the attention of the
industrial undertaking's senior m anagem ent. Inform ation from safety
inspections should be evaluated prom ptly to identify im m ediate risks
and to ensure that appropriate rem edial action is taken w ithout delay.
A n y c o rre c tive a c tio n sh o u ld b e im p le m e n te d a s q u ic kly a s
reasonably practicable. The inspection system should have a w ay of
checking that rem ed ial action is taken and m onitored b y the senior
m anag em ent.
A n effective inspection program m e should have a quality check built
in to ensure that the line m anag em ent is carrying out the m onitoring
function p rop erly. A g ood rep orting system w ith sup ervisory checks,
for exam ple, w ill be able to serve the purpose. The safety inspection
program m e should be regularly review ed to identify deficiencies and
p ossib le areas for im p rovem ent.
50
5.6 A programme to identify hazardous exposure or the risk of such
exposure to the workers and to provide suitable personal protective
equipment as a last resort where engineering control methods are not
feasible
5.6.1 Identification of hazardous exposure or the risk of such exposure to
the workers
This elem ent of the safety m anagem ent system is a pro-active one w hich
seeks to prom ote continuous im provem ent of the w orking environm ent
and ensure that hazards are identified tim ely so that risks can be assessed
and controlled before anyone (or anything) is adversely affected.
In ord er to id entify hazard s and assess their associated risks, the
proprietor or contractor of a relevant industrial undertaking should in the
first place prepare a list of item s covering prem ises, plant, people and
procedures, and gather inform ation about them . The inform ation required
should include:
(a) tasks being carried out, their duration and frequency;
(b) location(s) w here the w ork is carried out;
(c) w ho norm ally/occasionally carries out the tasks;
(d) w ho m ay be affected by the w ork (e.g. visitors, contractors, and the
public);
(e) training that personnel have received about the tasks;
(f) w ritten system s of w ork and/or perm it-to-w ork procedures prepared
for the tasks;
(g) plant and m achinery that m ay be used;
(h) pow ered hand tools that m ay be used;
(i) m anufacturers' or sup p liers' instructions for the op eration and
m aintenance of plant, m achinery and pow ered hand tools;
(j) size, shape, surface character and w eight of m aterials that m ay be
handled;
(k) distances and heights to w hich m aterials have to be m oved by hand;
The 14 elements of a safety management system - (6) hazard control programme
(l) services used (e.g. com pressed air, pow er supply);
(m ) substances used or encountered during w ork;
(n) physical form of substances used or encountered (fum e, gas, vapour,
liquid, dust/pow der, solid);
(o) contents and recom m endations of hazard data sheets relating to
substances used or encountered;
(p) legal requirem ents and standards relevant to the w ork, the plant and
m achinery used, and the substances used or encountered;
(q) control m easures in place;
(r) reactive m onitoring data (incidents, accidents and ill-health records
associated w ith the w ork and the equipm ent and substances used)
from w ithin and outside the organisation; and
(s) findings of any existing assessm ents relating to the w ork activity.
D etails of risk assessm ent, evaluation and d evelop m ent of safety
procedures and risk control m easures are described in Part 5.11.
5.6.2 Provision of suitable personal protective equipment as a last resort where
engineering control methods are not feasible
A fter the identification of the hazardous exposure or the risk of such
exposure to the w orkers of a relevant industrial undertaking, the proprietor
or contractor should find out w hether planned or existing safety precautions
(if any) are sufficient to keep the risk und er control and m eet leg al
requirem ents. If the findings are negative, he should take steps to control
the risks so that they are reduced to the low est level that is reasonably
practicable, using engineering m ethods (like adopting a safer production
process, enclosure of a noisy m achine, rem oval of the hazardous substances
at source, etc.).
If
(a) after the aforesaid engineering m easures have been taken, the
hazardous exposure or the risk of such exposure to the w orkers in the
relevant industrial undertaking is still intolerable, or
52
(b) there are no feasible engineering m ethods to control the risk,
the proprietor or contractor of the relevant industrial undertaking should
carry out a program m e to protect the w orkers in question by m eans of
suitable personal protective equipm ent.
Personal protective equipm ent (PPE) includes the follow ing:
G loves, safety footw ear, safety helm ets, high visibility w aistcoats,
aprons, protective clothing for adverse w eather conditions, eye
protectors, hearing protectors, life-jackets, respirators, breathing
apparatus including those used underw ater, and safety harness.
In the hierarchy of control m easures, PPE should alw ays be regarded as the
"last resort". Engineering controls and safe system s of w ork should alw ays
be considered first. It m ay be possible to do the job safely by another
m ethod w hich w ill not require the use of PPE. If that is not possible, it m ay
still be feasible to adopt other m ore effective safeguards. For exam ple, fixed
screens rather than safety goggles can be provided to protect w orkers'
eyes against sw arf throw n off a lathe. H ow ever in som e circum stances PPE
w ill still be needed to control the risk adequately.
There are a num ber of reasons for this approach. First, PPE protects only
the person w earing it, w hereas m easures controlling the risk at source can
protect everyone in the w orkplace. Second, PPE's theoretical m axim um
levels of protection are seldom achieved in practice, and the actual level of
protection is difficult to assess. Effective protection is only achieved w hen
the PPE chosen is of the suitable type, correctly fitted and m aintained, and
properly used. Third, PPE m ay restrict the w earer's m obility or visibility to
som e extent. O ther m eans of p rotection should therefore b e used
w henever reasonably practicable.
N evertheless, proprietors or contractors should provide w orkers w ith
appropriate PPE and training in its usage w herever there is a risk to safety
and health that cannot be adequately controlled by other m eans.
The program m e to provide PPE should include, but is not necessarily
lim ited to, the follow ing:
(1) C onducting PPE risk assessm ent
If it is necessary to provide PPE, a proprietor or contractor should
conduct an assessm ent. The purpose of the assessm ent is to ensure
that the correct PPE is chosen for the particular risk. Except in the
sim plest and m ost obvious cases w hich can be repeated and explained
at any tim e, the assessm ent should be recorded and kept readily
accessible by those w ho need to know the results. R isk assessm ent is
described in detail in Part 5.11.
(2) Proper selection of PPE
determ ine w hat type of PPE is required, taking into consideration the
legal requirem ents for specific situations, the intended use of the PPE,
the m anufacturer's product standards, the design of the PPE (in line
w ith the principle of ergonom ics?), acceptability of PPE to its w earer
and user, and, if used in conjunction w ith other PPE, the question of
com patibility, etc. C ertain respiratory protective equipm ent m ay
im pose significant physiological burdens to the users. The proprietor
or contractor should ensure that the users are m edically fit for using
the PPE.
(3) Steps to ensure adequate supply of PPE, including replacem ent supply,
and spare parts.
(4) Steps to ensure the proper use, m aintenance and storage of PPE.
(5) Steps (including supervision) to ensure that w orkers m ake proper use
of PPE.
(6) A dequate training, inform ation and instruction to ensure that w orkers
m ake safe and proper use of PPE and can m aintain it properly.
M aintenance should include, w here appropriate, cleaning, disinfection,
exam ination, replacem ent, repair and testing. The responsibility for
carrying out m aintenance should be clearly laid dow n, together w ith
the details of the procedures to be follow ed and their frequency. W here
appropriate, records of tests and exam inations should also be kept.
Training, inform ation and instruction should include:
(a) an explanation of the risks present and w hy PPE is needed;
(b) the operation, perform ance and lim itations of the PPE;
(c) instructions on the selection, use and storage of PPE;
54
(d) factors affecting the protection provided by the PPE;
(e) recognising defects in the PPE and arrangem ents for reporting
loss or defects; and
(f) hand-on practice in putting on, w earing, rem oving, inspection,
testing and m aintenance of PPE.
(7) M onitoring the use of PPE.
This includes the steps to m onitor the effectiveness of the PPE during
use by observing the actual protection provided by the PPE. The
re su lts o f m o n ito rin g w o u ld b e ve ry u se fu l in p ro vid in g
inform ation for review ing the selection of the P P E .
5.7 Investigation of accidents or incidents to find out the cause of any
accident or incident and to develop prompt arrangements to prevent
recurrence
The investigation of accidents or incidents form s part of a reactive m onitoring
system w hich is triggered after an event and includes identifying and reporting:
(a) injuries and cases of ill health;
(b) other losses, such as dam age to property;
(c) incidents, including those w ith the potential to cause injury, ill health or loss;
(d) hazards; and
(e) w eaknesses or om issions in perform ance standards.
Each of the above provides opportunities for a relevant industrial undertaking
to check safety perform ance, learn from m istakes, and im prove the safety
m anagem ent system and risk control. Inform ation gathered from investigations
is useful in reinforcing key safety and health m essages.
There is value in investigating both actual and potential losses to learn how to
prevent m ore serious events. A ccurate reporting can be prom oted by:
(a) providing training w hich clarifies the underlying objectives and reasons for
identifying such events;
(b) creating a culture w hich em phasises an observant and responsible approach
and the im portance of having system s of control in place before harm occurs;
The 14 elements of a safety management system - (7) accident / incident investigation
(c) providing open, honest com m unication in a just environm ent, rather than a
tendency m erely to allocate "blam e"; and
(d) cross-referencing and checking first-aid treatm ents, health records,
m aintenance or fire reports and insurance claim s to identify any otherw ise
unreported events.
5.7.1Level and nature of investigation
N ot all events need to be investigated to the sam e extent or depth. The
proprietor or contractor needs to assess each event (for instance, using a
sim ple risk-based approach) to identify w here the m ost benefit can be
obtained. The greatest effort should be focused on significant events w here
there have been serious injuries, ill health or losses as w ell as those w hich
have the potential to cause w idespread or serious injuries or losses.
Investigations should:
(a) identify reasons for any substandard perform ance;
(b) identify underlying failures in the safety m anagem ent system ;
(c) learn from events;
(d) prevent recurrences; and
(e) satisfy legal and reporting requirem ents.
Investig ations should b e led b y som eone w ith the status and
know ledge to m ake authoritative recom m endations. U sually, this w ill
be a line m anager or a safety officer. H ow ever, if events have serious
or p otentially serious conseq uences, a safety and health consultant/
ad visor, a m ed ical or nursing ad visor, technical staff or eq uip m ent
suppliers m ay be called in to provide assistance, and senior m anagers
should be involved from the very beginning. A dequate training in relevant
techniques should also be provided.
A good investigation should be prom pt and thorough to enable rem edial
actions to be taken as soon as practicable after the event.
A n investigation consists of 4 ingredients:
(a) C ollecting evidence about w hat has happened;
(b) A ssem bling and considering the evidence;
56
(c) C om paring the findings w ith the appropriate legal, industry and
com p any stand ard s, d raw ing conclusions on the causes and
recom m ending m easures to prevent recurrence; and
(d) Im plem enting the recom m endations and tracking progress.
Standard report form s can usefully guide people through the investigation
p rocesses outlined ab ove and help the m anag ers resp onsib le for
authorising necessary follow -up actions to set priorities. The recording
system should enable:
(a) inform ation to be collected accurately and presented in a consistent
form ;
(b) com m on causes, features and trends, w hich m ay not be apparent from
the investigation of an individual event, to be analysed and identified;
(c) useful inform ation to be retained for future reference, including
inform ation on the tim e taken to carry out the investigation and the
related costs; and
(d) others to learn from a single event or a series of events.
5.7.2 Key data to be covered in accident, ill health and incident reports
(a) D etails of the injured person, including age, sex, experience, training,
etc.;
(b) A description of the circum stances, including the place, tim e, and
conditions at the scene;
(c) The direct causes of injuries, ill health or other losses;
(d) The underlying causes like failures in w orkplace precautions, safety
procedures, risk control system s or m anagem ent arrangem ents; and
(e) D etails of the outcom e, including in particular:
(i) the nature of the outcom e exam ples are injuries, ill health,
dam age to property, process disruptions and creation of hazards;
(ii) the severity of the harm caused, including the seriousness of
injuries, ill health and losses;
(iii) the im m ediate m anagem ent response to the situation and its
effectiveness. This involves the consideration of the follow ing
questions:
- H as the situation been dealt w ith prom ptly?
- H ave the continuing risks been dealt w ith prom ptly and
adequately?
- H as the first-aid response been adequate?
- H ave em ergency procedures been follow ed properly?
(iv) R ecom m endations to prevent the recurrence of the accident or
incident.
5.7.3 Following-up of the progress of the implementation of recommendations
to prevent recurrence
ensure that there is a m echanism for im plem enting, w ith priorities, the
aforesaid recom m end ations to p revent recurrence of accid ents/
incid ents.
5.7.4 Statistical analysis
It is essential that a proprietor or contractor of a relevant industrial undertaking
should perform statistical analysis based on the inform ation collected from
the investigation of accidents and incidents. The analysis w ill enable the
m anagem ent to identify com m on causes, features and trends w hich m ay
not be apparent from the investigation of an individual event. This in turn
provides valuable inform ation for the m anagem ent to review the safety plan
and form ulate corresponding action program m es.
A safety officer or line m anager w ill be able to assist the proprietor or
contractor in statistical analysis. H ow ever, in highly specialised areas
involving, for exam ple, com plicated health issues, the proprietor or contractor
m ay seek advice from professionals, like occupational health experts, on
the setting up of a data base, and on the analysis and interpretation of the
inform ation.
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5.8 Emergency preparedness to develop, communicate and execute plans
prescribing the effective management of emergency situations
Em ergency preparedness is vital because, w hen an em ergency does occur,
q uick and correct resp onse is necessary to red uce injuries, illnesses,
p rop erty d am ag e, environm ental harm and p ub lic concern. M anag em ent
should id entify the typ es of em erg encies the org anisation need s to p lan
and p rep are for.
5.8.1 Emergency planning
A n em ergency planning com m ittee or a sim ilar set-up (for exam ple, a
sub-com m ittee of a safety com m ittee) should be form ed to identify all
possible em ergencies, evaluate their effects and im pact, and prioritise
and review the list of possible em ergencies. To get a com plete picture
and to consid er all p ossib le scenarios, the com m ittee should , as far
a s re a so n a b ly p ra c tic a b le , in c lu d e re p re se n ta tive s fro m a ll
d ep artm ents/sections in the relevant ind ustrial und ertaking . A list of
p otential em erg ency situations such as fire, electric shock, flood ,
exp losion, hazard ous chem ical sp ills or releases, internal/external
leaks of exp losive or flam m ab le g as, p ersonal injuries and illnesses,
natural disasters, electrical outage, tow n gas supply interruption and
critical d am ag e to facility/eq uip m ent, etc. should b e d raw n up , w ith
p riority p rop erly accord ed .
5.8.2 Emergency response plan
A w orking com m ittee or sim ilar set-up should b e form ed to w ork out
the details of an em erg ency resp onse p lan for each of the p ossib le
em ergencies on the list. The m em bers of the w orking com m ittee should
com e from the departm ents/sections likely to be involved in the possible
em ergency situations. The em ergency response plan, covering w hat can
and should b e d one, w hat equipm ent is necessary and w hat p eop le
are needed , should b e d evelop ed for each em erg ency situation. It
should be com m unicated to all w orkers and be m ade readily accessible
to m anagers and supervisors. In addition, a notice outlining the plan should
be posted up w here it can be seen by all people. The em ergency plan
should, w here appropriate, include the follow ing:
The 14 elements of a safety management system - (8) emergency preparedness
(a) an alarm system ;
(b) the procedures for reporting and declaring em ergencies and, w hen
they are over, announcing a return to norm al;
(c) a control centre its location and resources (such as radio equipm ent,
records, engineering draw ings, a list of supporting personnel, etc.);
(d) an em ergency organisation duties and responsibilities of em ergency
p ersonnel;
(e) procedures to be follow ed by em ployees w ho m ust rem ain to perform
critical operations before they evacuate;
(f) special team s for first aid, salvage, rescue, fire fighting and other
operations, if necessary, and their d uties;
(g) training of team m em bers, w orkers and staff;
(h) facilities and equipm ent to m eet the needs of em ergencies (such
as com m unication eq uip m ent for use d uring em erg encies, fire
hoses, fire extinguishers, spill containm ent m aterials, breathing
apparatus, m asks and special suits, first aid boxes, and em ergency
pow er supply to the m ain sw itchboard, sensors, alarm system s, and
exit signs/lights.);
(i) an evacuation route m ap and a safe assem b ly p oint;
(j) a sched ule for em erg ency d rills to test read iness; and
(k) a list of the authorities to contact in case of em erg ency.
A fter an em ergency response plan has been put together, it should be
kept in an em ergency m anual. The m anual should include all inform ation
necessary to respond to various em ergencies. It should contain floor
plans and layout plans show ing em ergency exits, fire-fighting equipm ent,
diagram s of vital chem ical system s and, as far as practicable, the utility
lines. U tility system s and sp ecial (if any)/reg ular fire exting uishing
system s should be clearly m arked in the plans. In addition, telephone
num bers of key com pany personnel, police and fire services, and a list
of outside bodies qualified to assist w ith special problem s should be
kept in the m anual for easy reference. The m anual should be kept in a
secure area w hich is easily accessible to em ergency personnel.
The 14 elements of a safety management system - (8) emergency preparedness
60
5.9 Evaluation, selection and control of sub-contractors to ensure that sub-
contractors are fully aware of their safety obligations and are in fact
meeting them
5.9.1 Evaluation and selection strategy
The evaluation and selection strategy should clearly aim at ensuring that
only sub-contractors w ith high safety standards are selected for the w ork.
A practicable approach to evaluate and select suitable sub-contractors is
set out below :
(1) P re-q ualification
(a) Each sub-contractor w ishing to qualify as a bidder should be
asked to provide a safety policy w hich should be vetted to
assess its adequacy.
(b) The sub-contractor should also be required to subm it details of
his -
- safety organisation;
- safety track records;
- w orking experience w ith clients dem anding high safety
standards;
- safe system s of w ork/safety program m es in place;
- current safety m anagem ent system ; and
- training program m es and standards.
These should also be vetted to assess adequacy.
(c) O nly w hen a sub-contractor passes the adequacy test m entioned
in (a) and (b) above should he becom e a qualified bidder.
(2) Identification of suitable sub-contractors
(a) W here reasonably practicable, all qualified bidders should be
invited in w riting to attend a pre-bid briefing and their attendance
should be recorded.
The 14 elements of a safety management system - (9) evaluation, selection and control of sub-contractors
(b) S afety req uirem ents, stand ard s and sp ecifications, the
conseq uences of non-com p liance and the relevant safety
provisions in the contract, as w ell as local safety law s that apply,
should be clearly com m unicated to bidders in w riting during the
pre-bid briefing.
(c) B idders should identify all the safety and health requirem ents in
the specifications. To help them do this, a checklist of all the
com m on safety and health problem s w hich m ay arise from the
w ork should be presented to them for reference before the bid is
m ade. W here necessary and appropriate, an additional 'on site'
briefing can be arranged for bidders w ho w ant to have a better
understanding of the safety and health problem s. Som e topics
that should be included in the checklist are:
- A ccess to and egress from the places of w ork;
- W orking at heights;
- Lifting appliances operation;
- Fire prevention;
- Electrical requirem ents;
- U nderground and overhead services;
- Lighting requirem ents;
- M anual handling operation;
- Special hazards such as those inherent in w orking in
confined spaces or w orking w ith asbestos, etc.;
- O ccupational health risks from noise and toxic fum es, etc.;
- Storage of flam m able substances and chem icals;
- Personal protective equipm ent;
- Em ergency rescue/first-aid;
- W elfare am enities such as toilets and drinking w ater facilities;
and
- W orker training requirem ents.
62
(d) The bids subm itted by the potential sub-contractors should be
checked against the potential safety and health problem s to
ensure that all the safety and health hazards that m ay arise during
the w ork have been clearly identified by them and that proper
provisions w ill be m ade for the control of the risks assessed. Each
potential sub-contractor should also be required to subm it an
outline safety plan for the im plem entation of the risk control
m easures. This plan should set out in sum m ary form the sub-
contractor's proposed m eans of com plying w ith his obligations
in relation to safety and health at w ork. Sufficient tim e should be
allow ed for sub-contractors to prepare the bids.
(e) The contractor should select the sub-contractor w ho is able to
identify all the safety and health hazards inherent in the w ork,
can ensure that the m ost proper and adequate provisions w ill be
m ade for the control of the risks, and has the best outline safety
plan.
5.9.2 Control Strategy
The control strategy should aim at m onitoring the safety perform ance of
sub -contractors and keep ing them on the rig ht track to achieve the
p rop rietor's or contractor's safety and health ob jectives in the
execution of the contract. A practicable control approach should include
the follow ing:
(1) Special term s and conditions in the contract
A ll safety rules and provisions should be laid dow n in detail in the
contract for the sub-contractor to follow and im plem ent. O ne of the
p rovisions should b e that the sub -contractor ab id es b y all the
provisions of the proprietor's or contractor's safety policy, including
com pliance w ith w orkplace safety rules. In case the sub-contractor
further sub-contracts all or part of his w ork to other sub-sub-contractors,
the sub-contractor should ensure that the sub-sub-contractors are fully
aw are of the safety policy and the safety rules. The follow ing special
conditions should therefore be attached to the contract for the sub-
contractor to follow :
- to inform any sub-sub-contractor of all safety requirem ents;
- to include observance of all safety requirem ents as a condition
in any future sub-contract; and
- to require the sub-sub-contractor to do sim ilarly if he in turn
sub -contracts his w ork.
A nother provision in the contract should require the sub-contractor to
subm it a detailed and com prehensive safety plan based on the outline
safety plan, setting out how he and the sub-sub-contractors (if any)
w ill im plem ent the safety m easures for controlling the risks during w ork
in com pliance w ith all the safety and health provisions stipulated in the
contract. The sub-contractor should adhere to the safety plan in
carrying out his obligations under the contract and should ensure that
his ow n sub-sub-contractors (if any) receive copies of the safety plan
and com ply w ith its requirem ents as w ell.
In ad d ition, a sub contractor's p articip ation in on-site safety
com m ittees should also be one of the contract conditions.
(2) R isk assessm ent by the sub-contractor before the com m encem ent of
w ork
The sub-contractor should be requested to conduct a risk assessm ent
before w ork com m ences and recom m end the necessary safety
procedures and risk control m easures. The system should spell out
how the sub-contractor should organise and perform his w ork to reduce
risks to w orkers' safety and health.
The sub-contractor should be required to subm it the risk assessm ent
report, together w ith the recom m ended safe system of w ork, to the
proprietor or contractor for scrutiny and endorsem ent.
(3) C ontrol of sub-contractors
The proprietor or contractor should adopt the follow ing m easures to
control the safety perform ance of a sub-contractor:
- The sub-contractor should be required to appoint a person or a
team to co-ordinate all aspects of the contract, including safety
and health m atters on site. In addition, the sub-contractor should
develop com m unication paths to pass on all relevant safety
inform ation to those at the shop floor level.
64
- The sub-contractor should be required to attend a m eeting to
discuss the safety aspects of the w ork prior to the com m encem ent
of the contract.
- The sub-contractor should be required to attend regular progress
m eetings w ith all other parties, at w hich safety and health should
be on the agenda.
- The proprietor or contractor should inspect his sub-contractor's
activities at reg ular intervals. The freq uency of insp ection
should be com m ensurate w ith the hazards and com plexity of
the construction p roject. G enerally, insp ection at w eekly
intervals is desirable.
- The sub -contractor should b e req uired to p rovid e w ritten
m e th o d statem ents b efore c a rryin g o u t a n y w o rk w ith
sp ecial hazard s like dem olition w ork, confined space w ork,
asb estos w ork, w ork on energ ised electrical installations,
falsew ork erection w ork, steel erection w ork and any other w ork
involving disruptions or alterations to m ain services or other
facilities. In the event that there is a need to deviate from the
m ethod statem ent, further progress of w ork should be w ithheld
until a revised m ethod statem ent has b een d raw n up and
endorsed.
- The sub-contractor should be required to report all lost-tim e
accidents and dangerous occurrences, including those of
sub-sub-contractors.
- The sub-contractor's safety and health training program m e
should be regularly m onitored to ensure effectiveness.
5.10Safety committees
5.10.1 Setting up of safety committee
A proprietor or contractor specified in Part 1 or 3 of Schedule 3 of the
Safety M anagem ent R egulation shall establish not less than one safety
com m ittee having the function of identifying, recom m ending and keeping
under review m easures to im prove the safety and health of the w orkers
in the relevant ind ustrial und ertaking . [S ection 10(a) of the S afety
In general, it should be unnecessary for a proprietor or contractor of a
relevant industrial undertaking to have tw o or m ore com m ittees for the sam e
w orkplace to represent, e.g., different levels of staff. Safety com m ittees are
m ost likely to prove effective w hen their w ork is related to a single
establishm ent rather than a collection of w orkplaces at different locations.
Therefore, if the proprietor or contractor is running a business consisting
of tw o or m ore establishm ents in separate places, he should have tw o
or m ore safety com m ittees. Exam ples are:
(a) A large factory w ith branches in different districts.
(b) A construction com pany operating construction sites at different
locations.
In these cases, there should be a safety com m ittee per location at the
w orkplace level, as w ell as a central safety com m ittee at the enterprise
level.
5.10.2 Functions of safety committees
A safety com m ittee should carry out the follow ing functions for the purposes
of identifying, recom m ending and keeping under review m easures to
im prove the safety and health of w orkers in a relevant industrial undertaking:
(a) m onitoring of the safety policy determ ining w hether it is adequate
and how w ell it is being im plem ented;
(b) on-going evaluation of hazards and arrangem ents to im plem ent safety
m easures;
The 14 elements of a safety management system - (10) safety committees
66
(c) establishm ent of arrang em ents to d eal p rom p tly and effectively
w ith dangerous w orking conditions, including those com ing to light in
disputes arising from w orkers refusing to w ork on the grounds of
im m inent danger;
(d) discussion and establishm ent of a m echanism to resolve disputes w hen
w orkers refuse w ork on the grounds of im m inent danger;
(e) assistance in the d evelop m ent of safe w orking p roced ures and
safe system s of w ork;
(f) vetting of accident/incident/ill-health statistics to identify trends and
m onitor safety perform ance, and subm ission of reports on its findings
to the top m anagem ent w ith recom m endations;
(g) exam ination of safety aud it rep orts and sub m ission of rep orts on
its ob servations to the top m anagem ent w ith recom m endations;
(h) scrutiny of safety perform ance reports subm itted by the safety office
and giving of direction on appropriate actions;
(i) m onitoring of the adequacy and effectiveness of safety training;
(j) m onitoring of the ad eq uacy of safety and health com m unications
and publicity in the w orkplace;
(k) organisation of safety prom otion activities such as safety com petitions,
exhibitions, safety incentive schem es, and safety suggestion schem es;
and
(l) provision of links w ith external sources regarding safety and health.
The safety com m ittee should organise regular site visits for its m em bers to
enable them to experience the actual situations on the ground so that they
can ad d a p ractical touch to their w orking strateg ies. Their reg ular
presence on site also serves good public relations and prom otional purposes.
5.10.3 Duty to implement measures recommended
The proprietor or contractor shall im plem ent, so far as is reasonably
practicable, any m easures recom m ended by the safety com m ittee in
relation to m atters of safety and health at w ork of the w orkers in the
undertaking [Section 10(b) of the Safety M anagem ent R egulation]. A
m echanism should b e estab lished w hereb y d ecisions and actions
recom m ended by the safety com m ittee can be effectively com m unicated
to those persons responsible for their im plem entation. W here necessary,
m onitoring arrangem ent should be set up by the safety com m ittee to follow
through the im plem entation of its recom m endations.
5.10.4 Composition of safety committee
A safety com m ittee should have a w ide representation adequately covering
the interests of m anagem ent and all w orkers, yet its size should be kept as
reasonably com pact as possible. The num ber of m em bers representing
w orkers in the relevant industrial undertaking shall not be less than half the
m em bers of the com m ittee [Section 11(1)(a) of the Safety M anagem ent
R egulation]. M em bers of the safety com m ittee can be nom inated or elected.
M anagem ent m em bership should com e from as m any levels as practicable,
w ith senior m anagem ent w ell represented and a careful m ix of line
m anagem ent and functional m anagem ent. The aim is to ensure that the
com m ittee -
(a) is given adequate authority to consider view s and recom m endations,
and m ake decisions; and
(b) is provided w ith the necessary expertise to form ulate practicable
policies and strategies.
Supervisors are the key m en in regard to safety as w ell as production and
their active cooperation is therefore essential. It is m ost im portant that the
supervisors should be kept continuously inform ed of the safety com m ittee's
w ork. They should therefore have a representative on the safety com m ittee.
68
In undertakings w here com pany doctors, industrial hygienists or safety
officers or advisers are em ployed, they should be m ade ex-officio m em bers
of the safety com m ittee. O ther specialists, such as project engineers,
chem ists, organisation and m ethods personnel and training officers m ay
also be asked to attend m eetings on an ad hoc basis w hen issues on w hich
they have expertise are to be discussed.
The p rop rietor or contractor req uired b y section 10 of the S afety
M anagem ent R egulation to establish a safety com m ittee shall ensure that
the safety com m ittee is provided w ith a w ritten statem ent setting out the
rules governing its m em bership.
[Section 11(1)(b) of the Safety M anagem ent R egulation]
The roles of tw o of the key m em bers, nam ely the chair and the safety advisor,
in a safety com m ittee are as follow s:
Chair
The success of a safety com m ittee depends on the com m itm ent and
support given to it by the top m anagem ent. This is best expressed by the
appointm ent of a senior m anager as the chair. For a safety com m ittee at
the enterp rise level, the chairm an should b e ap p ointed b y the top
m anagem ent and given the authority to m ake decisions. H e should report
regularly to the top m anagem ent and keep safety and health on the agenda.
For a safety com m ittee at the w orkplace level, the chairm an should be the
top person in charge of the w orkplace (for exam ple, the project m anager in
the case of a construction site).
Safety adviser/Safety Officer/Person in charge of the safety office
H is participation is extrem ely valuable by virtue of his expertise. A s his job
dem ands im partiality, his advice should be available equally to m em bers
representing m anagem ent and w orkers on the com m ittee.
Size
R egarding the size of the safety com m ittee, a balance should be struck
betw een a w ide representation and a reasonable size. A safety com m ittee
should not be too large. It should norm ally have no m ore than 15 m em bers.
5.10.5 Proceedings of meetings, etc.
A proprietor or contractor required by section 10 of the Safety M anagem ent
R egulation to establish a safety com m ittee shall ensure that the safety
com m ittee is also provided w ith a w ritten statem ent setting out rules
governing its term s of reference and m eeting procedures [Section 11(1)(b)
of the Safety M anagem ent R egulation].
O nly m atters relating to safety and health at w ork of the w orkers in the
relevant industrial undertakings shall be discussed at the m eeting of the
safety com m ittee. [Section 11(2) of the Safety M anagem ent R egulation]
In general, the frequency of m eetings of a safety com m ittee depends upon
the volum e of w ork to be handled and the com plexity and nature of hazards
in the w orkplace. N evertheless, in any case, a proprietor or a contractor
shall ensure that a safety com m ittee m eets at least once every three m onths
[Section 11(1)(c) of the Safety M anagem ent R egulation].
M onthly m eetings are usually found to be satisfactory. If sub-com m ittees
are form ed for particular tasks, it w ill norm ally be necessary for them to
m eet m ore often because their aim is to produce a specified result w ithin a
tim e lim it.
The safety com m ittee's program m e should be arranged w ell in advance
and notices of the dates of m eetings published to let all m em bers know .
R eports and relevant m aterials should also be circulated to all m em bers in
advance.
The proprietor or contractor of a relevant industrial undertaking shall ensure
that proper records on safety com m ittee m eetings are kept to provide a
progress report on decisions m ade, recom m endations put forw ard and
actions taken. These records shall be
(a) kept for not less than 5 years after the date of the m eeting to w hich
the record concerned relates; and
(b) m ade available for inspection upon request by an occupational safety
officer.
[Section 11(d) of the Safety M anagem ent R egulation]
The decisions and recom m endations of a safety com m ittee should be
brought to the notice of em ployees. The relevant docum ents should be
displayed or circulated to them for reference.
70
5.10.6 Protection of safety committee members
A proprietor, contractor or em ployer shall not
(a) term inate, or threaten to term inate, the em ploym ent of; or
(b) in any w ay discrim inate against,
a w orker by reason of the fact that the w orker has perform ed his function
as a m em ber of a safety com m ittee.
[Section 12 of the Safety M anagem ent R egulation]
5.11Evaluation of job related hazards or potential hazards and development
of safety procedures
This elem ent refers to the carrying out of job related risk assessm ent and risk
control. The objective of risk assessm ent and risk control is to provide a m eans
w hereby job hazards or potential hazards are identified, evaluated and m anaged
in a w ay that elim inates them or reduces them to a tolerable level. Safety procedures
and risk control m easures that are to be taken to prevent the hazards and to control
the risks should be developed after risk assessm ent.
5.11.1 Programme for risk assessment and risk control
The relevant industrial undertaking should establish and m aintain a
p rog ram m e for id entification of job hazard s, assessm ent of risks,
developm ent, im plem entation and m aintenance of safety procedures and
risk control m easures and review . The program m e should aim at:
(a) recording know n hazards;
(b) identifying new hazards;
(c) evaluating the risks associated w ith the hazards;
(d) analysing the effects or the potential effects resulting from these risks;
and
(e) developing and im plem enting m eans to elim inate the risks or to
reduce them to a tolerable level.
The 14 elements of a safety management system - (11) job hazards analysis
R isk assessm ent and risk control should:
(a) form part of the safety inspection program m e referred to in Part 5.5 ;
(b) be a m ajor com ponent in the risk control program m e referred to in
Part 5.6; and
(c) be an essential part of the health protection program m e covered
b y P art 5.14 of this C O P.
The proprietor or contractor should ensure that persons responsible
for the analysis of hazards, evaluation of risks, and determ ination of
the m eans of elim inating or red ucing any risks are com p etent and
g iven the necessary support so that they can perform their duties
effectively. Please see Part 4.1.1(4) regard ing the com p etency of a
p erson carrying out risk assessm ent.
5.11.2 Main stages in risk assessment and risk control
There are five stages in risk assessm ent and risk control, nam ely:
(a) identification of hazards;
(b) determ ination of risk;
(c) developm ent of safety procedures and risk control m easures;
(d) im plem entation and m aintenance of safety procedures and risk
control m easures; and
(e) review of safety procedures and risk control m easures.
5.11.3 Hazard identification
H azard identification is the process of identifying all situations or events
that could give rise to the potential for injury, illness or dam age to plant or
property. H azard identification should take into account how things are
being done, w here they are done and w ho is doing them , and should also
consider how m any people are exposed to each hazard identified and for
how long. The follow ing should be accorded top priority in the hazard
identification process:
72
- High frequency accidents or near misses
Jobs w ith a high frequency of accidents or near m isses pose a
significant threat to the safety and health of w orkers and should
therefore b e g iven top p riority.
- History of serious accidents causing fatalities
Jobs that have alread y p rod uced fatalities, d isab ling injuries or
illnesses, reg ard less of the freq uency, should have a hig h
p riority in the hazard id entification p rocess.
- Existence of a potential for serious harm
Jobs that have the potential to cause serious injury or harm need
hazard analysis, even if they have never produced an injury or illness.
- Introduction of new jobs
W henever a new job is introduced, a hazard identification process
should be conducted before any w orker is assigned to it.
- Recent changes in procedures, standards or legislation
Jobs that have undergone a change in procedure, equipm ent or
m aterials, and w ork affected by new regulations or standards w ill need
risk assessm ent.
M ajor m ethods for identification of hazards include:
- Direct observation method
This involves observing an experienced w orker w ith good safety
aw areness carrying out the w ork several tim es. The job steps and the
hazards in each of these are recorded.
- Recall method
This should be done for jobs that are rarely perform ed. The m ethod
involves inviting the designers, engineers, supervisors and w orkers
involved in the jobs to attend a brainstorm ing session, during w hich
they w ould look into the m aterials, m achines and equipm ent used,
and the job steps to identify the hazards inherent in such jobs.
In order to identify hazards and evaluate their associated risks, the proprietor
or contractor of a relevant industrial undertaking should in the first place
prepare a list of item s covering prem ises, plant, people and procedures,
and gather inform ation about them . D etails of inform ation required are
given in Part 5.6.1. W hen all the necessary inform ation is in hand, the
hazards related to w ork activities can be identified.
5.11.4 Determination of risk
The risk associated w ith a hazard is a reflection of the likelihood that the
hazard w ill cause harm and the severity of that harm . The tw o elem ents of
risk, i.e. likelihood and severity, are independent of each other. The vast
m ajority of hazards are relatively straightforw ard and requiring only a sim ple
m ethod of risk rating. The m ethod incorporates a judgm ent as to w hether
or not a risk is tolerable. Such a m ethod is illustrated as follow s:
(1) For each hazard identified, ask the question "W hat if?". R ealistically,
w hat is the w orst likely outcom e (i.e. the potential severity of harm ) ?
Is it a fatality, m ajor injury/perm anent disability including perm anent
ill health, a m inor injury, or no injury and only plant dam age? For the
purpose of determ ination of risk, the severity of harm can be divided
into 3 categories:
- Slightly harm ful:
Exam ples are -
- superficial injuries; m inor cuts and bruises; eye irritation from
dust;
- nuisance and irritation (e.g. headaches); ill-health leading
to tem porary discom fort.
- H arm ful:
Exam ples are -
- lacerations; burns; concussions; serious sprains; m inor
fractures;
- deafness; derm atitis; asthm a; w ork related upper lim b
disorders; ill-health leading to perm anent m inor disability.
74
- Extrem ely harm ful:
Exam ples are -
- am putations; m ajor fractures; poisonings; m ultiple injuries;
fatal injuries;
- occupational cancer; other severe life shortening diseases;
acute fatal diseases.
(2) M ake a judgm ent about the probability or likelihood of harm occurring
based on the follow ing table:
Probability/likelihood Description
Likely/frequent O ccurs repeatedly/event only to be expected
U nlikely R ather rem ote, though conceivable
H ighly unlikely So unlikely that probability is close to zero
If the judgm ent is "highly unlikely", this needs to be subject to particularly
rigorous scrutiny as, in reality, this is a relatively rare situation. D ecisions
as to w hether or not action is needed should then be m ade by reference
to the m atrix form ed by probability/likelihood and the likely outcom e
(i.e. severity) w hich is usually called the R isk Level Estim ator. The
follow ing table illustrates a R isk Level Estim ator:
Risk Level Estimator
Slightly harmful Harmful Extremely harmful
Highly unlikely Trivial risk Minor risk Moderate risk
Unlikely Minor risk Moderate risk Substantial risk
Likely Moderate risk Substantial risk Extreme risk
A ction should be taken according to a list of priority. Extrem e risks
should be accorded the first priority, substantial risks the second
priority; m oderate risks the third priority and so on. In deciding w hether
a risk is tolerable, the proprietor or contractor has to take into account
w hether the condition is w ithin statutory lim its and/or conform to legal
or internationally recognised standards. O nly w hen these lim its and
standards are m et and the risk is at, or has been reduced to, the
low est possible level that is reasonably practicable should a risk be
considered tolerable.
G enerally, in determ ining risks levels, it is not necessary to m ake
precise num erical calculations. N orm ally, com plex m ethods for
q uantified risk assessm ent should only b e req uired w here the
consequences of failure could be catastrophic. In the m ajority of
situations, the above-m entioned m ethod w ould be good enough.
H ow ever, for m ajor or com plex hazards, such as those associated
w ith m ajor hazard plants, a variety of techniques are available for
assessing the risks involved. Exam ples are the "hazard and operability
study", the "failure m ode and effect analysis" and the "fault tree analysis".
These are highly sophisticated techniques and should only be used
by professionals adequately trained in these areas.
5.11.5 Development of safety procedures and risk control measures
Safety procedures and risk control m easures are procedures and m easures
to be put in place to reduce risk to a tolerable level.
W hen deciding on safety procedures and risk control m easures, the list
below should be considered, in the order given. Safety procedures and
risk control m easures low er dow n the list should only be used if it can be
show n that using a procedure and/or m easure higher up the list is not
reasonably practicable.
List of safety procedures and risk control measures
(1) Procedures and m easures to elim inate hazards at source: for exam ple,
using a non-hazardous substance instead of a hazardous one.
(2) Procedures and m easures to reduce hazards at source: for exam ple,
replacing a noisy m achine w ith a quieter one.
(3) Procedures and m easures to rem ove w orkers from the hazard: for
exam ple, paint spraying by unattended robots.
(4) Procedures and m easures to contain hazards by enclosure: for
exam ple, installing soundproofing enclosure for a noisy m achine.
76
(5) Procedures and m easures to reduce w orker exposure: for exam ple,
reducing exposure to noise by reducing the hours of w ork.
(6) Procedures and m easures to ensure the proper use of personal
protective equipm ent as the last resort; for exam ple, using hearing
protectors for w orkers operating noisy m achines.
In developing safety procedures and risk control m easures, the proprietor
or contractor should also refer to Parts 4.1.1(3)(c), 5.4, 5.6, 5.13 and 5.14
dealing w ith risk assessm ent, risk control, specific procedures and control
m easures.
5.11.6 Implementing and maintaining safety procedures and risk control
measures
For safety procedures and risk control m easures to be im plem ented
effectively and efficiently, they should be as far as practicable developed
at the w orkplace w ith the participation of all levels of staff. Feedback from
people im plem enting the safety procedures and risk control m easures
should be encouraged so that im provem ent to the procedures and
m easures can be m ade.
M aintaining safety p roced ures and risk control m easures req uires
scheduled inspections and m aintenance. It also requires the enforcem ent
of discipline to ensure that people do not tam per w ith safety procedures
and risk control m easures (e.g. by rem oving m achine guards).
5.11.7 Review of safety procedures and risk control measures
W hatever safety procedures and risk control m easures are used, they should
be review ed if there is reason to suspect that they are no longer effective,
or if there has been a significant change in the m atters to w hich they relate.
Exam ples are :
(1) W hen inform ation is obtained about a previously unknow n design or
m anufacturing fault, or about a previously unidentified hazard.
(2) W hen the design is revised or m odified.
(3) W hen the system of w ork associated w ith the plant is changed.
(4) W hen the plant is m oved.
(5) W hen there is a change to the w orkplace environm ent.
In the circumstances, the risk has to be reassessed and new safety
procedures and control measures devised.
5.12 Promotion, development and maintenance of safety and health
awareness in a workplace
The objective of safety prom otion is to develop and m aintain aw areness am ong
all personnel of (a) the organisation's com m itm ent to safety and health; and (b)
individual persons' responsibility to support that com m itm ent. The proprietor or
contractor of a relevant ind ustrial und ertaking should recog nise that the
prom otion of safety and health is an effective w ay of advancing the culture of
safety and health in the w orkplace and of reinforcing the concept that safety and
production are inseparable.
5.12.1 The need for a safety promotion programme
Safety prom otion program m es should have clearly defined objectives.
They require very careful thought and consideration if the m axim um benefit
is to be obtained. The proprietor or contractor should develop, as part of
a safety p rom otion p rog ram m e, a p roced ure to recog nise and
acknow ledge good safety perform ance either by individuals, team s,
sections, departm ents or the organisation. H e should appoint a coordinator
for the program m e to ensure its sm ooth im plem entation.
5.12.2 Safety promotion approaches
(1) Prom otion of safety in m eetings and sem inars etc.
A m eeting can provide a good opportunity for prom oting safety.
M eetings suitable for prom oting safety include orientation m eetings
for new com ers, training m eetings, and tool-box m eetings. Safety
and health film s/videos can be show n during these m eetings w ith
The 14 elements of a safety management system - (12) safety and health awareness
78
tim e allow ed for discussion after the view ing. Safety sem inars and
conferences can also be used to prom ote safety.
(2) Prom otion of safety to individuals
The line m anagers can prom ote safety directly to all subordinates
during the norm al course of w ork. Through the day-to-day contacts,
they can get the safety m essages across and m ake w orkers accept
safety as a w ay of life.
(3) Prom otion of safety through safety publications, posters, etc.
Safety can be prom oted through the circulation of safety and health
publications, like safety bulletins, new sletters, leaflets and safety
m agazines. For w orkers w ho do not like reading, the use of safety
posters, banners and billboards m ay prove m ore appealing. Posting
of new s cuttings on notice boards highlighting spectacular accidents
w ould also have a strong im pact.
(4) Prom otion of safety through cam paigns
C am paigns are perhaps the m ost high-profile w ay to prom ote safety.
They can be used to raise safety aw areness and prom ote good
practices and safety standards. Safety cam paigns usually involve
the m obilisation of people at different levels for a cause and can
thus focus m ind s on safety issues and sp read the safety
m essages across the entire w orkforce. Safety cam paigns can be in
the form of aw ard schem es. For exam ple, by launching a "good
housekeeping" aw ard schem e, the m anagem ent can encourage staff
at all levels to participate in a com petition in w hich individuals, team s,
sections, units, d ep artm ents, etc., d em onstrating the b est
housekeep ing p ractices w ill b e p icked out for aw ard s. The
cam paigns can effectively arouse w idespread aw areness of the
subject, w ith far-reaching im plications for the organisation's long-
term safety perform ance. O ther form s of safety prom otion include
com pany-w ide safety quizzes, subject-specific educational drives
and roving exhibitions.
The 14 elements of a safety management system - (12) safety and health awareness
In considering w hich approach or approaches to take, a proprietor or
contractor should take into account the culture and other
characteristics of the organization, or w orkplace, in question. The m ost
im portant thing is that the prom otional activities should be able to
convey a clear m essage to all levels of personnel that safety is taken
seriously w ithin the industrial undertaking.
5.12.3 Successful safety promotion programmes
Successful safety prom otion program m es usually have the follow ing
characteristics:
(a) They address properly identified safety problem s.
(b) They have clearly defined focus, them es and objectives.
(c) A ctivities in support of the m ain them e are w ell organised and
co-ordinated.
(d) Incentives for w idespread participation in the program m e are
provided.
(e) Top m anagem ent's total com m itm ent is clearly dem onstrated.
5.13 A programme for accident control and elimination of hazards before
exposing workers to any adverse work environment
This elem ent refers to a process control program m e aim ed at identifying
occupational safety and health risks and properly planning the w ork p rocess
to control those risks. The process control program m e can be applied to all
processes, from construction of bridges, building of ships to m ore specific
processes like the m anufacturing of highly hazardous substances. A n effective
process control program m e requires a system atic approach to evaluating the
w hole process. U sing this approach, the process design and technology,
operational and m aintenance activities and procedures, em ergency plans and
procedures, training program m es, and other elem ents w hich im pact on the
process are all considered in the evaluation. The various lines of d efence
incorp orated into th e d esig n and op eration of the p rocess to ab ate or
reduce the safety and health risks need to be evaluated and strengthened to
ensure their effectiveness at each level. The follow ing stipulates som e of the
m ain com ponents of a process control program m e.
The 14 elements of a safety management system - (13) accident control and hazard elimination
80
5.13.1 Provision of process safety information
C om plete and accurate w ritten inform ation concerning process m aterials,
chem icals, technolog y and eq uip m ent is essential to an effective
process control program m e and to process hazard analysis as described
in Part 5.13.2. The com piled inform ation is a necessary resource for a variety
of users including those perform ing process hazard analysis, those
developing the training program m e and the operating procedures, and
the contractors w hose w orkers w ill be w orking w ith the process, if any.
B esides, process technology inform ation, being part of the process safety
inform ation package, should include appropriate diagram s (such as block
flow diagram s, process flow diagram s and piping and instrum ent diagram s)
of the process to be carried out. O ther inform ation m ay also be required,
such as: the established criteria for m axim um inventory levels for process
m aterials and chem icals; lim its beyond w hich the conditions w ould be
consid ered up set cond itions; and a q ualitative estim ate of the
consequences or results of deviation that could occur if the established
process lim its are exceeded. The inform ation pertaining to process
equipm ent design and the codes and standards relied on to establish good
engineering practice should also be docum ented.
5.13.2 Process hazard analysis
A process hazard analysis is sim ilar to the risk assessm ent m ethod as
described in Part 5.11. It should be an organised and system atic effort to
identify and analyse the significance of potential hazards associated w ith
the carrying out of a specific process in the relevant industrial undertaking.
It should provide inform ation to assist the top m anagem ent in m aking
decisions for im proving safety and health standards in the process. Process
hazard analysis should be directed tow ards analysing the potential causes
and consequences of the occurrence of accidents, particularly those likely
to result in injuries, fires, explosions and releases of toxic or flam m able
substances. It should focus on equipm ent, instrum entation, utilities and
hum an actions that m ight im pact on the process. These considerations
w ill assist in determ ining the hazards and potential failure points or failure
m odes in a process.
The selection of a technique to carry out a process hazard analysis w ould
be influenced by m any factors including the level of existing know ledge
about the process. The questions to be asked include: (a) "Is it a process that
has been operated for a long period of tim e w ith little or no innovation and
extensive experience has been gained from its use?"; and (b) "Is it a new
process or one w hich has been changed frequently w ith the inclusion of
innovative features?" A lso, the size and com plexity of the process w ould
influence the decision as to the appropriate technique to be used. The
sim ple checklist m ethodology w orks w ell w hen the process is very stable
and no changes have been m ade, but it is not as effective w hen the process
has undergone extensive changes.
The techniques com m only available for form al assessm ent of m ajor or
com plex hazards as described in Part 5.11.4 can be used to carry out
process hazard analysis.
5.13.3 Operating procedures
A fter conducting process hazard analysis, the proprietor or contractor of
the industrial undertaking should devise the corresponding operating
procedures w hich can effectively elim inate or control the risks associated
w ith the process. O perating procedures include w ork m ethod statem ents
and, w here applicable, perm it-to-w ork system s. O perating procedures
should describe tasks to be perform ed, data to be recorded, operating
conditions to be m aintained, sam ples to be collected, and safety and health
precautions to be taken. The procedures need to be technically accurate,
understandable to w orkers involved and revised periodically to ensure that
they reflect current operations. O perating procedures should be review ed
by engineering staff and operators, together w ith the safety officer or advisor
to ensure that they are accurate and p rovid e p ractical instructions
regarding how to carry out duties safely.
O perating procedures should include specific instructions as to w hat steps
are to b e taken or follow ed in carrying out the stated p roced ures.
O perating instructions for each procedure should include the applicable
safety p recautions and contain ap p rop riate inform ation on safety
im plications. C om puterised process control system s w ould add com plexity
to operating instructions. These operating instructions should describe
the logic of the softw are as w ell as the relationship betw een the equipm ent
and the control system . A ll control room personnel (if any) and operating
staff should have a full understanding of operating procedures w hich are
also called standard operating practices for operations. O perating
procedures should be review ed w hen there is a change in the process or
82
w hen there are other changes that m ake the previous job hazard analysis
invalid. The consequences of operating procedure changes should be
fully evaluated and the inform ation conveyed to the relevant personnel.
5.13.4 Training and competency of workers
The p rop rietor or contractor should ensure that all w orkers fully
understand the safety and health hazards of the processes they w ork w ith
for the p rotection of b oth them selves and their fellow w orkers. A lso,
additional training in subjects such as operating procedures and safe
w ork p ractices, em erg ency evacuation and resp onse, safety
procedures and other subjects pertinent to process safety and health
should b e includ ed in the training p rog ram m e.
H ands-on training w here w orkers are able to use their senses beyond m erely
listening w ill enhance learning and should be provided. O ther training
techniques using videos or on-the-job training should also be considered.
The proprietor or contractor of the relevant industrial undertaking should
periodically evaluate the training program m e to see if the necessary skills
and know ledge are being properly applied by their trained w orkers. In
addition, the proprietor or contractor should ensure that w orkers, including
sub-contractor's w orkers (if any), have received current and updated
training.
5.13.5 Mechanical integrity programme
review their m aintenance program m es and schedules to see if there
are areas w here "breakdow n" m aintenance (or corrective m aintenance)
is used rather than an on-going m echanical integrity program m e. Plant
and equipm ent used should be designed, constructed, installed and
m aintained in such w ay as to m inim ise the risk at w ork. A m echanical
integrity program m e should be in place to ensure the continued integrity
of process plant and equipm ent. The elem ents of a m echanical integrity
program m e should include the identification and categorisation of plant,
equipm ent and instrum ents, inspections and tests, testing and inspection
freq uencies, d evelop m ent of m aintenance p roced ures, training of
m aintenance personnel, establishm ent of criteria for acceptable test
results, docum entation of test and inspection results, and docum entation
of the m anufacturer's specified m ean-tim e-to-failure data.
5.14 A programme to protect workers from occupational health hazards
The nature of health risks can m ake the link betw een w ork activities and
w orker ill health less apparent than in the case of injury from an accident.
Since health m ay be irreversibly dam aged before the risk is apparent, it is
essential to develop a preventive strategy to identify and control risks before
anyone is exposed to them . Failure to do so can lead to w orkers' disability
and loss of livelihood . It can also m ean financial losses for the relevant
industrial undertaking due to sickness absence, lost production, com pensation
and increased insurance prem ium s.
It is the duty of the proprietor or contractor of a relevant industrial undertaking
to ensure the safety and health of their w orkers. The principles for protecting
w orkers from occupational health hazards through controlling risks are the
sam e as those for safety. A program m e to protect w orkers from occupational
health hazards therefore also consists of:-
(a) identification of hazards;
(b) determ ination of risk;
(c) developm ent of safety procedures and risk control m easures;
(d) im plem entation and m aintenance of safety procedures and risk
control m easures; and
(e) review of safety procedures and risk control m easures,
as described in detail in Part 5.11.
The follow ing paragraphs provide additional guidance w hich is of particular
relevancy to the identification, evaluation and control of health hazards.
5.14.1 Identification of hazards
This is the essential first step. The objective is to find out w hether there
exists any health hazard in the w orkplace. R elevant sources of inform ation
include:
The 14 elements of a safety management system - (14) occupational health assurance programme
84
(a) legislation and supporting codes of practice;
(b) inform ation and advice from suppliers of equipm ent, chem icals and
other m aterials used at w ork;
(c) international standards;
(d) industry or trade association guidance;
(e) the personal know ledge and experience of m anagers and w orkers;
(f) accident, ill health and incident data;
(g) expert advice and opinion; and
(h) findings of research.
B esides, the hazard identification process should take into account the
follow ing-
(1) H azardous chem icals w hich
- if inhaled can cause asthm a, bronchitis or cancer;
- if sw allow ed can cause poisoning; and
- if sp ilt onto the skin or sp lashed into the eyes can cause
derm atitis or severe irritation.
(2) Im proper m anual handling, poorly designed w orkstations, repetitive
m ovem ents, poor w orking postures etc. w hich can cause all kinds of
m usculo-skeletal disorders.
(3) N oise w hich can lead to hearing loss.
(4) Vibration w hich can lead to hand-arm vibration syndrom e and 'w hite
finger'.
(5) R adiation w hich can cause problem ranging from eye and skin dam age,
ill-health (including cancer), to severe burns and even death.
(6) Extrem es of tem perature, pressure and hum idity w hich can affect
people's ability to w ork safely and cause harm ful changes w ithin their
bodies, such as heat stress and 'bends' (decom pression sickness).
(7) Stress w hich can affect all w orkers, not just m anagers. Stress is often
behind a lot of sickness absences. It can contribute to coronary heart
disease and illness caused by high blood pressure.
There should be a critical appraisal of all routine and non-routine business
activities. In the sim plest cases, hazards can be identified by observation
and by reference to the relevant inform ation [(a) to (h) above]. In m ore
com plex cases, m easurem ents such as air sam pling m ay be necessary to
identify the presence of health hazards. The assistance of occupational
hygienists, occupational physicians and occupational health nurses should
be enlisted if necessary. In the m ost com plex cases, special hazard
analysis techniques such as hazard and operability studies and fault tree
analysis should be used. Specialist advice is needed in choosing and
applying the m ost appropriate m ethod.
5.14.2Determination of risk
The process of determ ination of risk helps to decide w hich health risk should
be given priority. The aim is to identify the steps to be taken to control risk.
The process should be done by com petent persons.
A full description of the process is given in Part 5.11.4.
5.14.3 Development of safety procedures and risk control measures
W hen risks have been analyzed and assessed, decisions about the
precautions against occupational health hazards can be m ade. A ll final
decisions about safety procedures and risk control m ethods should take
into account the relevant legal requirem ents w hich establish m inim um
standards for risk prevention or control.
The follow ing is a sum m ary of the safety procedures and risk control
m easures in descending order of priority:
(1) Elim ination of risks by substituting the hazardous substances or
processes w ith non-hazardous or less hazardous ones.
(2) C om bat of risks at source by m eans of engineering controls. Exam ples
are:
(a) to separate the operator from the risk of exposure to a know n
hazardous substance by enclosing the process; and
86
(b) to design process m achinery and w ork activities in such a w ay
as to m inim ise the release of, or to contain, airborne hazards.
(3) M inim isation of risk by m eans of:
(a) adm inistrative control m easures, such as a perm it-to-w ork system ;
and
(b) personal protective equipm ent as a last resort.
A lthough, in com plicated cases, specialist help m ay be needed to control
risks to health, the proprietor or contractor can do a lot to prevent or control
risks to health by taking straight-forw ard m easures such as:
(a) consulting the w orkforce about the design of w orkstations;
(b) consulting the suppliers of substances, plant and equipm ent about
m inim ising exposure;
(c) enclosing m achinery to cut dow n noise;
(d) exploring the feasibility of using less hazardous m aterials; and
(e) ensuring that w orkers are trained in the safe handling of all the
substances and m aterials w ith w hich they m ay com e into contact.
In d evising the safety p roced ures and risk control m easures, the
involvem ent of affected w orkers is essential to ensure that the solutions are
practical for those w ho have to im plem ent them .
5.14.4Implementing and maintaining safety procedures and risk control
measures
Sam e as that described in Part 5.11.6.
5.14.5Reviewing of safety procedures and risk control measures
Sam e as that described in Part 5.11.7
5.14.6Health surveillance
The prim ary objective of health surveillance is to detect adverse health
effects at an early stage, thereby enabling further harm to be prevented. In
addition, the results of health surveillance can provide a m eans of:
(a) checking the effectiveness of control m easures;
(b) providing feedback on the accuracy of the risk assessm ent; and
(c) identifying and protecting individuals from increased risk.
The proprietor or contractor should arrange health surveillance and
m edical checks for w orkers, such as those w orking w ith carcinogenic
sub stances, w ith asb estos, in com p ressed air, or und erg round in
accordance w ith relevant legal requirem ents. If a w orker is found to be
suffering from an occupational disease, the proprietor or contractor should
take steps to prevent him from further exposure to the substance or agent
causing the disease by, for exam ple, transferring him to another job in the
industrial undertaking. H e should review the health protection program m e
to identify the deficiencies and take m easures to rectify them .
88
Safety audit constitutes the "feedback loop" w hich enables the relevant industrial
undertaking to reinforce, m aintain and develop its ability to reduce risks to the fullest
extent and to ensure the continued effectiveness of the safety m anagem ent system .
U nder the Safety M anagem ent R egulation, the m ain duties of the proprietor or
contractor of a relevant industrial undertaking specified in Parts 1 or 3 of Schedule 3 of
the Safety M anagem ent R egulation in relation to safety audits include the follow ing:
- appointm ent of a registered safety auditor to conduct safety audits [Section 13 of
the Safety M anagem ent R egulation];
- provision of facilities, etc. for purpose of safety audits [Section 14 of the Safety
M anagem ent R egulation]; and
- actions to be taken on safety audit reports subm itted by a safety auditor [Section
16 of the Safety M anagem ent R egulation].
This part of the C O P aim s to provide practical guidance in respect of these legal
requirem ents.
6.1 What is a "Safety Audit" ?
6.1.1 "safety audit" means an arrangement for -
(a) collecting, assessing and verifying inform ation on the efficiency,
effectiveness and reliability of a safety m anagem ent system (including
the elem ents specified in Schedule 4 of the Safety M anagem ent
R egulation contained in the system ); and
(b) considering im provem ents to the system .
6.1.2 Collection of information on the safety management system
(1) Interview ing individuals
Individuals should be interview ed to gather inform ation about the
operation of the safety m anagem ent system and the perceptions,
know led g e, und erstand ing , m anag em ent p ractices, skills and
com petence of m anagers and em ployees at various levels in the
organisation.
6.SA FETY A U D IT
In general, key personnel in the relevant industrial undertaking to be
audited, as w ell as its sub-contractors, should provide the safety auditor
w ith relevant inform ation. Q uestionnaires can be used to ensure that
interview s are carried out in a structured m anner and that all the
inform ation required is obtained efficiently w ith m inim um inconvenience
to the parties involved. K ey personnel usually include the proprietor
or contractor, directors, m anagers, safety officers/safety advisors, perm it-
to-w ork controllers, and experienced em ployees. O ther representative
personnel at all levels should also be interview ed to establish w hether or
not procedures are understood and follow ed.
(2) Exam ining docum ents
D ocum ents should be exam ined to check and assess the industrial
undertaking's risk control system s, perform ance standards, safety
procedures and safety instructions and to verify the inform ation
obtained through interview s.
The docum ents to be exam ined should include:
- the safety policy, com plete w ith the general policy statem ent and
a description of the supporting safety organisation and safety
arrangem ents;
- risk assessm ent reports;
- previous safety audit records;
- d ocum ents setting out the safety and health risk control
arrangem ents;
- safety com m ittee/safety group m eeting m inutes;
- safety inspection reports;
- accident, incident and ill-health reports and statistics;
- occupational hygiene records (for exam ple, personal m onitoring
records);
- reports by the enforcing authorities;
- safety training records;
- in-house safety rules and reg ulations and record s of their
com pliance;
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90
- the agreem ents w ith sub-contractors (if applicable);
- records of safety prom otion program m es;
- statutory registers, form s and certificates;
- records of safety and health suggestions; and
- em ergency procedures.
(3) Visual observations
The purposes of visual observation of physical conditions and w ork
activities are to exam ine com pliance w ith legal requirem ents, to
verify the im plem entation and effectiveness of w orkplace safety
procedures / precautions and risk control system s, and to confirm
the inform ation gathered through interview s and exam ination of
docum ents. There are various types of observation ranging from
sim ple visual observation of w ork and behaviour to very thorough
visual checking of prem ises, plant and equipm ent. It can cover the
w hole of a particular operation or activity or focus on som e sam pled
parts.
C ollection of inform ation about the safety m anagem ent system requires
decisions on the level and detail of an audit. M ost audits involve sam pling
and a key question is alw ays "H ow m uch sam pling needs to be done to
m ake a reliable assessm ent?". The nature and com p lexity of an aud it
should therefore vary according to its objectives and scope; the size,
sophistication and com plexity of the relevant ind ustrial und ertaking ;
and the m aturity of the existing safety m anagem ent system .
The inform ation so collected in a safety audit should be able to provide
a check on the adequacy and effectiveness of the safety m anagem ent
system in place. Therefore, the inform ation concerned w ith answ ering
the follow ing questions should be collected:
(a) Is the safety m anagem ent system adequate, w orking w ell and w ithout
w aste of resources ? (i.e. is it doing the right things ?)
(b) Is the safety m anagem ent system w orking as intended and to the
desired effect ? (i.e. is it doing things right ?)
(c) C an the safety m anagem ent system be relied upon ? (i.e. can it ensure
that all requirem ents regarding safety and health are com plied w ith
consistently and can it secure continued effective operation?)
Safety Audit
6.1.3 Assessment and verification of information on the safety management
system
(1) The adequacy of a safety m anagem ent system should be assessed
by m aking a com parison betw een w hat is found against a relevant
"standard" or benchm ark (i.e. the audit criteria). Legal standards, codes
of practice, guidance notes, applicable industry standards and
international standards should be used to m ake audit judgm ents.
(2) Sufficient evidence should be collected to verify w hether the relevant
industrial undertaking's safety m anagem ent system conform s w ith the
audit criteria. Evidence is typically secured through interview s,
exam ination of docum ents, and visual observation of activities and
conditions. Indications of non-conform ity w ith the audit criteria should
be recorded.
(3) Evidence can be in the form of qualitative or quantitative data. The use
of correctly designed audit aids such as checklists and questionnaires,
etc. can help sim plify the analysis of data. In som e cases, it w ould be
helpful to score audit findings so that changes in perform ance can be
m easured from one audit to the next. W here such an approach is
ad op ted , it should b e b ased on aud iting m ethod s that ensure
consistency in scoring.
(4) The value of a safety audit is dependent upon (a) the experience and
know ledge of the safety auditor and his ability to interpret and use the
audit findings; and (b) the im plem entation of the recom m endations of
the safety audit report. It is also dependent upon the integrity of
all the parties involved. Therefore, checks should be built into the
system to help avoid m isrepresentation or m isapplication of safety audit
results.
(5) The safety auditor should review all his audit evidence to determ ine
w here the safety m anagem ent system does not conform to the audit
criteria. H e should then ensure that the findings of non-conform ity are
supported by audit evidence and properly docum ented. Lastly, the
safety auditor should discuss his findings w ith the m anager in question
to counter-check the factual basis of these findings. If objection is
raised by the m anager, the findings should be clarified before they are
presented to the proprietor or contractor of the relevant industrial
undertaking.
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92
6.1.4 Consideration of improvements to the safety management system
(1) B ased on the audit findings, the overall perform ance of the safety
m anagem ent system should be assessed. If inadequacies or non-
conform ities are identified, recom m endations should be m ade to
im prove the system . The audit should also identify the strengths and
suggest how to build on them .
(2) A plan based on the audit findings for im proving the safety m anagem ent
system should be developed and draw n up. This plan should contain
the necessary rem ed ial m easures and actions to rectify the
inadequacies and non-conform ities, com plete w ith a description of
responsibilities, com pletion dates and reporting requirem ents. Follow -
up m onitoring arrangem ents should be established to ensure the
satisfactory im plem entation of the plan.
6.2 The appointment of a registered safety auditor to conduct a safety
audit
6.2.1 (1) A proprietor or contractor specified in Part 1 or Part 3 of Schedule 3 of
the Safety M anagem ent R egulation shall appoint a registered safety
auditor to conduct a safety audit in relation to the relevant industrial
undertaking. [Section 13(1) of the Safety M anagem ent R egulation]
(2) W ho is a registered safety auditor ?
(a) For a person to be registered as a safety auditor, he should satisfy
the requirem ents of Schedule 1 in the Safety M anagem ent
R egulation. [Section 4(1) of the Safety M anagem ent R egulation]
Safety Audit
The person shall -
(a) be a reg istered safety officer und er the Factories
and Ind ustrial U nd ertaking s (S afety O fficers and
S afety S up ervisors) R eg ulations (C ap .59 sub .
leg .);
(b ) have not less than 3 years' full-tim e experience, in the
5 years period im m ediately preceding the application
concerned under section 5 of this R egulation, in a
m anagerial post responsible for industrial safety and
health m atters in respect of an industrial undertaking;
(c) occupy, at the tim e of the application concerned
under section 5 of this R egulation, the m anagerial post
referred to in paragraph (b), or a like post;
(d ) have successfully com p leted -
(i) a schem e conducted by a registered schem e
op erator; or
(ii) before the com m encem ent of this Schedule,
a schem e recog nized b y the C om m issioner
for the p urp oses of this S ched ule; and
(e) und erstand the req uirem ents und er leg islation in
H ong K ong relating to industrial safety and health
m atters.
(b) The person should apply to the C om m issioner for registration
[S ection 5 of the S afety M anag em ent R eg ulation]. If the
C om m issioner considers that the person is eligible, com petent,
fit and proper to be registered, he w ill be registered as a safety
auditor [Section 6(2) of the Safety M anagem ent R egulation]
and the p articulars of his nam e and ad d ress, etc. w ill be
kept in a register m aintained by the C om m issioner [Section 3(1)(a)
of the Safety M anagem ent Regulation].
Safety Audit
94
(3) H ow should the proprietor or contractor choose a safety auditor ?
(a) The proprietor or contractor should go to such offices of the
G overnm ent as the C om m issioner m ay direct to inspect the
reg ister, free of charg e, d uring office hours [S ections 3(1)
and 3(2) of the Safety M anagem ent R egulation]. H e should
only ap p oint a reg istered safety aud itor w hose nam e
appears in the register and w hose registration is not for the
tim e being suspended under this R egulation. H e can inspect
the reg ister kep t b y the C om m issioner to check w hether or
not the reg istered safety aud itor is susp end ed und er the
S afety M anag em ent R eg ulation and the p eriod of tim e that
reg istration is susp end ed [S ection 3(3)(b ) of the S afety
M anag em ent R eg ulation].
(b) In choosing a safety aud itor, the p rop rietor or contractor
should consider the possible draw back of an internal safety
auditor being over-fam iliar or over-satisfied w ith the relevant
industrial undertaking's arrangem ents. Furtherm ore, he should
adhere to the follow ing basic criteria in choosing his safety
auditor -
- The auditor should understand his task and be com petent
to carry it out.
- The auditor should be fam iliar w ith the industry and the
processes being carried out in the relevant industrial
undertaking.
- The auditor should have a good know ledge of the safety
m anag em ent p ractices in the ind ustry.
- The auditor should have the necessary experience and
know ledge to enable him to evaluate perform ance and
identify deficiencies effectively.
(4) H ow should the proprietor or contractor appoint a registered safety
auditor ?
The appointm ent of a registered safety auditor should preferably
be done in w riting by the proprietor or contractor so that there are
docum ents to prove the appointm ent.
Safety Audit
6.2.2 (1) The proprietor or contractor specified in Part 1 or Part 3 of Schedule 3
of the Safety M anagem ent R egulation is required to ensure that safety
audits are conducted according to the frequency stated. [Section 13(2)
of the Safety M anagem ent R egulation]
(2) H ow frequent should safety audits be conducted in relevant industrial
undertakings carrying out construction w ork?
(a) For such a relevant industrial undertaking set up before the
com m encem ent of the Safety M anagem ent R egulation -
safety audits should be conducted not less than once in each 6
m onths period, beginning w ith the com m encem ent of the Safety
M anagem ent R egulation.
(b) For such a relevant industrial undertaking set up after the
m onths period beginning w ith the day on w hich the undertaking
com es into existence.
(c) In any case, safety audits should be conducted not less than 6
m onths after the last safety audit report w as subm itted under
section 15 of the Safety M anagem ent R egulation in respect of
the undertaking.
[Section 13(2)(a) of the Safety M anagem ent R egulation]
(3) H ow frequent should safety audits be conducted in relevant industrial
undertakings other than those carrying out construction w ork?
m onths period, beginning w ith the com m encem ent of the Safety
M anagem ent R egulation.
m onths period beginning w ith the day on w hich the undertaking
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96
(c) In any case, safety audits should be conducted not later than 12
m onths after the last safety audit report w as subm itted under
section 15 of the Safety M anagem ent R egulation in respect of
the undertaking.
[Section 13(2)(b) of the Safety M anagem ent R egulation]
6.3 Assistance, facilities and information to be provided for the purposes
of safety audit
6.3.1 The proprietor or contractor w ho has appointed a registered safety auditor
to conduct a safety audit shall provide all such assistance, facilities and
inform ation as m ay be necessary for the audit. [Section 14(a) of the Safety
6.3.2 (1) W hat "assistance" should be provided ?
(a) Full co-operation w ith the safety auditor
The proprietor or contractor should ensure that staff at all levels
in the relevant industrial undertaking are m ade aw are of the
objectives of a safety audit and its benefits so that they w ould not
see the audit as a threat. A ll staff should be required to be open
and co-op erate w holehearted ly w ith the safety aud itor b y
responding to any questions and request for inform ation/data
frankly and efficiently during the audit.
(b) D eterm ination of the scope of the safety audit
The scope of the audit should be determ ined by the proprietor or
contractor in consultation w ith the safety auditor prior to the audit.
The scope of the safety audit should describe the extent and
b ound aries of the aud it in term s of p hysical locations,
organisational activities and other param eters. A ll em ployees,
including m anagem ent staff, should be inform ed about the audit
scope by the proprietor or contractor, w ho should ensure that
the resources com m itted to the audit are sufficient to m eet its
intended scope.
Safety Audit
(c) A ssisting in the establishm ent of the audit criteria and audit plan
The proprietor or contractor should assist the safety auditor to
w ork out the safety audit criteria. International standards, codes
of practice, guidance notes, guidelines, legal requirem ents, and
a host of other safety and health literatures, w ill be valuable
sources of reference to help draw up the audit criteria.
In addition, the proprietor or contractor should take part in the draw ing
up of the safety audit plan so that he can fully understand the plan
and com m unicate it to all staff m em bers w ho w ill be affected by the
audit. The proprietor or contractor should also take part in the review
of the plan during the audit. The plan should include:
- the safety audit objectives and scope;
- the safety audit criteria;
- a description of the organisational and functional units to
be audited;
- a description of the units and/or individuals in the relevant
und ertaking having sig nificant d irect resp onsib ilities
regarding safety m anagem ent;
- the procedures for auditing the safety m anagem ent system ;
- the languages used in the safety audit;
- a description of reference docum ents;
- the expected tim e and duration for m ajor safety audit
activities;
- w hen and w here the safety audit is to be conducted;
- the schedule of m eetings to be held w ith the m anagem ent;
- the confidentiality and privacy protection requirem ents;
- the contents, form at and expected date of issue of the safety
audit report; and
- docum ent retention requirem ents.
Safety Audit
98
B esides, the proprietor or contractor and the safety auditor should
agree on the dates for com m encem ent and com pletion of the
safety audit, and the date by w hich the audit report is to be
com pleted by the safety auditor.
(d) A uthorisation and resources
The safety auditor should be authorised to enter w orkplaces,
access confidential inform ation, and inspect reports, records and
statutory form s relating to safety and health during the audit. In
addition, the safety auditor should be provided w ith adequate
financial and hum an resources to ensure that he can carry out
the audit in an effective and efficient w ay.
(e) A ppointm ent of senior staff to accom pany the safety audit
R esponsible and com petent senior staff should be appointed to
accom pany the safety auditor to the w ork sites and to ensure
that the aud itor is fully aw are of the safety and health
requirem ents enforced at the sites.
(2) W hat "facilities" should be provided ?
Provision of on-site facilities
p rovid e the aud itor w ith a suitab le m eeting p lace (such as an
interview room ) to conduct interview s w ith relevant w orking personnel
on site, com plete w ith desks and chairs. H e should also provide the
safety auditor w ith suitable personal protective equipm ent and the
necessary secretarial support (such as photocopying and e-m ail
services). In addition, suitable testing and m easuring equipm ent should
be m ade readily available during the audit. Transportation for the
auditor to go from one w ork location to another should also be arranged.
(3) W hat "inform ation" should be provided ?
D ocum ents relating to safety and health m atters
co-operate fully w ith the safety auditor by tendering all the necessary
docum ents for inspection and checking by the safety auditor. The
docum ents should include the organisational chart, safety com m ittee
Safety Audit
m eeting m inutes, accidents and incidents investigation reports,
p rod uction flow charts, w ork sp ecifications and p roced ures,
perm it-to-w ork procedures, m aterial safety data sheets, statutory form s
and certificates, safety and health m anuals, risk assessm ent reports,
m ethod statem ents, p revious safety aud it rep orts, and record s
show ing that the w ork activities m eet the safety and health standards.
6.4 Things to observe when the safety auditor is an employee of the
6.4.1 The p rop rietor or contractor w ho has ap p ointed a reg istered safety
auditor to conduct a safety audit shall ensure that the auditor, if he is
an em p loyee of the p rop rietor or contractor, as the case m ay b e, is
not req uired to carry out other w ork of a nature or to the extent that
w ould prevent the efficacious conduct of the audit. [Section 14(b) of
the S afety M anag em ent R eg ulation]
6.4.2 W hat sort of w ork w ould prevent the efficacious conduct of the audit ?
If the safety aud itor is an em p loyee of the relevant ind ustrial
und ertaking , the p rop rietor or contractor should , as far as p ossib le,
only req uire him to carry out w ork relating to cond ucting the safety
aud it.
If it is not reasonably practicable to release the safety auditor from other
duties during the audit, he should not be requested to take up duties of a
nature that w ould prevent the efficacious conduct of the audit, including
those likely to give rise to a conflict of interest and underm ine his im partiality
as an auditor. H e should avoid duties that w ould overload him or cause
undue interruptions to his w ork as a safety auditor. For exam ple, if the
safety auditor is an in-house safety officer or safety advisor, he should be
released from the duties of a safety officer or safety advisor to avoid conflict
of interest and m aintain im partiality once he is appointed by the proprietor
or contractor as the safety auditor.
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100
6.5 Actions to be taken on safety audit report
6.5.1 The proprietor or contractor to w hom a safety audit report has been subm itted
under section 15 of the Safety M anagem ent R egulation shall
(a) read and countersig n the rep ort, and record the d ate of his
countersignature, as soon as practicable after receiving the report;
(b) if the report contains recom m endations for im provem ents to the safety
m anagem ent system to w hich it relates -
(i) draw up a plan for the im provem ents w ithin 14 days after
receiving the report; and
(ii) im plem ent the plan as soon as is practicable;
(c) if a plan referred to in paragraph (b) is draw n up, subm it a copy of the
report together w ith a copy of the plan to the C om m issioner w ithin 21
days after receiving the report; and
(d) keep a copy of the report and the plan, if any, for a period of not less
than 5 years after the d ate of countersig nature referred to in
paragraph (a).
6.5.2 (1) W hat should the proprietor or contractor do before countersigning
the safety audit report ?
B efore countersigning the safety audit report, the proprietor or
contractor, together w ith the m anagers affected by the findings of the
rep ort, should seriously consid er the aud it find ing s and the
recom m endations for im proving the safety m anagem ent system to
see if they have any questions for im m ediate clarification w ith the
safety auditor.
Safety Audit
(2) H ow should the plan for im provem ents be ?
If the safety audit report contains recom m endations for im proving
the safety m anagem ent system , the proprietor or contractor should
draw up a plan, in w ritten form and com plete w ith a description of
the rem ed ial m easures, resp onsib ilities, com p letion d ates and
rep orting req uirem ents, etc., for the im p lem entation of the
recom m ended im provem ents, w ithin 14 days after receiving the
report. In general, the plan should include the follow ing essential
com ponents
(a) Present situation
The present situation regarding the effectiveness, efficiency and
reliability of the safety m anagem ent system in operation in the
relevant industrial undertaking should be defined as specifically
as possible, based on the audit findings. This should be com pared
w ith the desired situation to find out how big the gap is.
(b) D esired situation
The desired situation regarding the effectiveness, efficiency
and reliab ility of the safety m anag em ent system should b e
d e fin e d a s sp e c ific a lly a s p o ssib le , b a se d o n th e
recom m end ations of the safety aud it rep ort. It w ill p rovid e
th e sta n d a rd s fo r th e in d u stria l u n d e rta kin g 's sa fe ty
m anag em ent system to m easure up to.
(c) A ction p lan
The action p lan d eals w ith how to m ove from the p resent
situation to the d esired situation. It should b e sp ecific
enough to be m easurable and should answ er the questions
of "w hat", "w ho" and "w hen" in the process of upgrading the
safety m anag em ent system . M onitoring arrang em ents
should b e laid d ow n in the p lan to ensure its effective and
efficient im p lem entation.
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(3) H ow soon should the p rop rietor or contractor im p lem ent the
im provem ent plan?
The proprietor or contractor shall as soon as is practicable im plem ent the
plan draw n up to rectify the shortcom ings that exist in the safety
m angem ent system . H e should, in consultation w ith the safety auditor,
w ork out a priority list of actions so that situations w ith im m inent risks are
dealt w ith im m ediately and non-im m inent situations are dealt w ith as soon
as possible.
In any case, the proprietor or contractor shall subm it a copy of the safety
audit report together w ith a copy of the plan to the C om m issioner w ithin
21 days after receiving the report. The proprietor or contractor shall also
keep a copy of the report and the plan, if any, for not less than 5 years
after the date of his countersignature. Follow -up m onitoring arrangem ents
should be established by the proprietor or contractor to ensure satisfactory
im plem entation of the plan for im proving the efficiency, effectiveness
and reliability of the safety m anagem ent system .
Safety Audit
6.6 Obligation to produce safety audit report or plan for inspection
6.6.1 The proprietor or contractor shall at all reasonable tim es m ake available the
safety audit report or plan for inspection by any occupational safety officer
w ho requests to see it. [Section 17(a) of the Safety M anagem ent Regulation]
6.6.2 The proprietor or contractor shall provide a copy of the report or plan,
and/or any docum ent w hich supports any m atter specified or referred to in
the report or plan not later than 14 days after receiving a w ritten request
from the C om m issioner to do so. [Sections 17(c) and (d) of the Safety
6.6.3 W hat are the docum ents w hich support the m atter specified or referred to in the
safety audit report or plan?
Such docum ents include records or other docum ents w hich:
(a) provide evidence on the developm ent, im plem entation and m aintenance
of the safety m anagem ent system ; and
(b) have been used by the safety auditor to support his audit findings
and recom m endations. Som e exam ples of such docum ents are
listed in Part 6.1.2(2) for reference.
6.6.4 A proprietor or contractor shall perm it an occupational safety officer to m ake
a copy of the safety audit report or plan he requests to see. [Section 17(b)
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104
Safety review constitutes the "feedback loop" w hich enables the relevant industrial
undertaking to reinforce, m aintain and develop its ability to reduce risks to the fullest
extent and to ensure the continued effectiveness of the safety m anagem ent system .
U nder the Safety M anagem ent R egulation, the m ain duties of the proprietor or
contractor of a relevant industrial undertaking specified in Part 2 or 4 of Schedule 3 in
relation to safety review s include the follow ing:
- appointm ent of a safety review officer to conduct safety review s [Section 19 of
the Safety M anagem ent R egulation];
- provision of facilities, etc. for purpose of safety review s [Section 20 of the Safety
M anagem ent R egulation]; and
- action to be taken on safety review reports subm itted by a safety review officer
[Section 22 of the Safety M anagem ent R egulation].
This part of the C O P aim s to provide practical guidance in respect of these legal
requirem ents.
7.1 What is a "Safety Review"?
7.1.1 "safety review" means an arrangement for -
(a) review ing the effectiveness of a safety m anagem ent system (including
the elem ents specified in Schedule 4 of the Safety M anagem ent
R egulation contained in the system ); and
(b) considering im provem ents to the effectiveness of the system .
7.1.2 Review of the safety management system
(1) D ocum ent review
S afety and health instructions are an integ ral p art of norm al
procedures and w orking instructions. Therefore, relevant docum ents
should b e review ed as p art of the safety review . In g eneral,
docum ents to be review ed and assessed should be those w hich
7.SA FETY R EVIEW
provide evidence on the im plem entation and m aintenance of the
safety m anagem ent system , including:
- the safety policy, com plete w ith the general policy statem ent and a
description of the supporting safety organisation and safety
arrangem ents;
- risk assessm ent reports;
- previous safety review records;
- safety and health m anuals, setting out the safety and health risk
control arrangem ents;
- safety group m eeting m inutes;
- safety inspection reports;
- accident, incident and ill-health reports and statistics;
- occupational hygiene records (for exam ple, personal m onitoring
records);
- reports by the enforcing authorities;
- safety training records;
- in-house safety rules and regulations and records of their com pliance;
- the agreem ents w ith sub-contractors (if applicable);
- records of safety prom otion program m es;
- statutory registers, form s and certificates;
- records of safety and health suggestions; and
- em ergency procedures.
Safety Review
106
(2) Physical condition check
Physical check of prem ises, plant and equipm ent, supplem ented by
visual observation of w ork and behaviour by the safety review officer,
should be conducted during the safety review . The purposes are to
check com p liance w ith leg al req uirem ents and to verify the
effectiveness of w orkplace safety procedures / precautions and risk
control system s. The physical condition check m ay either cover the
w hole of a particular operation or activity or focus on only the sam pled
parts.
D uring the physical condition check, the proprietor or contractor of
the relevant industrial undertaking or his representative, the person
resp onsib le for safety m atters and the exp erienced em p loyees
involved in the particular operation or activity to be review ed, should
be asked to provide inform ation to counter-check the validity of the
observation findings.
Finally, the physical condition check findings so collected should
b e used to verify the inform ation g athered throug h exam ining
docum ents.
(3) The safety review should answ er the questions "w here are w e now ?"
and "how w ell or badly are w e perform ing?". It should be a review of
the existing arrangem ents for m anaging safety and health in the
relevant industrial undertaking and an appraisal of the perform ance of
the safety m anagem ent system in operation. D uring the safety review ,
inform ation should b e ob tained on the scop e, ad eq uacy and
im plem entation and m aintenance of the current safety m anagem ent
system . A lso, the review should provide a reference for the next safety
review on the progress of the im plem entation and m aintenance of the
safety m anagem ent system . In general, the safety review should
com pare the existing safety m anagem ent system w ith:
(a) the requirem ents of the Safety M anagem ent R egulation on the
developm ent, im plem entation and m aintenance of a safety
m anagem ent system ;
Safety Review
(b) the standards stipulated in the relevant codes of practice and
guidance notes; and
(c) the industry standards and international standards applicable to
the operation of a safety m anagem ent system .
(4) A conclusion should be draw n as to w hether or not the relevant
industrial undertaking's safety m anagem ent system conform s to the
requirem ents and standards as laid dow n in (3) above, based on the
findings of the physical condition check and docum ent review .
(5) The safety review officer should ensure that the find ing s of
non-conform ity are properly docum ented and supported by review
evidence. Lastly, the safety review officer should discuss his findings
w ith the m anager or supervisor in question to verify the factual basis of
his findings. If objection is raised by the m anager or supervisor, the
m atters should be clarified before the review findings are presented to
the proprietor or contractor of the relevant industrial undertaking.
7.1.3 Consideration of improvements to the safety management system
(1) B ased on the review find ing s, the overall p erform ance of the
safety m anagem ent system should be assessed. If inadequacies or
non-conform ities are id entified , recom m end ations should b e
m ade to im prove the system . The review should also identify the
streng ths and sug g est how to b uild on them .
(2) A p lan b ased on the review find ing s for im p roving the safety
m anagem ent system should be developed and draw n up. This plan
should contain the necessary rem edial m easures and actions to
rectify the inadequacies and non-conform ities, com p lete w ith a
d escrip tion of resp onsib ilities, com p letion dates and reporting
req uirem ents. Follow -up m onitoring arrang em ents should b e
established to ensure the satisfactory im plem entation of the plan.
Safety Review
108
7.2 The appointment of a safety review officer to conduct a safety review
7.2.1 (1) A proprietor or contractor specified in Part 2 or 4 of Schedule 3 of the
Safety M anag em ent R eg ulation shall
(a) ap p oint, in the ap p roved form , a p erson (w ho m ay b e an
em ployee of the proprietor or contractor), being a person w ho is
capable of com petently carrying out a safety review , to be the
safety review officer to conduct a safety review in relation to the
relevant industrial undertaking; and
(b) cause a copy of the appointm ent to be displayed -
(i) in a consp icuous p osition at each p lace w here the
undertaking is carried on; and
(ii) as soon as practicable after m aking the appointm ent.
(2) W ho is a safety review officer ?
A safety review officer can b e an em p loyee of the relevant
ind ustrial und ertaking to b e review ed or an outsid er w ho is not
an em p loyee of the relevant ind ustrial und ertaking . H e shall b e
a person w ho is capable of com petently carrying out a safety review .
For a person to be considered as com petent in carrying out a safety
review , he should have a g ood understanding of (a) the operation
of the relevant industrial undertaking in respect of w hich he conducts
the safety review ; and (b) the legal requirem ents in force in H ong
K ong relating to ind ustrial safety and health, and should have
received ap p rop riate training in how to review the effectiveness
of a safety m anag em ent system w ith a view to im p roving it. A s
an exam p le, a p erson w ho has successfully com p leted a safety
aud itor training course cond ucted b y a reg istered schem e
op erator w ill b e consid ered as having received such training .
Safety Review
(3) H ow should the proprietor or contractor choose a safety review officer ?
In choosing a safety review officer, the general factors that should be
considered by the proprietor or contractor include the availability
of the safety review officer for the length of tim e necessary to undertake
the safety review ; the availability of a safety review officer w ith the
necessary skills; the safety review experience required; the specialist
know ledge or technical expertise required; and the danger of an internal
safety review officer being over-fam iliar or over-satisfied w ith the relevant
industrial undertaking's arrangem ents.
(4) H ow to appoint a safety review officer ?
The proprietor or contractor should appoint a safety review officer in
w riting, using an approved form . This approved form is specified by the
C om m issioner for this purpose. [Section 36(1) of the Safety M anagem ent
Regulation]
7.2.2 (1) The proprietor or contractor specified in Part 2 or Part 4 of Schedule 3 of
the Safety M anagem ent R egulation shall ensure that safety review s
are conducted according to the frequency stated. [Section 19(2)
(2) H ow freq uent should safety review s b e cond ucted in relevant
industrial undertakings carrying out construction w ork?
safety review s should be conducted not less than once in each
6 m onths period, beginning w ith the com m encem ent of the
S afety M anag em ent R eg ulation.
6 m onths p eriod b eg inning w ith the d ay on w hich the
undertaking com es into existence.
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110
(c) In any case, safety review s should be conducted not less than 6
m onths after the last safety review report w as subm itted under
section 21 of the S afety M anagem ent R egulation in respect of
the undertaking.
[Section 19(2)(a) of the Safety M anagem ent R egulation]
(3) H ow freq uent should safety review s b e cond ucted in relevant
industrial undertakings other that those carrying out construction w ork?
com m encem ent of the S afety M anag em ent R eg ulation -
safety review s should b e cond ucted not less than once in
each 12 m onths period, beginning w ith the com m encem ent
of the S afety M anag em ent R eg ulation.
com m encem ent of the S afety M anag em ent R eg ulation -
12 m onths period beginning w ith the day on w hich the undertaking
(c) In any case, safety review s should be conducted not later than
12 m onths after the last safety review s report w as subm itted
under section 21 of the Safety M anagem ent R egulation in respect
of the undertaking.
[Section 19(2)(b) of the Safety M anagem ent R egulation].
Safety Review
7.3 Assistance, facilities and information to be provided for the purposes
of safety review
7.3.1 The proprietor or contractor w ho has appointed a safety review officer to
conduct a safety review shall provide all such assistance, facilities and
inform ation as m ay be necessary for the review [Section 20(a) of the
S afety M anagem ent R egulation].
7.3.2 (1) W hat "assistance" shall be provided ?
(a) Full co-operation w ith the safety review officer
The proprietor or contractor should ensure that staff at all levels
in the relevant industrial undertaking are m ade aw are of the
objectives of a safety review and its benefits so that they w ould
not see the safety review as a threat. A ll staff should be required
to be open and co-operate w holeheartedly w ith the safety review
officer by responding to any questions and request for inform ation/
data frankly and efficiently during the safety review .
(b) D eterm ination of the scope of the safety review
The scope of the safety review should be determ ined by the
proprietor or contractor in consultation w ith the safety review
officer prior to the safety review . The scope of the safety review
should describe the extent and boundaries of the safety review
in term s of physical locations, organisational activities and other
param eters. A ll em ployees, including m anagem ent staff, should
be inform ed about the safety review scope by the proprietor or
contractor, w ho should ensure that the resources com m itted to
the safety review are sufficient to m eet its intended scope.
(c) A ssisting in the establishm ent of the review criteria and review
plan
The proprietor or contractor should assist the safety review
officer to w ork out the safety review criteria. International
standards, codes of practice, guidance notes, guidelines, legal
requirem ents, and a host of other safety and health literatures,
w ill be valuable sources of reference to help draw up the safety
review criteria.
Safety Review
112
In addition, the proprietor or contractor should take part in the
d raw ing up of the safety review p lan so that he can fully
understand the plan and com m unicate it to all staff m em bers
w ho w ill be affected by the safety review . The proprietor or
contractor should also take part in the review of the plan during
the safety review . The plan should include:
- the safety review objectives and scope;
- the safety review criteria;
- a description of the organisational and functional units to
be review ed;
- a description of the units and/or individuals in the relevant
und ertaking having sig nificant d irect resp onsib ilities
regarding safety m anagem ent;
- the p roced ures for review ing the safety m anag em ent
system ;
- the languages used in the safety review ;
- a description of reference docum ents;
- the expected tim e and duration for m ajor safety review
activities;
- w hen and w here the safety review is to be conducted;
- the schedule of m eetings to be held w ith the m anagem ent;
- the confidentiality and privacy protection requirem ents;
- the contents, form at and expected date of issue of the safety
review report; and
- docum ent retention requirem ents.
B esides, the proprietor or contractor and the safety review officer
should agree on the dates for com m encem ent and com pletion
of the safety review , and the date by w hich the review report is to
be com pleted by the safety review officer.
Safety Review
(d) A uthorisation and resources
The safety review officer should be authorised to enter w orkplaces,
access confidential inform ation, and inspect reports, records and
statutory form s relating to safety and health during the safety
review . In addition, the safety review officer should be provided
w ith adequate financial and hum an resources to ensure that he
can carry out the safety review in an effective and efficient w ay.
(2) W hat "facilities" shall be provided ?
Provision of on-site facilities
provide the safety review officer w ith a suitable m eeting place (such
as an interview room ) to conduct interview s w ith relevant w orking
personnel on site, com plete w ith desks and chairs. H e should also
provide the safety review officer w ith suitable personal protective
eq uip m ent and the necessary secretarial sup p ort (such as
photocopying and e-m ail services). In addition, suitable testing and
m easuring equipm ent should be m ade readily available during the
safety review . Transportation for the safety review officer to go from
one w ork location to another should also be arranged.
(3) W hat "inform ation" shall be provided ?
D ocum ents relating to safety and health m atters
co-operate fully w ith the safety review officer by tendering all the
necessary docum ents for inspection and checking by the safety
review officer. The docum ents should include the organisational chart,
safety com m ittee m eeting m inutes, accid ents and incid ents
investigation reports, production flow charts, w ork specifications and
procedures, perm it-to-w ork procedures, m aterial safety data sheets,
statutory form s and certificates, safety and health m anuals, risk
assessm ent reports, m ethod statem ents, previous safety review reports,
and records show ing that the w ork activities m eet the safety and health
standards.
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114
7.4 Things to observe when the safety review officer is an employee of the
7.4.1 The proprietor or contractor w ho has appointed a safety review officer to
conduct a safety review shall ensure that the officer, if he is an em ployee of
the proprietor or contractor, as the case m ay be, is not required to carry out
other w ork of a nature or to the extent that w ould prevent the efficacious
conduct of the review . [Section 20(b) of the Safety M anagem ent R egulation]
7.4.2 W hat sort of w ork w ould prevent the efficacious conduct of the review ?
If the safety review officer is an em p loyee of the relevant ind ustrial
undertaking, the proprietor or contractor should, as far as possible, only
require him to carry out w ork relating to conducting the safety review .
If it is not reasonably practicable to release the safety review officer from
other duties during the safety review , he should not be requested to take up
duties of a nature that w ould prevent the efficacious conduct of the safety
review , including those likely to give rise to a conflict of interest and
underm ine his im partiality as a safety review officer. H e should avoid
d uties that w ould overload him or cause und ue interrup tions to his
w ork as a safety review officer. For exam ple, if the safety review officer
is an in-house safety officer or safety ad visor, he should b e released
from the duties of a safety officer or safety advisor to avoid conflict of
interest and m aintain im partiality once he is appointed by the proprietor
or contractor as the safety review officer.
Safety Review
7.5 Action to be taken on safety review report
7.5.1 The proprietor or contractor to w hom a safety review report has been
subm itted under section 21 of the Safety M anagem ent R egulation shall
(a) read and countersig n the rep ort, and record the d ate of his
countersignature, as soon as practicable after receiving the report;
(b) if the report contains recom m endations for im provem ents to the safety
m anagem ent system to w hich it relates -
(i) draw up a plan for the im provem ents w ithin 14 days after receiving
the report; and
(ii) im plem ent the plan as soon as is practicable;
(c) if a plan referred to in paragraph (b) is draw n up, subm it a copy of the
report together w ith a copy of the plan to the C om m issioner w ithin 21
days after receiving the report; and
(d) keep a copy of the report and the plan, if any, for a period of not less
than 5 years after the d ate of countersig nature referred to in
paragraph (a).
7.5.2 (1) W hat should the proprietor or contractor do before countersigning the
safety review report ?
B efore countersigning the safety review report, the proprietor or
contractor, together w ith the m anagers affected by the findings of the
report, should seriously consider the safety review findings and the
recom m endations for im proving the safety m anagem ent system to see
if they have any questions for im m ediate clarification w ith the safety
review officer.
Safety Review
116
(2) H ow should the plan for im provem ents be ?
If the safety review report contains recom m endations for im proving
the safety m anagem ent system , the proprietor or contractor should
draw up a plan, in w ritten form and com plete w ith a description of
the rem ed ial m easures, resp onsib ilities, com p letion d ates and
rep orting req uirem ents, etc., for the im p lem entation of the
recom m ended im provem ents, w ithin 14 days after receiving the
report. In general, the plan should include the follow ing essential
com ponents
(a) Present situation
The present situation regarding the effectiveness of the safety
m anagem ent system in operation in the relevant industrial
undertaking should be defined as specifically as possible, based
on the safety review findings. This should be com pared w ith the
desired situation to find out how big the gap is.
(b) D esired situation
The desired situation regarding the effectiveness of the safety
m anag em ent system should b e d efined as sp ecifically as
possible, based on the recom m endations of the safety review
report. It w ill provide the standards for the industrial undertaking's
safety m anagem ent system to m easure up to.
(c) A ction plan
The action plan deals w ith how to m ove from the present situation
to the desired situation. It should be specific enough to be
m easurable and should answ er the questions of "w hat", "w ho"
and "w hen" in the process of upgrading the safety m anagem ent
system . M onitoring arrangem ents should be laid dow n in the
plan to ensure its effective and efficient im plem entation.
Safety Review
Safety Review
(3) H ow soon should the p rop rietor or contractor im p lem ent the
im provem ent plan?
The proprietor or contractor shall as soon as is practicable im plem ent
the plan draw n up to rectify the shortcom ings that exist in the safety
m angem ent system . H e should, in consultation w ith the safety review
officer, w ork out a priority list of actions so that situations w ith im m inent
risks are dealt w ith im m ediately and non-im m inent situations are dealt
w ith as soon as possible.
In any case, the proprietor or contractor shall subm it a copy of the
safety review rep ort tog ether w ith a cop y of the p lan to the
C om m issioner w ithin 21 d ays after receiving the rep ort. The
proprietor or contractor shall also keep a copy of the report and the
p lan, if any, for not less than 5 years after the d ate of his
countersignature. Follow -up m onitoring arrangem ents should be
established by the proprietor or contractor to ensure satisfactory
im plem entation of the plan for im proving the effectiveness of the
safety m anagem ent system .
118
Safety Review
7.6 Obligation to produce safety review report or plan for inspection
7.6.1 The proprietor or contractor shall at all reasonable tim es m ake available the
safety review report or plan for inspection by any occupational safety officer
w ho requests to see it. [Section 23(a) of the Safety M anagem ent R egulation]
7.6.2 The proprietor or contractor shall provide a copy of the report or plan, and/
or any docum ent w hich supports any m atter specified or referred to in the
report or plan not later than 14 days after receiving a w ritten request from
the C om m issioner to d o so. [S ections 23(c) and (d ) of the S afety
7.6.3 W hat is the docum ent w hich supports the m atter specified or referred to in
the safety review report or plan?
Such docum ents include records or other docum ents w hich:
(a) p rovid e evid ence on the d evelop m ent, im p lem entation and
m aintenance of the safety m anagem ent system ; and
(b) have been used by the safety review officer to support his safety review
findings and recom m endations. Som e exam ples of such docum entation
are listed out in Part 7.1.2(2) for reference.
7.6.4 A proprietor or contractor shall perm it an occupational safety officer to m ake
a copy of the safety review report or plan he requests to see. [Section 23(b)
1. Successful Im plem entation of W orks B ureau and H ousing A uthority H ealth and
Safety M anagem ent System s, 1998, O ccupational Safety and H ealth C ouncil,
H ong K ong
2. C ourse m aterials for safety auditor course, 1997, YH L International, Singapore
3. C ode for the establishm ent of shipyard safety m anagem ent system , 1995,
A ssociation of Singapore M arine Industries, Singapore
4. C ourse m aterials for B asic Safety A uditing C ourse, 1996, D N V Industry Pte. Ltd.,
1995, Singapore
5. G uidelines for the Establishm ent of Safety M anagem ent System at C onstruction
W orksites, 1995, Singapore C ontractors A ssociation Ltd., Singapore
6. C ourse notes of C onstruction C H A SE A uditor's course, H ealth and Safety
Technology A nd M anagem ent Ltd., 1995, U nited K ingdom
7. R isk assessm ent- A Practical G uide, 1993, Institution of O ccupational Safety and
H ealth, U nited K ingdom
8. C ourse notes of Safety A uditors Training Schem e, 1997, H ong K ong Polytechnic
U niversity, H ong K ong
9. B S8800:1996 G uide to occupational health and safety m anagem ent system s,
1996, B ritish Standards Institution, U nited K ingdom
10. H SC 6: W riting a safety policy statem ent: advice to em ployers, 1990 Edition,
H ealth and Safety C om m ission
11. Successful health and safety m anagem ent, 1997 Second Edition, H ealth and
Safety Executive, U nited K ingdom
12. H ealth risk m anag em ent: a p ractical g uid e for m anag ers in sm all and
m edium -sized enterprises, 1995 Edition, H ealth and Safety Executive, U nited
K ingdom
13. Five steps to inform ation, instruction and training, 1996 Edition, H ealth and Safety
Executive, U nited K ingdom
14. M anag em ent of health and safety at w ork: ap p roved cod e of p ractice:
M anagem ent of H ealth and Safety at W ork R egulations 1992, H ealth and Safety
Executive, U nited K ingdom
REFERENCES
120
15. Personal protective equipm ent at w ork: guidance on regulations: Personal
Protective Equipm ent at W ork R egulations 1992, H ealth and Safety Executive,
U nited K ingdom
16. Safety representatives and safety com m ittees, Third Edition, 1996, H ealth and
Safety Executive, U nited K ingdom
17. A S/N ZS4360:1995 A ustralian/N ew Zealand Standard on R isk M anagem ent, 1995,
A ustralia
18. ISO 14001:1996 Environm ental M anagem ent System s - Specification w ith
G uidance for U se, 1996, International O rganization for Standardization
19. ISO 14004:1996 Environm ental M anagem ent System s - G eneral G uidelines on
P rincip les, S ystem s and S up p orting Techniq ues, 1996, International
O rganization for Standardization
20. ISO 14010:1996 G uidelines for Environm ental A uditing - G eneral Principles, 1996,
International O rganization for Standardization
21. ISO 14011:1996 G uidelines for Environm ental A uditing - A udit procedures -
A uditing of Environm ental M anagem ent System s, 1996, International O rganization
for Standardization
22. ISO 14012:1996 G uidelines for Environm ental A uditing - Q ualification C riteria for
Environm ental A uditors, 1996, International O rganization for Standardization
23. O H SA S 18001:1999 O ccupational health and safety m anagem ent system s -
Specification
24. O H SA S 18002:1999 O ccupational health and safety m anagem ent system s -
G uidelines for the im plem entation of O H SA S 18001
25. O S H A R eg ulations (S tand ard s - 29C FR ), C om p liance G uid elines and
R ecom m endations for Process Safety M anagem ent - 1926.64 A pp C , 1993,
O ccupational Safety and H ealth A dm inistration, U nited States of A m erica
26. M anagem ent System s for Safety, Jerem y Stranks, 1994, Pitm an Publishing
References
27. Industrial Safety and H ealth M anagem ent, C . R ay A sfahl, Third Edition, 1995,
Prentice H all
28. Safety Engineering, Jam es C oVan, 1995, John W iley & Sons, Inc.
29. Safety A uditing - A M anagem ent Tool, D onald W . K ase/K ay J. W iese, 1990, Van
N ostrand R einhold
30. Safety M anagem ent System s, A lan W aring, 1996, C hapm an & H all
31. A nalyzing Safety System Effectiveness, D an Petersen, Third Edition, 1996, Van
N ostrand R einhold
32. M anaging O ccupational H ealth and Safety in A ustralia - A M ultidisciplinary
A pproach, M icheal Q uinlan/Philip B ohle, 1991, M acM illan Education A ustralia
Pty. Ltd.
33. C onstruction Safety M anagem ent, R aym ond Elliot Levitt/N ancy M orse Sam elson,
Second Edition, 1993, John W iley & Sons, Inc.
References
122
U SEFU L IN FO R M ATIO N
If you w ish to enquire about this C ode of Practice or require advice on occupational
safety and health, you can contact the O ccup ational S afety and H ealth B ranch
through :
Telephone : 2559 2297 (auto-recording after office hour)
Fax : 2915 1410
E-m ail : laboureq@ labour.gcn.gov.hk
Inform ation on the services offered by the Labour D epartm ent and on m ajor labour
legislation can also be found by visiting our H om e Page on the Internet. A ddress of our
H om e Page is http://w w w .info.gov.hk/labour.
Occupational Safety and Health Branch
Labour Department
1/2002-1-COP25

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CODE OF PRACTICE ON SAFETY MANAGEMENT 1

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