Professional Documents
Culture Documents
This document contains information that is confidential and proprietary to Holcim and is solely for the use of Holcim. No part of it may be circulated,
quoted, or reproduced for distribution outside Holcim without prior written approval from Holcim Corporate Occupational Health and Safety Project
Co-ordination Office. 2002
Table of Contents
OH&S POLICY
1.
INTRODUCTION
2.
PYRAMID ELEMENTS
2.1
10
2.2
11
3.
12
3.1
Summary of Intent
12
3.2
General Comment
12
3.3
Details
13
3.4
Auditor Evidence
14
4.
15
4.1
Summary of Intent
15
4.2
General Comments
15
4.3
Detailed Discussion
16
4.4
Additional Issues
22
4.5
Auditor Evidence
23
5.
24
5.1
Summary of Intent
24
5.2
General Comments
24
5.3
Details
25
5.4
27
5.5
Auditor Evidence
27
6.
PLANNED INSPECTIONS
28
6.1
Summary of Intent
28
6.2
General Comments
28
6.3
Discussion of topics
29
6.4
Auditor Evidence
32
7.
LEGAL OBLIGATIONS
33
7.1
Summary of Intent
33
7.2
General Comments
33
7.3
Details
33
7.4
Auditor Evidence
34
Page 3
8.
35
8.1
Summary of Intent
35
8.2
General Comments
35
8.3
Issues to be addressed
37
8.4
Emergency Planning
38
8.5
Management Review
40
8.6
Auditor Evidence
40
9.
42
9.1
Summary of Intent
42
9.2
Induction
42
9.3
Training
43
9.4
Training Review
44
9.5
Auditor Evidence
44
10.
45
10.1
Summary of Intent
45
10.2
General Comments
45
10.3
46
10.4
49
10.5
Auditor Evidence
50
11.
51
11.1
Summary of Intent
51
11.2
General Comments
51
11.3
Workplace Monitoring
51
11.4
Health Monitoring
52
11.5
Auditor Evidence
52
12.
53
12.1
Summary of Intent
53
12.2
General Comments
53
12.3
Details
54
12.4
Auditor Evidence
55
13.
56
13.1
Summary of Intent
56
13.2
Details
56
13.3
OH&S Manual
57
13.4
Records
58
13.5
Design Information
58
Page 4
13.6
Reporting
59
13.7
Auditor Evidence
59
14.
60
14.1
Summary of Intent
60
14.2
Task Analysis
60
14.3
Auditor Evidence
61
15.
62
15.1
Summary of Intent
62
15.2
General Comments
62
15.3
Inspection Topics
62
15.4
64
15.5
Auditor Evidence
65
16.
DESIGN SAFETY
66
16.1
Summary of Intent
66
16.2
General Comments
66
16.3
Details
67
16.4
Auditor Evidence
68
17.
69
17.1
Summary of Intent
69
17.2
69
17.3
69
17.4
Auditor Evidence
70
18.
OCCUPATIONAL REHABILITATION
71
18.1
Summary of Intent
71
18.2
Rehabilitation
71
18.3
Auditor Evidence
71
19.
PROCUREMENT
72
19.1
Summary of Intent
72
19.2
General Comments
72
19.3
Details
72
19.4
Auditor Evidence
73
20.
MANAGEMENT OF CHANGES
75
20.1
Summary of Intent
75
20.2
General Comments
75
20.3
Details
76
Page 5
20.4
Auditor Evidence
76
21.
77
21.1
Summary of Intent
77
21.2
77
21.3
Other Issues
77
21.4
Auditor Evidence
77
APPENDICES
A1
74
A2
89
A3
92
A4
OH&S Definitions
102
Page 6
OH&S Policy:
We provide healthy and safe workplaces by striving for zero risk to our
employees, contractors and visitors.
We apply OH&S standards and guidelines, provide the necessary
resources and training, and measure performance.
Page 7
1.
INTRODUCTION
U
The Holcim Executive Committee (Exco) has clearly stated as a goal that the Group companies
achieve accepted good practice with respect to Occupational Health and Safety (OH&S)
performance.
To achieve this goal a Holcim OH&S Pyramid has been established. The purpose of this
Pyramid, its elements (blocks) and associated documentation, is to indicate the key
requirements within each of these elements for establishing accepted good practice in OH&S
Management System performance.
Because of historical circumstances, companies in different countries have developed
approaches to OH&S management in different manners. It is important that any Group wide
OH&S Management System establishes clear guidelines regarding what must be achieved, so
that as a minimum requirement can be reached. However, at the same time, it is important that
the approach is not prescriptive, requiring companies to unnecessarily revise existing practices
and existing work and effort, i.e. the approach should be to indicate what must be achieved by
each Group company, but still leave the details of how they achieve it to them individually.
The purpose of this Handbook is to clearly establish the minimum level for the outcomes that
must be achieved for a site to achieve accepted good practice in OH&S management. This
document is structured in a manner so that for each of the elements within the Pyramid
P
AKNOWLEDGEMENT: Dr. W.G. Danaher of Risk Management Intercontinental (Brisbane, Australia) prepared the first version
of this Handbook. A multi-functional Working Group representing a cross-section of Holcim business units worldwide, led by
Ted Anderson, did subsequent versions.
Page 8
Legend
Health &
Wellness
Issues
Occupational
Rehabilitation
Roles
Responsibilities
and
Accountabilities
2.
Incident
Investigation &
Corrective Action
Hazardous Work
Activities
Management
of Changes
Procurement
Inspection
& Testing
Safe Working
Procedures
Induction
& Training
Implementation
isPlanned
planned
Design
Safety
Industrial
Hygiene &
Monitoring
Hazard
Identification
and Risk
Assessment
Audit and
System
Improvement
Employee
Communication
& Involvement
Planned
Inspections
Implementation
hasBegun
started
Fully
implemented
Information
& Reporting
Legal
Obligations
Management
Commitment
& Planning
PYRAMID ELEMENTS
The elements within the Pyramid are:
People Related:
Roles, Responsibilities and Accountabilities, Hazardous Work Activities
Hazard Identification and Risk Assessment, Induction and Training
Incident Investigation and Corrective Action, Safe Working Procedures,
Occupational Rehabilitation
Process Related:
Industrial Hygiene and Monitoring, Planned Inspections
Audit and System Improvement, Inspection and Testing
Management of Changes, Design Safety, Procurement
Management Related:
Management Commitment and Planning, Legal Obligations
Employee Communication and Involvement, Information and Reporting
A Link to CSR:
Page 9
2.1
Health &
Wellness
Issues
MANAGEMENT
Occupational
Rehabilitation
Procurement
Legal
Obligations
Employee
Communication
& Involvement
Safe Working
Procedures
Design
Safety
PROCESS
PEOPLE
Information
& Reporting
Management
Commitment
& Planning
Induction
& Training
Roles
Responsibilities
and
Accountabilities
Incident
Investigation &
Corrective
Action
Hazardous
Work
Activities
Hazard
Identification
and Risk
Assessment
Inspection
& Testing
Industrial
Hygiene &
Monitoring
Management
of Changes
Planned
Inspections
Audit and
System
Improvement
The initial assessment of any Group company OH&S management system against the pyramid will
identify where the areas with the most improvement possibility exist. Addressing these can then be
prioritized on the basis of a risk assessment to decide which have the biggest potential threat to
control/opportunity to realize. In general terms, lower blocks in the three subdivisions should be
addressed at the same time and are likely to need to be dealt with before those higher up.
Page 10
2.2
The overall objective of implementing all of the blocks within the Holcim OH&S Pyramid is to provide an
OH&S Management System that is capable of delivering healthy and safe workplaces. This is
measured against the Targets for OH&S performance and, when all the blocks of the Pyramid are fully
implemented, this will be evidence of the application of OH&S standards and guidelines, provision of
the necessary resources and training, and measurement of performance. Individual Group companies
will grade their accomplishment in relation to each Pyramid block according to the scale. This grading
will be verified:
PT
Any company that cares about it's people and the management of health and safety in all its forms will
likely not only become an employer of choice, but also enhance it's reputation with it's stakeholders.
Hence, Group companies must be able to demonstrate that their activities are being conducted in such
a way as to provide healthy and safe workplaces while striving for zero risk to employees, contractors
and visitors.
TP
1
PT
eg. The Holcim Group OH&S Co-ordinator - Other Group company OH&S Co-ordinator - Other 3rd party - Or a
Page 11
3.
3.1
Roles, Responsibilities
and Accountabilities
Summary of Intent
Each Group company must ensure that appropriate organizational structures are put in place to
manage OH&S, and there is an appropriate allocation of responsibility and accountability to all
personnel within the organization to ensure successful functioning of the OH&S Management
System.
Group companies must maintain, as a basic principle, that their activities will be conducted in
such a way as to provide healthy and safe workplaces, and to strive for all operations to expose
employees, contractors and visitors only to levels of risk that are as low as reasonably
achievable.
Management commitment is an integral part of establishing an OH&S Management System.
One way in which management commitment can be demonstrated is through appropriate
organizational structures, and allocation of responsibility and accountability to key personnel
within the organization.
This element of the Pyramid addresses such matters, and addresses also the importance of
including annual review of OH&S management performance as part of each employees
performance review; eg. including it in employee Dialogue or the equivalent local Personal
Performance Management Program.
3.2
General Comment
Effective OH&S management occurs if persons at all levels within an organization are seen to
be responsible for relevant aspects of OH&S management. Therefore, it is expected that:
Page 12
Roles, Responsibilities
and Accountabilities
Details
Responsibility and Accountability System
Modern OH&S legislation is written such that obligations or duties of care are placed upon all
persons at a workplace. The system establishing OH&S responsibility and accountability; eg.
position descriptions, for all these persons should reflect the fact that everybody has some
responsibility for OH&S.
It is important that all personnel at all levels have defined responsibilities and accountabilities
for OH&S. Items that should be addressed include:
Legislative requirements;
Reporting requirements; and
Levels of authority.
Note: OH&S is not the responsibility of the OH&S Department or the OH&S coordinator. The
role of the OH&S Department or the OH&S coordinator/Officer is to provide guidance and
advice about OH&S matters. The discharge of OH&S responsibilities and the undertaking of
actions necessary to ensure OH&S at a workplace is the responsibility of all persons delegated
through the management structure at that workplace.
Performance Appraisal
Management should also evaluate the effectiveness of the performance of persons with
specific allocated responsibilities for OH&S. This evaluation of performance should be no
different to the evaluation that occurs with respect to performance in all other aspects of any
persons responsibilities.
Page 13
Roles, Responsibilities
and Accountabilities
Auditor Evidence
The following information will be sought as part of an audit.
Page 14
4.
4.1
Hazardous Work
Activities
Summary of Intent
This element has been included as one of the building blocks of the Pyramid because the
activities addressed by this element are those where there is potentially the greatest risk for
fatality or permanent disablement. The content of this element indicates the types of issues
that should be addressed, and the structures and systems that should be in place to ensure
that work permit systems are implemented and functioning effectively.
As a matter of priority, any organization serious about managing OH&S must address
the control of those areas or work practices in which there is potential risk for a fatality
or permanent disablement to occur. Work permit systems are the way to achieve this
control.
Hence the aim of this element is to ensure that the organisation has in place the systems
necessary
General Comments
The basic purpose of a work permit system is to ensure that a higher level of checking and
control is applied to particular work activities and work practices. A work permit system aims to
provide an independent check and assessment of particular work activities to ensure that
suitable risk controls are in place.
The requirement for issuing work permits may require an assessment of risk, and therefore this
element links to Hazard Identification and Risk Assessment.
For Holcim sites, it is expected that a system of work permits will be in place for the following
activities:
Page 15
Hazardous Work
Activities
Use of explosives
Kiln light up
Traffic and road OH&S
These activities will not require a work permit system, but will have Standard Work Procedures
(and Practices) that ensure that a higher level of checking and control is applied to them.
These lists above should not be considered exhaustive, and individual sites may have further
specific requirements that they include as well.
4.3
Detailed Discussion
Confined Space Entry
A confined space may be defined as an enclosed or partially enclosed space which
a) Is at atmospheric pressure during occupancy, and
b) Is not intended or designed primarily as a place of work, and
c) Is liable at any time to
Page 16
Hazardous Work
Activities
regarding the confined space entry system and their responsibility for issuing
confined space permits. Training and refresher training should be provided.
Personnel who are required to work within confined spaces should be trained
regarding the requirements of the permit system, and their responsibilities as
workers within a confined space. The training should include how particular
hazards identified with the tasks to be performed within the confined space
have been controlled. Training and refresher training should be provided.
A rescue capability should be in place to ensure that personnel who may be
trapped in a confined space can be rescued. Training should be provided to all
personnel who are or may be required to effect rescues within confined spaces.
This training should include use of breathing apparatus where this control is
determined necessary by the Risk Assessment process. Suitable rescue
equipment should be available. Training and refresher training should be
provided.
Control of Ignition Sources
The site should develop and implement a permit system to control ignition sources based upon
relevant international standards and practices. (Such a permit is often called a Hot Work
permit). This system must also take account of the requirements of the Alternative Fuels &
Raw Materials (AFR) Health & Safety Manual.2 As a minimum, the following should be in
place:
TP
PT
A written Control of Ignition Sources permit system and associated forms. This
system should identify those circumstances where gas testing is required as
part of permit issue.
The site should identify and document those circumstances/locations where
Control of Ignition Sources permits will be required; eg. Flammables,
combustibles, coal, coal dust, oil, gas and all other fuels.
Specific personnel should be authorized by site management to be responsible
for issuing Control of Ignition Sources permits. These personnel should be
trained regarding the Control of Ignition Sources permit system, and their
responsibility to issue Control of Ignition Sources permits. Training and
refresher training should be provided.
Personnel who are required to work under Control of Ignition Sources permits
should be trained regarding the requirements of the permit system, and their
responsibilities as workers. Training and refresher training should be provided
All personnel who are required to do 'Hot Work'; eg. welding, cutting, brazing,
etc must be competent and possess an appropriate qualification.
Suitable fire fighting equipment must be available onsite; eg. fire barriers, fire
screens (non-combustible), fire extinguishers, hose reels, foam, water, etc
A systematic program must be in place for testing fire fighting equipment
Personnel must be trained and retrained in the use of fire fighting equipment
TP
2
PT
albert.tien@holcim.com
Page 17
Hazardous Work
Activities
The site should develop and implement an excavation and digging permit
system.
Specific personnel should be authorized by site management to be responsible
for issuing excavation permits. These personnel should be trained regarding
the excavation permit system and their responsibility for issuing permits.
Training and refresher training should be provided.
Reference to site plans prior to undertaking excavation will be required as part
of the permit issue system
There must always be alternative access provided for persons who have to
cross the excavated area.
Entering Excavations
In addition to the excavation permit system discussed above, the site must also implement a
system for protecting persons entering excavations where there is potential for collapse of
walls.
Ideally this will involve a separate entry permit or equivalent system. It is essential that a
competent person inspects an excavation prior to persons entering that excavation. If
necessary, risk controls must be put in place to prevent the walls of the excavation collapsing.
In keeping with good risk management practice, attempts must be made to design the walls of
excavations in such a manner so that the potential for collapse is minimized (eg. angled walls
rather than vertical walls). Persons required to enter excavations must be trained with regard
to the content of this aspect of the Management System.
High Voltage Work
The definition of high voltage is as given by the local electrical authority but will always include
sub-station and/or plant distribution voltages. A permit system must be in place to manage
associated risks. As a minimum the following is required:
Page 18
Hazardous Work
Activities
Personnel who are required to work under high voltage permits should be
trained and retrained regarding the requirements of the permit system and their
responsibilities as workers
Personnel operating on high voltage electrical equipment must be suitably
licensed with respect to local or international regulations. Such licenses must
be kept current and an inspection system to ensure that they are must be in
place.
Suitable OH&S equipment must be provided and maintained, and personnel
trained and retrained in its use
Lockout and Isolation
Personnel may suffer severe injuries if equipment is energized at the time that work is being
undertaken on, or in the vicinity of, the equipment. Therefore, formalized isolation and lockout
procedures are required. As a minimum, the site must ensure:
That a documented lockout and isolation procedure is developed for the site.
(This procedure may also include requirements for tagging of equipment.)
Unless totally impracticable, lockout and isolation points for key items of
equipment must be identified and documented. If necessary, retro-fitting must
occur
Specific personnel are to be authorized by site management to be responsible
for issuing lockout / isolation permits. These personnel should be trained
regarding the operation of the permit system and their responsibility for issuing
work permits. Training and refresher training should be provided.
It should be noted that the accepted international good practice requirement is that there has to be the
ability to physically lock out and isolate equipment, not simply to rely on protection of any worker by
means of an advisory tagging procedure.
Working at Heights
Work at heights greater than 1.8 meters
While not a formal requirement under a work permit system, it is now internationally considered
good practice that any persons working at a height where they could fall 1.8 meters or more
wear fall arrest equipment. Note that this specifically refers only to those situations where
persons are not protected by handrails, scaffolding, etc.
Therefore the site must ensure that there is a system in place to provide protection for those
persons who may fall a distance of >1.8 meters. This will require those personnel to be
provided with protection or suitable fall arrest equipment. Where fall arrest equipment is
provided, the persons using the fall arrest equipment must be trained and retrained in its use.
In addition, the fall arrest equipment must be subject to inspection by a competent person on a
regular basis, and whenever a fall arrest system is used, there must be a system in place to
retrieve a person who has fallen in less than 5 mins.
Page 19
Hazardous Work
Activities
Where it is decided to provide other forms of protection, eg. scaffolding, then the person
erecting or providing that form of protection must be competent. Records of the necessary
competency should be available.
Hazardous Material Handling (incl. radioactive Sources)
Hazardous materials may be used in a variety of applications at the site. As such, there is the
potential for exposure of personnel to the material, should appropriate controls not be in place
or fail. This system must also take account of the requirements of the AFR Health & Safety
Manual.3 Therefore, the following is needed:
TP
PT
Each site to identify applicable local legislation and standards, and ensure that
there is a mechanism in place for remaining up-to-date with respect to changes
to that legislation.
Specific personnel should be authorized by site management to supervise
hazardous material handling. This includes a qualified person who is named
as taking overall responsibility for this (It is noted that this is not seen to be a
separate job, but simply a formal responsibility that may be applied to a suitably
skilled person at the site). These personnel should be trained regarding the
permit system, and their responsibility for issuing work permits. Training and
refresher training should be provided.
Personnel who are required to work with hazardous materials should be trained
and retrained regarding their responsibilities as workers in the safe handling of
hazardous materials.
Suitable emergency response systems must be in place to deal with an
emergency incident involving a hazardous material.
Mineral Fiber Materials
A particular group of hazardous substances are mineral fiber materials (MFM's). This includes
materials containing asbestos as well as those consisting of synthetic mineral fibers.
Synthetic mineral fibers (SMF's) are manufactured materials and include glass fiber and wool,
mineral wool (eg. rockwool, slagwool, kaowool) and ceramic fibers. SMF's can irritate the skin,
eyes, nose and throat, and cause itching, sneezing and coughing. The International Agency for
Research on Cancer (IARC) classifies ceramic fibers, glasswool and rockwool as possible
human carcinogens. Asbestos is a natural mineral fiber, which was used extensively in building
work and insulation during the 1950s, 60s and early 70s. It is now only used rarely4 in some
few applications such as friction materials like brake linings and gaskets. Asbestos is
hazardous because its dust contains tiny fibers that can be breathed in and lodge in lung
tissue. These have been found to cause diseases including asbestosis and mesothelioma, a
cancer that is usually fatal. Such diseases can take from 10 to more than 30 years to develop
after exposure to the fibers has ceased.
TP
TP
PT
TP
4
PT
PT
albert.tien@holcim.com
IMPORTANT NOTE: The use of asbestos has been banned in Holcim Group.
Page 20
Hazardous Work
Activities
Those who may be at risk from exposure to MFM's include asbestos removalists, demolition and
construction workers, operators of plant and equipment, trades people, laborers, office workers and
householders when they live in, work in or work on buildings, plant or equipment containing any MFM's.
The general requirements for managing hazardous materials given above apply and, in addition, to
manage any special risks from MFM's, each Group company OH&S coordinator must:
More information on MFM's as well as information on good practices in managing them can be found on
SafetyNet https://web.holcim.com/safetynet/
HTU
UTH
UTH
Piping, guttering/other associated roofing components and wall sheeting/other associated wall
components that are manufactured from asbestos-cement should be dealt with in the same
way as AC sheeting.
IMPORTANT:
TP
5
PT
See Appendix A1
Page 21
Hazardous Work
Activities
Each site to identify applicable local legislation and standards, and ensure that
there is a mechanism in place for remaining up-to-date with respect to changes
to that legislation.
Site management must ensure that position descriptions reflect responsibilities
for the storage, handling and management of explosives.
Documented site procedures must be in place for
Receival of explosives,
Storage of explosives,
Additional Issues
In addition to the formal work permit systems documented above, it is necessary for the site to
develop formal OH&S Management Systems/ procedures for dealing with the following
activities.
Kiln Light Up / Coal Mill & Coal Dryer Start-Up
Documented Safe Working Procedures (SWPs) must be in place for dealing with risks
associated with kiln light up as well as coal mill and coal dryer start-up. These SWPs will be
developed based upon hazard identification and risk assessment of all kiln start activities. All
personnel involved in kiln start-up must be trained and retrained regarding the content of the
procedures and a record of this training maintained.
Page 22
Hazardous Work
Activities
Auditor Evidence
Specific requirements in relation to work permit systems have been noted in section 4.3 above.
These effectively establish audit requirements, and an auditor would expect to sight evidence
that all of these issues have been implemented.
Page 23
5.
5.1
Hazard Identification
and Risk Assessment
Summary of Intent
Hazard identification and risk assessment are key building blocks of modern OH&S
Management Systems. From a legal point of view, OH&S legislation often specifies that
organizations must undertake risk assessments on the tasks and conditions existing in their
workplaces.
From a practical point of view, hazard identification and risk assessment provides the
opportunity to be proactive and to identify situations in the workplace that could cause injury or
illness, and deal with those situations before their consequences occur.
This guideline provides a lengthy discussion of hazard identification and risk assessment, and
also a simple methodology that can be used to perform this activity.
5.2
General Comments
Modern OH&S management legislation frequently spells out the need for a risk-based
approach to managing OH&S in the workplace. This approach requires that hazards are
identified, risks are analyzed and evaluated, and strategies put in place for effectively managing
and monitoring those risks.
A comprehensive approach to OH&S Risk Management must be implemented within the
organization to ensure that OH&S management goals are achieved, including:
Page 24
Hazard Identification
and Risk Assessment
Examples of hazards or circumstances for which risk assessment is expected to be required include,
but are not limited to:
5.3
Noise
Vibration
Dust / silica
Hazardous substances
Manual handling
Ergonomics
Human factors
Electrical
Communicable diseases
Crane operations
Coal dust
Hazardous substances
Confined spaces
Radiation
Biological hazards
Mobile plant and equipment
Fixed plant and equipment
High pressure
High temperature
Working at heights
Falling objects
Excavations
Hand tools
Plant rescue requirements
Introduction of new equipment
Changes to procedures
(NOTE: See the blocks
Design Safety, Purchasing, and
Management of Changes
Details
Hazard Studies
A number of different approaches are available for the management of OH&S at any site. One
area, which must be addressed, is identification and management of hazards intrinsically
associated with the process. Therefore, a formal Process Hazard Analysis (PHA) should be
undertaken and documented and recommendations made for control of risk.
Types of techniques that may be applicable to such an analysis include:
Risk assessment
HAZOP/HAZAN
What if? analysis
Failure mode and effect analysis
Fault tree analysis
Event tree analysis
It is expected that:
A multi- functional/disciplinary team will undertake any PHA done and that a
formal report will be issued;
The PHA should be subject to regular review; and
Hazard studies / risk assessments are undertaken on all operational and
maintenance activities.
Page 25
Hazard Identification
and Risk Assessment
Key issues to be considered by those who own and operate plants include:
Risk management
Design and construction
Positioning of plant in the workplace
Operation
Damaged plant
Dismantled/stored plant
Plant with moving parts
Powered mobile plant
Electrical plant and plant exposed to
electrical hazards
Industrial lift trucks
Industrial robots
Air conditioning units
Auditing
Inspection
Servicing
Maintenance
Repair
Modification
Cleaning
Disengaged and stored plant
Transporting plant
Lighting
Ventilation mists, fumes and dusts
Wear corrosion and damage
Information provision
Instructing workers
Training workers
Supervising workers
Safe work practices
Competency
Consultation
Records
Operating Procedures
Written operating procedures, which specify key information for operations personnel, should
be provided at the site. These assist personnel to manage OH&S by setting clear standards for
operational practices. Operating procedures should provide plain instructions for safe
operation of the facility and be consistent with the hazard identification and process OH&S
information available.
Operating procedures should address the following:
Initial start up
Normal operation
Normal shutdown
Start up following a shutdown or turnaround
Emergency operations, including emergency shutdown
Any temporary operations
Operating procedures should also provide information on operating limits and where a deviation
from normal operations could have OH&S consequences, the following should be provided:
Properties of, and hazards presented by, materials used in the process
Special precautions required to prevent exposure to materials
Control measures to be undertaken if physical contact or airborne exposure
occurs
Any special or unique hazards.
Operations procedures provide a description of operation of the plant and facility at a particular
time. Over time, plant modifications will occur and operator understanding of key plant issues
will also change. Therefore, operating procedures may need to be modified and updated to
Page 26
Hazard Identification
and Risk Assessment
reflect these changes. Thus a system must be in place for ongoing review of the effectiveness
of operations procedures and modifying and updating operations procedures, as required.
5.4
Auditor Evidence
The Audit will seek evidence of:
Hazard identification
Risk assessment
Implementation of risk controls
Review of effectiveness of risk controls
Any audit will also normally assess mechanisms in place for reviewing,
updating and improving operating procedures.
Page 27
6.
PLANNED INSPECTIONS
6.1
Summary of Intent
Planned Inspections
Simple planned inspections can be undertaken even in the absence of fully implemented OH&S
Management Systems. These inspections are useful to quickly identify deficiencies and
hazards in the workplace.
The inspections discussed in this section are those that can easily be undertaken by any
worker, eg. housekeeping, presence/absence of machinery guarding, etc. In section 15 of this
Handbook, those inspections requiring a high level of expertise are considered, eg. pressure
vessels/relief valves.
Undertaking regular inspections of key areas or aspects of a workplace is an important part of
effective OH&S management. Planned inspections allow a regular checking of key features of
the workplace, and ensure that appropriate risk controls are in place. Planned inspections may
be carried out even if the more comprehensive aspects of an OH&S Management System are
not in place.
When deficiencies and hazards have been identified, a properly operating corrective action
system ensures that they are eliminated or controlled. This block provides guidance on the
types of planned inspections that should be undertaken.
6.2
General Comments
Planned inspections may be applied to a range of different areas and activities within the
workplace. These include the various topics listed in the table below. Each site should
determine those topics for which planned inspections are required. This may require Planned
Inspections in addition to those listed below.
Guards
Access
Storage practices
Refuse disposal
Gas cylinder storage
Personal protective equipment
Color coding
Signage
Material OH&S Data Sheets
Handrails
Workplace Amenities
Housekeeping
Breathing apparatus
Ladders
Hygiene and sanitation
Refuse storage
Hand tools
Mobile plant and equipment
OH&S equipment
Labeling of critical equipment
Chemical storage (Including flammables and
corrosives)
Stairs
Eyewash Stations and Safety Showers
Certification & Licenses
Training is current/up to date (according to
Training Master Plan)
Lifting equipment
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6.3
Planned Inspections
Discussion of Topics
In the sections below, each of the inspection topics is briefly discussed in order to indicate their
role and purpose. The list is not expected to be comprehensive and each site should add local
requirements.
Guards
Providing guards, where required, is an important way of protecting employees from injury.
The requirement for guarding is likely to be determined by local legislation and applicable
Standards or Codes. A register of items of equipment requiring guarding should be developed,
including specific details relating to guards and, if appropriate, numbering of guards. The
person undertaking the inspection is then able to identify whether the guard is in place and in
good condition and, if necessary, make recommendations for further action.
Ladders
Ladders, stairs, and walkways are generally addressed either directly by legislation or by
appropriate Standards and Codes. Details of all portable ladders should be recorded including
their location. It is recommended also that each ladder be numbered for easy reference.
Access Inspection
This inspection is aimed at checking and making recommendations regarding access in various
areas within the workplace. Access is essentially a housekeeping item. However, many
incidents occur in workplaces because there is inadequate access. Where key problem areas
are known these should be included on the inspection form to ensure that when an inspection
for quality of access is undertaken those particular areas will be inspected.
Hygiene and Sanitation Inspection
This inspection aims to address hygiene and sanitation issues within the workplace. Therefore,
the types of issues to be addressed by the inspection include cleanliness of wash-up and
shower areas, toilets, restrooms, and lunchrooms. Each relevant area should be listed and
when the inspection is undertaken problems and recommended actions should be identified. If
the workplace has a specified first aid area or first aid room, this should also be inspected.
Storage Practices Inspection
The purpose of this inspection is to ensure those areas where materials are stored are
inspected and checked for good storage practices. Issues, which may be addressed by this
inspection, include storage of materials in work areas and also warehouses. The inspection
should also address the suitability and adequacy of stacking practices.
Refuse Storage and Disposal Inspection
This inspection relates to good housekeeping practices by focusing on storage and subsequent
disposal of refuse. The inspection can be used to check that materials are placed appropriately
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Planned Inspections
into bins and that bins are emptied at regular intervals. Therefore, the location of the key waste
storage and waste bin areas should be identified. It is noted that in some circumstances
different types of bins will be required for different types of materials eg. paper, glass,
chemicals etc. Where different types of bins are used, each should be separately identified.
Hand Tool Inspection
Many accidents occur in workplaces because persons use faulty tools and equipment. The
purpose of this survey is to inspect all key hand tools and ensure that they are fit for use.
Generally, the responsibility for completing the inspection will fall to the person who has
responsibility for the day-to-day use of the hand tool, or sometimes their supervisor to check
the adequacy of the inspections being undertaken.
Gas Cylinder Inspection
The purpose of this inspection is to identify the different types of gas cylinders present at a
worksite and their storage locations. The inspection enables identification of cylinders that
have been present in a particular location for an extended period of time and those that are in
need of maintenance attention and action.
Mobile Plant and Equipment Inspection
Because of the energies involved there is potential for serious incidents associated with mobile
plant and equipment to occur. Therefore, this inspection requires that all items of mobile plant
and equipment are identified and their usual location specified. The inspection then requires
that each item of equipment is inspected for suitability for continued operation and any
problems and associated recommendations are noted. These inspections may include daily
pre-start checks and regular maintenance inspections.
Personal Protective Equipment Inspection
As noted in a later section, personal protective equipment is one key strategy for protecting
employees from OH&S risks. However, PPE will be effective only if it is appropriately
maintained. This inspection enables an inventory of PPE to be developed, the various
locations to be identified and particular problems and recommended actions to be specified.
Generally each employee should have responsibility for his or her own protective equipment.
Safety Equipment Inspection
As well as personal protective equipment and fire fighting equipment there may be other
specified items of OH&S equipment present at a workplace. The purpose of this inspection is
to create an inventory of such equipment and its location and also to specify testing
requirements and confirm that tests have been undertaken. Depending upon the nature of the
equipment there may be applicable Standards or Codes specifying test intervals.
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Planned Inspections
Page 31
Planned Inspections
Auditor Evidence
An audit will check
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7.
7.1
Legal Obligations
LEGAL OBLIGATIONS
U
Summary of Intent
It is essential that each site satisfies legal obligations and complies with relevant legislation. It
is expected that if all the other elements in the Pyramid are fully addressed, then legal
compliance should in most cases be in place, since there is a commonality within OH&S
Management Systems and OH&S legislation.
Nonetheless, this element provides the opportunity for confirmation that all compliance
objectives have been met, and also requires that each Group company has in place a
mechanism for identifying changes to legislation, and ensuring that the impact of those
changes is assessed and implemented at each site.
7.2
General Comments
This element requires that each site establishes and maintains a procedure to identify and have
access to current legal and other requirements that are applicable to the site.
Compliance with relevant legislation and/or regulations must be fully achieved. This block
requires that Group companies have in place a mechanism for:
Details
Some of the issues that need to be considered include:
How the site accesses and identifies relevant legal and associated
requirements, e.g, legislation, Standards, Codes.
How the site addresses/complies with these legal and other requirements.
How the site monitors changes to legal and other requirements.
How the site communicates relevant information on legal and other
requirements to people working there.
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Legal Obligations
It is noted that the regulatory requirements applicable to a sites activities, products or services
may exist in several forms. Examples include:
Auditor Evidence
An audit will seek evidence of:
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8.
8.1
Summary of Intent
To be effective, an OH&S Management System requires the participation and support of all
sections of an organization. Gaining this commitment requires senior management to
demonstrate a corporate commitment through leadership and allocation of resources.
Management commitment and planning must manifest itself within policies and targets adopted
by Group companies.
General Comments
This element is considered to be a key element within the Holcim OH&S Management System.
Effective attention will not be given to the management of OH&S and implementation of OH&S
management initiatives unless there is demonstrated by management a demand for, and
commitment to, achieving good OH&S management.
The types of issues to be addressed as part of management commitment include:
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GC Exco Member
GC OH&S
Co-coordinator
GC and/or
Business Unit
OH&S Committee
Person
responsible for
OH&S in a
Business Unit
Informs
This model is recommended for effective and efficient OH&S structure and staffing, however
local legal requirements may mean there is a variation in a Group company.
Other issues to be considered as part of management commitment include:
Each operating site with 80 or more FTE employees should have a person
responsible for the function of providing OH&S support. A risk assessment is
required to decide how sites with less than 80 employees are to be provided
with OH&S functional support, and how much time should be allocated to
perform the function at a site.
Specification of responsibilities of all persons within the organization, with
respect to management of OH&S.
Structures for communication of OH&S information within the organization.
Structures for consultation within the workplace.
Commitment of sufficient financial resources towards the achievement of
OH&S management goals.
Review of OH&S management performance.
The need to be able to respond to emergency situations is also a fundamental part of any
OH&S Management System. Emergency planning is closely allied to hazard identification and
risk assessment, because it is through the hazard identification that it is possible to identify
where emergency plans are needed (See 8.4).
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8.3
Issues to be addressed
OH&S Policy
Company management, in consultation with workers, must develop an OH&S policy. This
Policy should embody the requirements of local legislation as well as the key aspects of the
Holcim OH&S Policy. The policy should be signed by the Chief Executive or Company
Manager, as appropriate, and be reviewed on an annual basis. This policy:
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Input from site personnel (via the OH&S Committee or local equivalent)
Focus on key hazards and risks
Linkage to requirements of legislation
Linkage to incidents that have previously occurred.
8.4
Emergency Planning
An effective risk management program aims at preventing the occurrence of incidents likely to
pose a significant threat to individuals or operations. Nevertheless, it is possible that such
incidents, including natural disasters, may occur and therefore an effective Emergency Plan
needs to be in place - See Appendix 3 for an example.
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General Comments
As a minimum, the following is required:
Identify the different types of emergency scenarios that could occur, eg. fire,
explosion, natural events, bomb threat, terrorism, etc.
Identify the types of consequences that are likely to emerge from such
incidents and also identify the emergency response measures that will be
needed to minimize the impact of those consequences.
Emergency planning follows naturally from risk management. Risk
management aims to identify risks and control them so that undesired
situations do not occur. Emergency planning and emergency response plans
attempt to minimize the consequences of those undesired situations when they
do occur.
Content
A well-constructed emergency plan should contain the following:
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Actions, involving specified personnel, which are required to deal with different
emergencies (an emergency plan may have several pages containing identified
scenarios and specific responses).
A list of contact phone numbers for emergency services, doctors, staff,
contractors etc. to be called in out of hours, suppliers of emergency equipment,
Government officials etc.
A list of emergency response equipment on-site and its storage location.
Identification of an emergency control room or point if that is appropriate.
A collection of relevant information that may be needed in an emergency, eg.
drawings, registers of chemical storage, etc.
Testing Emergency Plans
To be effective an emergency plan must be tested on a regular basis. Testing of emergency
plans should be documented and after each test, the results should be reviewed in order to
identify the types of improvements that can be made to the emergency response strategy.
Workplace circumstances may change and render the contents of an emergency plan
ineffective. Therefore, regular reviews are needed to ensure that changes are incorporated into
the plan and that the plan is reviewed at regular intervals.
Document Control
It is critical that at the time of any emergency, the Emergency Plan in place is current and is
therefore able to be effective in dealing with the emergency. Therefore, an Emergency Plan
should be a controlled document and those personnel participating in the plan or in need of an
understanding of the plan, should be part of a formal distribution list for the Plan.
8.5
Management Review
There must be a senior management review within each Group company of the OH&S program
on an annual basis. Although it is expected that OH&S performance and the OH&S program
will be reviewed at several levels, including the OH&S Committee, senior management must do
so, in recognition of their overall responsibility for OH&S management. They should:
Auditor Evidence
The following will be considered:
Page 40
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9.
9.1
Summary of Intent
The basis for any program aimed at the prevention of risk exposures or accidents is to cultivate
a culture of OH&S awareness, and to provide each person with the skills and knowledge
necessary to ensure that they work in a safe and healthy way.
This block establishes the need for all workers at Group company workplaces to receive a
systematic set of courses containing a series of guidance, instruction, schooling and
assessment that is given:
Induction
OH&S induction training for new employees is an important aspect of a site OH&S
Management System. Every new employee or a current employee working at a site or in an
area for the first time should undergo induction training.
The content of the induction training will depend on the circumstances, the type of work the
person is undertaking and the hazards to which they are likely to be exposed.
The elements that are common to most OH&S induction programs are:
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They should also receive a more detailed OH&S induction from their supervisor, manager, or
team leader on the job that relates specifically to the hazards that they are likely to encounter in
their area of work. Receipt of induction training should be recorded and it is important that
persons who have received induction training are able to undertake refresher training later.
It is also important for a site to review the content of its OH&S induction training from time to
time because as development occurs and processes change, the types of hazard that may
exist in a particular area of the workplace may also change.
9.3
Training
Training is complementary to the notion of including OH&S responsibilities in position
descriptions. Often many of the incidents that occur result from inadequate training.
The types of issues that need to be considered in identifying training needs are:
Occupation types.
OH&S issues.
Tasks within occupations.
Critical tasks within occupations.
Literacy and language
The following issues should be addressed:
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9.4
Training Review
It is important also that management tests and evaluates the effectiveness of the induction and
training program. This can be done in a number of ways:
Auditor Evidence
The following information will be sought as part of an audit:
New employees
Contractors
Visitors
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10.
10.1
Incident Investigation
and Corrective Action
Summary of Intent
In any organization incidents will continue to occur, and it is important to learn from them. A
proper incident investigation system will permit identification of the root cause, contributory
factors and system deficiencies in each particular case. It will also permit control of these
causes to help prevent any similar incidents recurring.
An additional requirement for reporting and sharing of critical information between Group
companies is established in this block.
It is fundamental to any improvement methodology that a corrective action system is in place in
order to distil lessons learned from any mistakes or hazards found, and then correct identified
deficiencies, and realize any identified opportunities for improvement.
In order for a site to
General Comments
Incidents are unwanted occurrences for any organization. An incident may not necessarily
result in damage or injury, but may be a near hit.
However, the occurrence of an incident provides the opportunity for identifying root cause,
contributory factors and system deficiencies and making changes to Management Systems and
work practices to prevent such an incident occurring again. Other elements of the OH&S
Management System, eg. hazard identification and risk assessment, attempt to take a
proactive approach to OH&S management and identify those circumstances that could lead to
incident or injury. Incident investigation, however, takes a predominantly reactive approach
and attempts to learn lessons from incidents that have occurred.
This particular element is included as one of the basic elements of the Holcim OH&S
Management System, because it is considered that any site, irrespective of the overall OH&S
Management Systems that are in place, should be capable of investigating incidents and
putting remedial measures in place.
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Incident Investigation
Corrective Action
It is also important that a robust incident investigation system is in place, so that relevant
statistical data can be accumulated to provide a better indication to a site of their OH&S
management performance. Formal incident investigation procedures should be in place for
investigating process-related incidents such as high temperature excursions, overfilling of bins,
silos etc.
Further, formal procedures should be in place to investigate incidents such as injuries, near
hits/misses, damage, substandard conditions, substandard practices, defects in plant and
equipment, hazards, illness, disease and any other matters of interest.
Investigation procedures should seek to determine the immediate and root cause, contributory
factors and system deficiencies, and develops remedial actions for preventing the same or
similar events occurring in the future. Managers and supervisors should be trained and
retrained in incident investigation procedures.
10.3
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Incident Investigation
Corrective Action
Incident Reporting
Documented procedures should be in place for reporting
Injuries
Note: An important part of this is SafetyAlert, the Critical Incident Reporting
System that has been established. All Fatal and Permanently Disabling
Injuries must be reported on this as soon as they occur.
Illnesses
Property damage
Near hits/misses, eg. person nearly struck by a falling object
Hazards
Defects
Undertaking Incident Investigation
Each site should develop and implement specific procedures or strategies for undertaking
incident investigation. However, any good incident investigation procedure should address the
following issues:
1) Identification of what happened
It is important that incident investigation identifies in a factual manner what happened. This
phase of incident investigation is not involved in determining causes or remedial action but is
merely concerned with obtaining information.
A good incident investigation report should list briefly:
The nature of the incident.
When it happened (date, time, shift).
Who was involved.
Who was a witness.
The type of equipment that was involved.
The nature of the injury.
The nature of the damage to the equipment.
A brief statement of the circumstances of the incident
After this is completed it is important to review it to ensure that it is purely factual information
and does not include cause analysis or recommendations.
2) Sequence of Events leading to Accident/Incident
After factual data has been obtained it is then necessary to identify the sequence of events
leading up to the incident. This might involve identifying the sequence of three or four events
that occurred immediately before the occurrence of the incident.
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Incident Investigation
Corrective Action
A short-term fix is something that can be put in place almost immediately and will prevent that
same incident from occurring again in the immediate future. The purpose of a longer-term
solution is to put in place measures that will effectively prevent the same incident occurring but
will also prevent similar incidents occurring in other areas of the workplace.
5) Communication with Persons involved
After an incident investigation has been undertaken and documented, it is important that the
results of the investigation are reviewed by the person or persons originally involved in the
incident. Incident investigation reports typically have an attached circulation list such that the
involved persons, the OH&S officer and also management, can review them. This must be
specified in the procedure.
6) Follow-up and Review
Many organizations fail to learn from mistakes by not adequately implementing
recommendations from incident investigation. Results of incident investigations should be
audited to confirm suitability and success in implementation of recommendations. Procedures
should be in place to review the outcome of incident investigation and confirm that
recommendations have been implemented. Group companies should also be aware that
sharing the results of investigations with other Holcim companies could help prevent a similar
incident occurring in another company. This sharing is done via SAFETY and/or the OH&S
coordinators' Community of Practice.
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Incident Investigation
Corrective Action
7) Training
Personnel involved in incident investigation should be provided with training, including training
in analysis of root cause, contributory factors and system deficiencies.
8) Statistical Analysis of Data
Review and analysis of data may reveal useful trends. Trends may be identified for:
Injuries
Property damage
Near hits/misses eg. person nearly struck by a falling object
Hazards
Illness
Compensation claims
10.4
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10.5
Incident Investigation
Corrective Action
Auditor Evidence
An audit will seek evidence of
Hazard reporting
Incident reporting (including Critical Incident reporting)
Incident investigation procedure
Incident investigation activities, including training
Development and communication of corrective actions
Implementation of corrective actions
Review of corrective actions
Statistical analysis of data
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11.
11.1
Industrial Hygiene
and Monitoring
Summary of Intent
Industrial hygiene is the anticipation, recognition, evaluation and control of those environmental
factors (sometimes called stressors) arising in or from the workplace that may cause sickness
or impaired health amongst employees, visitors, contractors or the general public. (These
various environmental factors or stressors are usually classified as chemical, physical,
biological or ergonomic.)
All workplaces should have a program to identify and measure the extent of environmental
factors in the workplace as well as the exposure of employees, visitors, contractors or the
general public.
If it is indicated by the results of a risk assessment, employees should be involved in a medical
monitoring program to identify if there has been any negative impact on them. This monitoring
may need to be ongoing or continuous to ensure that exposures are controlled to levels that is
as low as reasonable achievable.
11.2
General Comments
An industrial hygiene and monitoring program will:
11.3
PT
Workplace Monitoring
Issues that may be addressed as part of such monitoring include:
6
TP
PT
Temperature
Flammable gases
Fire
Radiation
Ergonomics
Lighting/Illumination
albert.tien@holcim.com
Page 51
Industrial Hygiene
and Monitoring
Each site should undertake hazard identification and determine the whether or not monitoring is
needed. If it is, the type of monitoring that is required must then be decided. It is important to
note that consideration should also be given to any environmental exposures being caused to
neighbors or other emission points in the area around the site.
11.4
Health Monitoring
There is a requirement for undertaking employee health monitoring when employees are
exposed to particular types of risks. This may be specified by local legislation or found through
risk assessments.
Depending upon the nature of work circumstances, employees may be exposed to hazards
requiring ongoing health monitoring. Hazards requiring health-monitoring programs may
include exposures to:
Noise
Dust containing crystalline silica
Asbestos
Lead, other heavy metals or other specified chemicals
Excessive stress resulting from the activities in the workplace
A health surveillance program may be undertaken when a risk assessment determines the level
of risk of exposure requires surveillance or there is a legislative requirement to have a program.
Any such program should established with suitable medical input. Results should be
communicated to workers and records of the length and type of exposure to each material
maintained on a secure long-term basis. Local legislation should be checked but as a guide,
keeping records of monitoring for at least 30 years should be considered. Health surveillance
results should also form the basis for improving strategies for minimizing worker exposure to
risks.
11.5
Auditor Evidence
An audit will seek evidence of the existence and implementation of the items listed above. An
audit will also review evidence of record keeping.
Based upon a site inspection, a comment may also be made on the adequacy of monitoring
undertaken.
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12.
12.1
Summary of Intent
Employee Communication
and Involvement
Modern OH&S Management Systems call for consultation through mechanisms such as OH&S
Committees. Consultation is important because it directly involves those persons performing
tasks in the workplace and it is these people who often have the best understanding of the
nature of the hazards involved in the work. Consultation should also involve discussing the
incidents (and near hit/miss incidents) that have occurred, and the solutions that can be put in
place for controlling such incidents.
Therefore, an open consultation process will ensure that such issues are raised, and will also
provide the opportunity for comment and feedback on the effectiveness of OH&S management
strategies.
OH&S is an integral part of the process of stakeholder involvement in the whole Corporate
Social Responsibility (CSR) program at a Group company, and this block includes recognition
of that requirement.
12.2
General Comments
Consultation in the workplace can occur in a number of ways. The most common method is
through an OH&S Committee. The requirements for the formation of an OH&S Committee and
the composition of the OH&S Committee are often specified by local legislation.
In some workplaces, it may be more practicable to have several OH&S Committees/OH&S
groups. For example, each shift or work area such as operations and maintenance may have
its own local OH&S group whose aim is to deal with their OH&S issues at the local level.
As a recommended minimum, an OH&S Committee should contain both workforce and
management representatives (majority workforce representatives) and meet at least four times
per annum. Minutes of meetings must be kept and communicated to both management and
the workforce.
Consultation must also address the problems associated with different languages at a given
site.
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12.3
Employee Communication
and Involvement
Details
OH&S Committee
The key factor to be considered when forming an OH&S Committee is to ensure that an
appropriate balance is maintained between representation of all interest groups and areas in
the workplace, and the overall size of the OH&S Committee.
To be effective OH&S Committee members must have received basic training in understanding
the applicable legislation and its impacts, and basic training in OH&S Management practices.
As a minimum, training in the following areas is recommended:
Publications
One important aspect of establishing communication systems is to identify critical OH&S
publications and determine the distribution list for them. The implementation stage requires
that key OH&S publications are identified and that a register of those publications is produced.
Similarly the distribution for each publication must be identified and a corresponding register
produced. Having both of these document registers is evidence that key OH&S publications
are distributed to the appropriate personnel in a timely manner.
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Employee Communication
and Involvement
Training
Good communication is not simply a matter of distributing documents to appropriate personnel.
To be effective Managers and Supervisors must also initiate communication on a personal
basis. Therefore, it is important that Managers and Supervisors have appropriate
communication skills. An assessment should be made of communication skills currently
possessed by Managers and Supervisors and, where appropriate, additional training is
provided.
OH&S Promotion
One of the most important functions of the OH&S Committee will be to engage in OH&S
promotion. There are a large number of ways that this outcome can be achieved and these
should be the focus of OH&S Committee considerations.
The OH&S Committee should consider the type of material that is currently available in the
organization and identify also sources of external promotional material, eg. ability to hire
videos, purchase other forms of OH&S awareness material, organize and run poster
campaigns, etc.
It is not the purpose in this document to prescribe any particular approach to OH&S promotion.
The topic of OH&S promotion is important because it raises the awareness of all persons at a
workplace regarding the importance of OH&S. The Committee needs to be aware of the type
of internal resources that are currently available, and those that are available for use from
outside the organization.
Language
It is recognized that at a number of Holcim sites different languages may be spoken.
Therefore, it is important that appropriate OH&S information is conveyed to all personnel. This
may require preparation of key information, such as policy and procedures, in multiple
languages. The site should demonstrate that it has reviewed this issue and produced
information in the appropriate manner and language.
Review of Consultative Arrangements
As with any process it is important that consultative arrangements are reviewed on an annual
basis. The OH&S Committee in consultation with the site management should, on an annual
basis, review its effectiveness, consider new initiatives, and consider also the need to change
the membership of the OH&S Committee.
12.4
Auditor Evidence
Evidence expected to be available in an audit is noted in section 12.3 above.
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13.
13.1
Summary of Intent
If the other blocks of the pyramid are to operate effectively, it is essential that the OH&S
handbook and/or any other source or reference documents are readily available, properly
controlled and updated to reflect any changes and improvements made. Hence a document
Management System is essential.
Those companies with existing ISO9000 and/or ISO14000 systems should have this
substantially in place.
Reporting of OH&S performance results is fundamental, and this block describes the reports
needed internally within the Group company, internally to Holcim group level, and externally as
appropriate.
13.2
Details
General
Many sites may already have document Management Systems based upon the ISO9000 or
ISO14000 series of Standards. If this is the case, then the systems will be able to be used. A
document Management System is required:
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Document Management
The intent of this section of the OH&S Management System is to ensure that persons have
access to correct and up-to-date documents and that changes to documentation are only made
with the approval of authorized persons.
In order to effectively manage OH&S it is important that key documents are identified and
controlled at all stages. Therefore, it is expected that there will be procedures to:
OH&S Manual
It is often considered to be effective to summarize the key documents from the OH&S
Management System into an OH&S Manual. This should show how key aspects of the OH&S
Management System would be addressed.
A Group company OH&S Manual is likely to include information on:
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13.4
Records
Procedures should be in place for identifying, collecting, filing, maintaining and controlling
OH&S records.
Records are required to demonstrate the standard of OH&S management achieved and the
effectiveness of the OH&S Management System.
Records may include:
Design Information
Adequate OH&S information is an essential prerequisite to effective hazard identification and
risk management. Systems must be in place to ensure that information is current and
available.
Suitable process design information should be available to permit operational personnel to
safely manage the plant and associated equipment.
Appropriate process design information should be available to operations and maintenance
personnel. This information may include:
Materials of construction
Piping and instrument diagrams
Electrical area classification drawings
Electrical diagrams
Design and basis of OH&S systems
Design of ventilation systems
Description of shutdown and interlock systems
Lighting/illumination system
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The mechanical design should be consistent with the requirement of local Codes and
Standards and reference should be made to these Codes and Standards. If design is not
consistent with Standards, then the differences should be documented.
13.6
Reporting
In addition to document control and the provision and recording of information, it is essential
that reporting of OH&S information occurs. The expectation is that all incidents will be recorded
in an incident register at each site. Based upon this information, the following reports must be
made.
UTH
NOTE: This report can also be applied for any serious accident, near hit or
other incident the Group company feels should be reported.
Every Group company must report their performance with respect to achieving
the Targets annually. This is to be done by the OH&S coordinator completing
the Annual Safety Statistics Report and submitting it to the responsible HGRS
person.
Regular reporting within the Group company will be done via a report that is
currently being developed as part of the Holcim Information Platform (HIP)
project.
13.7
Auditor Evidence
The audit will confirm that a document control process is in place and that
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14.
14.1
Summary of Intent
Task Analysis
Introduction
The OH&S risks experienced by an organization are related to the particular activities that
occur within an organization. For example, the types of risks present in a mining environment
are different to those present in an office environment. Therefore, it is important to be able to
analyze tasks undertaken in order to identify hazards and effectively manage risks.
General Comments
The topic of task analysis is closely related to hazard identification and risk assessment, and is
also related to Worker Behavior Modification - Refer to Appendix One where risk assessment
and task analysis are discussed in greater detail.
Hazard identification and risk assessment provides a general methodology for identifying and
managing OH&S issues. Task analysis is specifically focused on work tasks or work activities,
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whereas hazard identification is generally concerned with the physical layout and design of the
workplace as well as specific tasks.
The objective of task analysis is
Auditor Evidence
An audit will seek evidence of standard work practices generated by task analysis / risk
assessment. Other issues will include:
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15.
15.1
Summary of Intent
Where audits look at OH&S system performance, development and improvement, this pyramid
block deals with sophisticated inspection and testing techniques that are required to ensure the
ongoing reliability and OH&S of plant and equipment.
The inspections discussed in this section are different to those discussed in Section 6.
Employees with only low levels of training typically undertake the inspections discussed in
Section 6. The inspections discussed herein generally require employees with better
qualification and/or training to use sophisticated testing techniques.
Note that companies with existing maintenance cement systems (MAC) should have this block
substantially in place.
15.2
General Comments
This element requires that regular inspections and tests of critical plant and equipment be
undertaken. A good program should be based upon:
Inspection Topics
Inspections may be applied to a range of different areas and activities within the workplace.
These include the various topics listed in the table below.
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Each site should determine those topics for which inspections are required. This may require
inspections in addition to those listed below.
Buildings and Roofs
Lighting/Illumination
Electrical
Lifting Gear
Pressure vessels
Lightening Protection
Overhead Cranes/Gantries
Brief descriptions of topics that may receive routine inspections are listed below.
Buildings and Roofs
Regular inspection of buildings and roofs should be undertaken. The types of issues that may
need to be considered are:
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This inspection serves a similar purpose as that regarding portable electrical equipment. Each
earth leakage circuit breaker (or residual current device) should be identified, including location
and test intervals specified. The inspection can then be used to confirm that the appropriate
testing has been undertaken. Generally, legislation or applicable Standards and Codes will
specify testing requirements.
Lifting Gear
Items of lifting gear should be identified and recorded in a Register, including their usual
location. In addition, where appropriate, a Safe Working Load (SWL) should be marked. The
SWLs applicable should be marked on shelving where lifting gear is stored. Regular testing of
lifting gear is required. Qualified personnel should inspect lifting gear and make
recommendations for repair or replacement as appropriate.
Pressure Vessels
The requirement for testing of pressure vessels and associated pipe work and valves is
generally covered directly by legislation or through appropriate pressure vessel Codes. A
register of pressure vessels should be developed, including specification of the type of
equipment, location, design pressure limits and required testing interval.
Fire Fighting Equipment Inspection
The purpose of this inspection is to ensure that all items of fire fighting equipment present at a
workplace are identified and documented. Items will include fire extinguishers, fire blankets,
fire hoses, fire pumps and other supporting items of fire fighting equipment. The location of
each item should be specified and the required test interval also included on the inspection
form. The required test interval for different items of fire fighting equipment is generally
specified by the appropriate Standard or Code. The inspection form enables the due date for
the testing to be identified and confirmation that the test has actually been done can also be
included on the form.
Emergency Stop Systems
Emergency stop systems associated with plant and equipment should be identified and
documented. A structured program for proof testing the effectiveness of these should be
implemented, with results recorded.
Other Inspections
Other areas of consideration for inspection may include:
Corrosion monitoring
Structural integrity checks (especially tall structures)
Condition monitoring of bearings and drives
Monitoring of natural hazards
Areas agreed with local authorities and/or insurance companies
15.4
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15.5
Auditor Evidence
An audit will seek evidence supporting the requirements noted above.
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16.
16.1
Design Safety
DESIGN SAFETY
U
Summary of Intent
There are many ways of controlling risk in the workplace. However, the most effective way of is
to ensure that, where practicable, hazards are eliminated at the design stage, or where this is
not practicable, the mechanism for control of those hazards, is incorporated intrinsically into the
design. This element of the OH&S Management Pyramid requires the establishment of
processes to ensure that all new designs are reviewed and hazards identified prior to
construction of the plant or implementation of the particular change. This element also requires
that designs be based upon internationally recognized standards, and that a design should also
take into account human factors as well as the practicalities of engineering design.
This also cover the requirements of "due diligence" in identifying the necessary safety
equipment, documented procedures and training to be included in new projects, mergers and
acquisitions, etc.
16.2
General Comments
OH&S Management must start at the initial design and planning phase and be an integral part
of all phases of a project or activity; ie. planning, design, procurement, construction, operation,
maintenance, modification, decommissioning and rehabilitation.
This particular element requires that consideration of OH&S issues be included in the design
phase for plant, equipment and operations. Furthermore, a design should reflect consideration
of the hierarchy of risk controls (see Appendix One), and formal design review should be
conducted at appropriate stages in the development a design.
It is important also that there is a clear linkage between the design and the documentation
generated by the design process.
Broad-brush review
Design review
Design standards
HAZOP/HAZAN study
As built study
Commissioning risk assessment
Updating of drawings
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16.3
Design Safety
Details
Design Process
Consideration of OH&S issues must be included in the design phase for plant, equipment and
operations. The most effective way of managing OH&S is to ensure that risk control features
are incorporated into the design of system, plant or equipment. Therefore, it is important that:
Design
Manufacture
Storage
Transportation
Installation
Commissioning
Use
Cleaning
Setting and adjustment
Inspection
Maintenance, servicing and repair
Modification and refurbishment
Decommissioning
Dismantling and demolition.
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Design Safety
Provision of information
Provision of guarding
Identification of energy sources
Static electricity
Fire and explosion
Noise
Vibration
Radiation
Lighting and illumination
Release of substances
Testing of plant and operational stability
Control devices and operating controls
Hierarchy of Risk Controls
Design should reflect a consideration of the hierarchy of risk controls. OH&S risks can be
managed in a number of ways. Effective design should consider each of the elements of the
hierarchy and, where practicable, and incorporate the most important. The hierarchy is:
Elimination
Substitution
Separation/isolation/engineering
Administration
Personal protective equipment.
16.4
Auditor Evidence
The audit will seek evidence of:
Hazard identification
Occurrence of design reviews
Documentation of design risk studies
Evidence of attempts to eliminate the need for PPE
Consideration of OH&S in design reviews
Completion of recommendations
It is important that there is a clear linkage between the design and the
documentation generated by the design process.
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17.
17.1
Summary of Intent
A system of internal audits is essential to monitor and review the performance of those
elements that have been implemented, and ensure the ongoing functioning and improvement of
an OH&S Management System. Internal audits do not have to be extensive site wide audits,
but may be internal reviews conducted within a particular department or work group aimed at
reviewing the implementation and performance of the OH&S Management System in a specific
area. For example, in relation to high-risk work activities, it is recommended that internal audit
reviews of the performance of the work permit system be undertaken on a regular basis.
Similarly, internal audits should be undertaken in relation to the effectiveness of incident
investigation, risk assessment etc. Outputs from internal audits can then be linked to the
corrective action system to ensure that improvements are locked into place.
Although internal audits provide feedback regarding the effectiveness of OH&S management
performance, it is important that an external audit by an independent party be undertaken to
provide a full and objective review of the performance of the OH&S Management System.
External audit also provides feedback to senior management to assist them in their ongoing
system improvement and development.
17.2
17.3
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A suitably qualified auditor should undertake an external audit, and the audit results reported to
site management. This person or persons (in a team) could be drawn from HGRS or other
Holcim companies and do not have to necessarily be from a 3rd party (external) organization.
P
Any recommendations from the external audit should be part of the sites OH&S Plan.
17.4
Auditor Evidence
An audit will seek evidence of:
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18.
18.1
Occupational
Rehabilitation
OCCUPATIONAL REHABILITATION
U
Summary of Intent
Corporate social responsibility (CSR) addresses how a Group company manages its societal
obligations and expectations. One key issue from an OH&S viewpoint is occupational
rehabilitation. Implementation of this block requires close cooperation between all relevant
stakeholders.
18.2
Rehabilitation
Although the primary aim of any OH&S Management System is to prevent the occurrence of
incidents and injury, it is important in those situations where an injury or illness has occurred,
that assistance is provided to an employee to return them to meaningful work as soon as
possible. Therefore an effective employee rehabilitation scheme should be in place to return
employees to productive work as soon as possible after a lost time injury or after contracting
work related disease.
The rehabilitation scheme should be in place consistent with the requirements of any local
Workers Compensation/Insurance Legislation.
Key issues to consider in a structured rehabilitation program are:
Auditor Evidence
An audit will seek evidence of:
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19.
19.1
Procurement
PROCUREMENT
U
Summary of Intent
Just as design safety is an important way of ensuring that hazards are not brought
unnecessarily into the workplace, so management of procurement activities is also a way of
preventing new hazards from entering the workplace. Taken together, these two elements are a
combined approach to ensure that emerging OH&S issues are identified and controlled.
This OH&S pyramid block sets guidelines for ensuring that the procurement process for any
new plant and equipment, goods or contractor services, is subject to a review process in which
hazards are identified, risks are assessed, and appropriate control measures planned and
taken prior to introduction.
19.2
General Comments
It is important that procedures are in place to ensure that the OH&S requirements of procured
materials and equipment are specified and met. To ensure OH&S issues are included in the
process that defines how suitable equipment and services are obtained, the appropriate OH&S
coordinator shall be consulted during the specification process. Further, the OH&S coordinator
shall be asked to assist by providing OH&S input during the making of procurement decisions,
if necessary.
19.3
Details
Procurement and Suppliers
The most effective way of dealing with any OH&S problem is to eliminate or minimize the
problem. One pro-active way of doing this is to ensure that controls are placed upon the
procurement of items of plant, equipment, and substances. The types of issues that can be
addressed by an effective procurement policy are:
Ensuring that only OH&S equipment that meets criteria set by the Group
company is procured, eg. hard hats, safety glasses, boots, respiratory
protection, gloves, fire-resistant clothing, etc to ANSI or OSHA standards.
Ensuring that when items of plant and equipment are procured, OH&S and
particularly ergonomic considerations are taken into account prior to placing an
order, and when the goods are received on site that appropriate documentation
relating to any OH&S aspects is obtained; etc
An effective procurement system will also ensure that:
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Procurement
Material Safety Data Sheets are obtained before the procurement or receipt of
a chemical (risk assessments can be undertaken before the chemical is used)
Persons involved in procurement are always made aware of the OH&S issues
that need to be taken into account in the procurement process
People in procurement and stores should be included on OH&S training schedules relating to
hazard awareness. Prior to purchasing, an evaluation should be carried out to ensure that
materials and equipment to be procured meet:
Legislative requirements
Relevant Standards and Codes
Hazardous chemicals requirements
Any other OH&S performance criteria or specifications.
Procurement documents must clearly describe the goods and specify OH&S needs. A system
should also be in place for verifying that the goods supplied meet them.
Contractors
Contractors are best controlled in terms of OH&S performance through the selection process.
The process of selecting a suitable contractor should involve consideration of that contractors
past OH&S performance and whether they can show evidence of having an effective OH&S
Management System operating.
Control of contractors is important for various reasons.
The company may have a duty of care to contractors who are working for it.
Where it exists, part of this duty of care involves informing the contractor of the
types of hazards to which they are likely to be exposed and having systems of
supervision and control that ensure that the OH&S of the contractors
personnel are protected.
It is also important to control contractors by preventing them undertaking tasks
or working in areas where it is considered that it is unacceptable for them to
work. There may be, for example, high-risk areas in a plant where very specific
training is required in order to work there. Part of the control placed on a
contractor would be non-entry to certain areas without having received specific
induction training.
So despite the contractual arrangements that may exist, OH&S for contractors should be
addressed in the same way as that for an employee.
19.4
Auditor Evidence
An audit is expected to address the details noted in section 18.3, including:
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Procurement
A selection process for contractors based in part upon their ability to meet
clearly defined OH&S requirements.
Evidence of consideration of OH&S requirements in the procurement of
services.
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20.
20.1
Management of Changes
MANAGEMENT OF CHANGES
U
Summary of Intent
Management of changes builds upon the elements of Design OH&S and Hazard Identification
and Risk Assessment. The inclusion of this element is recognition of the fact that
circumstances in the workplace will change over time, and that changes may introduce new
hazards or alter the effectiveness of existing OH&S Management Systems and controls.
Therefore, a risk-based Management of Changes procedure is required to identify hazards
associated with proposed changes and ensure that those hazards are effectively controlled
prior to the implementation of the change.
This block establishes a risk-based procedure to check for actual or proposed changes,
examine the hazards associated with them, and ensure:-
General Comments
An organization and its facilities may be subject to continual change to increase efficiency,
improve operability and safety and accommodate innovation and improvement. These
changes may introduce new hazards or alter existing risks. Therefore, appropriate systems
should be in place to manage changes.
The purpose of this element is to ensure that when a change is made to an organization's
activities, products or services, the associated changes to OH&S aspects and impacts are
identified at, or preferably before, the time at which the change is made. All of these factors are
considered within the context of determining whether the change requires a change in OH&S
objectives and targets and an overall change in the OH&S Management Program.
The Management of Changes procedure addresses both physical change and also changes in
policies, standards, and work instructions. It is a critical procedure because it is through the
Management of Changes procedure that a site will develop amended policies and standards
and determine their impact on operations. This is a key aspect in the implementation of the
OH&S Management System and provides the bridge between the global policies and standards
and the specific instructions that provide guidance to workers at lower levels.
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20.3
Management of Changes
Details
Many OH&S problems emerge because changes (to technology, plant, equipment or systems)
are made which destroy or diminish the integrity of plant and equipment or existing OH&S
systems. Therefore, it is necessary that:
Auditor Evidence
An Audit will seek evidence of:
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21.
21.1
Health and
Wellness Issues
Summary of Intent
Effective management of OH&S is not confined solely to the workplace and workplace
activities. Many issues may impact on the ability of a worker to perform tasks and functions in
a safe and efficient manner. This element of the pyramid addresses broader health and
wellness issues, some of which are directly related to workplace activities and others may be
related to business activities outside ones normal work.
This block is a key element within the corporate social responsibility program, and recognizes
Holcims commitment to addressing issues beyond the bounds of a particular work site.
21.2
21.3
Other Issues
As a minimum, each site should demonstrate that risks associated with the following have been
assessed for their workforce:
Auditor Evidence
An Audit will seek evidence that other issues decided as relevant to the employees in the
Group company are being dealt with appropriately.
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Page 78
Introduction
The first phase of the risk management process is hazard identification.
The purpose of hazard identification is to construct a comprehensive list of hazards associated
with any particular asset, item of plant, work practice, work area etc. The fact that many
hazards may exist is not necessarily an indication that there are significant levels of risk
because the hazards may be well controlled.
Therefore, it is always important to maintain a clear distinction between the process of
identifying hazards, and subsequently analyzing the risk associated with them.
Definition of Hazard
A hazard is typically defined as "anything that has the potential for harm or a potentially
damaging energy source".
The key word in the definition of hazard is the word potential. By defining a hazard as a
potential for harm, one is not stating that the harm will actually occur. Therefore, the notion of
hazard is a notion of possible harm and possible future consequences. In hazard identification,
one is attempting, through a range of techniques, to identify what could happen and the types
of energies present in a workplace that could cause injury, illness, or property damage.
Sources of Hazards
As noted above, hazards can be identified as different types of damaging energies. Examples
of damaging energies include:
Thermal
Electrical
Chemical
Radiation
Biological
Vibration
Noise
Gravity
Kinetic
Mechanical
Potential
In general terms, hazards can be associated with three categories.
People
The workplace layout and general work environment.
Work practices
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1.
People
There are potentially damaging energies associated with people. These are damaging
energies associated with physical/muscular exertion, activities such as:
Lifting
Striking an object
Being struck by another object
Pushing/pulling/restraining
Repetitive strain
Postural strain
Some risks may arise because of mismatches between people, the tasks that they must
perform, and the equipment that they must use. Care must be taken when assessing people
as new employees may be at greater risk performing a task than older employees with years of
experience behind them. On the other hand younger employees may be more agile and
physically fitter than older employees.
2.
Thermal
Machinery: mobile, fixed
Chemical
Electrical
Noise
The hazards associated with this category are those that arise from the type of plant and
equipment that are in use, the general design and layout of the workplace and the broader work
environment in which the workplace is located. Usually these types of hazards are the easiest
to identify, and often (unfortunately) hazard identification does not proceed beyond this stage.
3.
Work Practices
Many hazards arise through work practices, and many workers are exposed to hazards as that.
For example, a chemical hazard may be present in the form of chemicals stored in drums.
However the way that workers are exposed to the chemical will depend upon the work
practices that are adopted. Particular work practices may also affect the nature of the hazard;
eg., a chemical normally in liquid form may be sprayed in an airborne state where it can be
easily inhaled.
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Identification of hazards in work processes is probably the most difficult part of hazard
identification, and therefore such hazards are often overlooked. Because work practices may
change on a daily basis, the nature of hazards and worker exposures to those hazards may
also change. Safe work practices are one way of addressing such hazards. For new or
unusual tasks, hazard identification and risk assessment should be undertaken before the
commencement of the task. The process management approach will assist to clarify work
practices and associated OH&S issues.
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particular policy or procedure. Workers also may be aware of incidents that have
occurred in the past that have not been formally documented or reported.
Brainstorming
Brainstorming is a technique that is used to tap the creative thinking of a group of
people. Consultation with workers may occur via brainstorming, but it may also involve
other people; eg. OH&S experts, managers, etc
Use of Checklists
Checklists can be used in hazard identification to focus attention on particular hazards
and collect relevant data. It is often convenient to construct checklists based upon the
results of previous hazard identification activities or upon a review of historical data.
The main advantage of checklists is that they are easy to use and are good at focusing
attention on particular issues. Their major disadvantage is that by focusing on some
particular hazards, other significant hazards may be ignored.
Observation
Direct observation is also an effective technique for identifying hazards. Observation
may be undertaken in conjunction with the use of a checklist or other suitable recording
device, eg. video camera. Observation may be used for studying work practices and
identifying hazards associated with workplace layout/design and environment,
ergonomics and patterns of flow, etc.
Flowcharting
It has already been noted that it is essential that hazard identification addresses
hazards associated with work practices. Although this can be partly achieved through
observation, flowcharting is a systematic technique that can be used to break a work
practice into its component parts and allow identification of hazards at each step of a
work practice. Using a flowchart in this manner can provide the basis for
HAZOP/HAZAN studies as well as the subsequent development of safe work practices
for each of the steps.
Selection of Hazard Identification Techniques
As noted above a range of techniques are available for undertaking hazard analysis.
For example, if the focus is on work practices then techniques such as observation and
flowcharting should be used. If, however, the aim is to identify hazards associated with
workplace layout, then observation, checklists, and consultation may be more effective.
Relevant historical data should be reviewed on all occasions.
It is essential in the longer term that all types of hazard (different damaging energies)
and all sources are addressed (people, practices, layout, and environment). In
addition, the human factor (people are fallible) should also be addressed by having a
system to make sure that the person with the right abilities, skills and training required
for the position is actually filling it (this is a normal function of Human Resources).
Definition of Risk
Risk is the chance of something happening that will have an impact on objectives or
targets. It is measured in terms of likelihood and consequence and may arise from an
event, an action or from a lack of action.
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DESCRIPTION OF CLASSIFICATION
Illness, injury requiring first-aid or no treatment
Medical (doctor) treatment
Single serious (hospitalization) injury
Single death or major permanent disablement
Multiple deaths
DESCRIPTION OF CLASSIFICATION
Expected many times per year
Expected about once per year
Expected between once every year and once every 10 years
Expected between once every 10 years and once every 100 years
(possibly once or twice in the life of a site/plant)
Expected between once every 100 years and once every 1000
years (not expected to occur in the life of a site/plant)
Once a risk has been assessed according to the classification descriptions above, a 5
X 5 risk analysis matrix is then possible in which consequence and likelihood are
combined to give a measure or ranking of risk. Risks are ranked from low (possibly
acceptable) to extreme. The purpose of this risk analysis matrix is to provide a
prioritization of risks and therefore the basis for developing risk management plans and
allocating valuable risk management resources.
Consequence
Likelihood
A
B
C
D
E
H
M
L
L
L
H
H
M
L
L
E
H
H
M
M
E
E
E
H
H
E
E
E
E
H
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Page 85
ELIMINATION
SUBSTITUTION
ENGINEERING
ADMINISTRATIVE
PERSONAL PROTECTIVE EQUIPMENT
Note that any control measure adopted must achieve the following criteria:
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Substitution
Although hazard elimination is desirable often it is not possible to eliminate a hazard.
In fact, although some hazards may be able to be eliminated, the vast majority will
continue to be present at the workplace. The fact that work is being undertaken, that
equipment is being used, that chemicals are being used, that persons are involved in
various types of manual activity, means that there will be a whole range of hazards
present. Ultimately the only way to eliminate such hazards would be to discontinue the
particular work activity.
Once a workplace is established a large number of hazards will also be introduced and
the vast majority of those hazards will persist for the lifetime of the workplace. The
strategy of substitution requires substituting something that is less hazardous for
something that is more hazardous.
For example, replacing a noisy piece of equipment with a new item of equipment that is
less noisy is an example of substitution. There is a noise hazard present in both
circumstances. However, with less noisy equipment the hazard is significantly reduced
because substitution has occurred.
Another example of substitution is to use a chemical in a pellet form rather than in a
powder form. Solids that are present as powders may become airborne and so may be
inhaled by persons. On the other hand, a chemical that is present in a pellet form will
less easily become airborne, and therefore the level of risk in that situation will be
lower. Substitution therefore is a highly desirable risk control strategy.
Elimination and to a lesser extent substitution are the preferred risk control strategies.
The main reason why they are preferred is that they make a fundamental change to the
nature of the workplace. As noted above, elimination comprehensively removes a
hazard from the workplace. Substitution on the other hand reduces the degree or
severity of a hazard. Both of these strategies are independent of other aspects of the
workplace, i.e. they do not require the continuous functioning of particular items of
plant, they do not require people to understand and use procedures and they do not
require the use of particular items of PPE.
When considering risk control it is important that the possibility of elimination or
substitution is seriously considered as the first step. In many situations, these may not
be possible or realistic risk control strategies. However it is necessary that they are
considered and, if possible, actions taken in this regard.
Elimination and substitution are often not the quickest-to-implement control options that
can be chosen. It is recognized that sometimes it may take a considerable period to
apply either of these risk control strategies. To eliminate a hazard, for example, may
require the redesign of a workplace and changing of work processes. In many
situations, this may require significant capital expenditure that will need to go through
various approval stages. In addition, associated design work will also need to be
undertaken. However, Elimination and substitution should always be considered and if
possible implemented.
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Engineering Controls
The next control in the hierarchy of control options is engineering controls. Types of
Engineering controls are varied and examples are:
Ventilation systems
Separation of workers and hazards
Isolation
Fundamentally, an engineering control is one that changes or affects the way a hazard
and the worker may come into contact. Therefore, an engineering control places a
barrier between a worker and the hazard. The worker is unable to come in contact with
the energy source that constitutes the hazard.
It should be noted that an engineering control does not make any fundamental change
to the nature of the hazard. For example, use of a ventilation system in an area where
hazardous fumes are present is an example of an engineering control. The hazard in
this situation is a chemical hazard associated with the chemical composition of the
particular dust or fume. Installation of a ventilation system will protect workers by
removing the fumes from the work area and venting them into some other safe
location. However, the ventilation system does not prevent the fumes from being
generated and therefore the nature of the hazard is unaltered. What is altered is how
the hazard and the worker can come into contact. If an engineering control fails or
ceases to be present then a worker will be exposed to the original hazard or energy
source.
Another example of an engineering control is a guard that prevents a worker coming
into contact with moving mechanical equipment. A guard is very effective while it is in
place. However on many occasions guards are removed during maintenance work and
are not reinstalled. If this does occur, then the hazard associated with the mechanical
equipment is uncontrolled and the worker is exposed to a higher level of risk.
Therefore, although engineering controls are very effective in the areas in which they
are applied, engineering controls also require on-going monitoring, observation and in
some situations maintenance to ensure that control remains in place and continues to
perform its desired function.
Administrative Controls
The fourth type of control in the hierarchy of risk controls is administrative controls.
Administrative controls refer to those ways in which risks are controlled by procedures
or particular rules and regulations. Regulatory authorities, eg. Acts of Parliament and
associated Regulations, may define administrative controls. Administrative controls
may also be present in particular Standards and Codes that may be applied in a given
industry. For example, a Standard for Safe Working in a Confined Space is an
administrative control because it defines a series of requirements that must be in place
before a person can work in a confined space.
Many administrative controls are generated at a particular worksite in response to the
risks associated with a certain type of hazard. Therefore, the requirement to follow
certain safe working practices when doing a job is a particular form of an administrative
control. A well-developed administrative control will be effective in the control of risk.
However for an administrative control to be effective it is necessary that the persons to
whom the particular administrative control applies are aware of the control, understand
the need for the control and have the skill, knowledge and experience to make control
work.
The current version of the Holcim OH&S Handbook is on HolSpace (SafetyNet)
Please check for updates and/or changes.
Page 88
There are numerous instances where administrative controls have existed but for
various reasons persons do not follow the requirements of a particular administrative
control and as a result suffer an injury. Administrative controls therefore require the
cooperation and involvement of workers at a worksite and this introduces a range of
additional issues. Aspects relating to human factors in risk assessment are discussed
in a following section.
Role of Task Analysis
The risk assessment process involves identifying hazards, assessing risk and if the risk
is unacceptably high putting in place risk control strategies. Often the major focus of
hazard identification is the physical layout and design of the workplace, i.e. hazards are
identified in terms of storage of chemicals or other forms of equipment, access, and
other states of affairs that exist in the workplace.
One of the major sources of hazards in a workplace, however, is within work practices;
i.e. workers are exposed to hazards because of the types of jobs that they do and the
way they do those jobs. Therefore task analysis is an essential aspect of any OH&S
Management System and incorporates the previously discussed aspects of risk
assessment. The outputs of task analysis are safe working practices.
Strategy: The key strategy involved in task analysis is to document particular work
tasks. Until a work task is formally documented, it is difficult to identify the types of
hazards to which a worker is exposed and the nature of the risk associated with those
hazards.
Documentation must be developed in consultation with the involved workers. It is
important in documenting work practices and work tasks that workers are comfortable
to discuss the actual practices that they use and adopt rather than those that might be
specified in any existing procedure or be assumed by management to be undertaken.
The quality of task analysis and the development of subsequent safe working
procedures will depend upon the accuracy with which a particular task is documented.
Risk Assessment: After a task has been documented, it is possible to undertake a risk
assessment of the risks associated with the task. This is done by reviewing the task
and asking at each stage of the task what are the hazards associated with that task or
what are the sort of incidents that could occur leading either to personal injury or
property damage.
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Once a risk control has been identified, the risk analysis and risk assessment process
needs to be undertaken again to confirm that that control is adequate. For example, a
risk control may affect consequences, it may affect likelihood, or it may affect both.
Therefore, it is necessary to undertake an analysis and assessment again considering
the situation where risk control is in place and determine the level of risk.
The level of risk remaining after a risk control has been put in place is called residual
risk.
The purpose in choosing a risk control is to ensure that the level of residual risk is as
low as is practicable and/or acceptable.
It may be that when a particular risk control is postulated and the assessment is
undertaken again the analysis may show that the risk is still unacceptably high. In such
a situation, it would be necessary to develop either a new risk control strategy or add
another level of risk control to that already suggested. Once this is done, the analysis
and assessment process should be repeated again to demonstrate and ensure that the
level of risk is acceptably low.
It is often this aspect of verification of the suitability of risk control that is omitted from
the process of risk management. It cannot be stressed highly enough that it is
necessary that each time a risk is identified as requiring risk control, that it is ensured
that the control is evaluated to determine whether it will adequately control the risk.
Role of Monitoring
It is necessary to confirm that a particular risk control is achieving the desired level of
risk reduction after being put in place, ie: Ongoing monitoring of risks and associated
risk controls needs to be undertaken. For example, a risk might be identified, analyzed,
assessed, and found to be unacceptably high. A risk control is then chosen, verified,
and put into place. It would be expected that some months after the control has been
put into place, a review of the adequacy and effectiveness of that control should be
made. This is to ensure that it is achieving its role in the workplace as expected by
those who undertook the risk assessment.
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Plant:
Title:
Reg. No:
Contact the Group OH&S coordinator at Holcim (US) for more detail on this form.
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Yes
or
no
Signed
and
dated
Date ........
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Example:
For
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Site Information -
Notification:
Person
Phone
Emergency Co-coordinator
_________________________________________
Plant/Site Manager
_________________________________________
_________________________________________
Fire Warden
_________________________________________
First Aid
_________________________________________
Plant Communication
Position
Telephone/s
_________________________________________
Call Number/Sign
_________________________________________
_________________________________________
CB
_________________________________________
Two-way radio/s
_________________________________________
Other
_________________________________________
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Notification Procedures
Should one of the persons listed not be on site - notification is to be to the next level.
1.
2.
Plant should notify whichever of the following they are first able to contact -
a)
Emergency Co-coordinator.
b)
Plant/Site Manager.
c)
Area Supervisor.
a)
b)
Co-ordinate response.
c)
Notify emergency services (If this has not already been done).
3.
It is the responsibility of all personnel on site to comply with all emergency plan requirements.
4.
5.
The Business Unit Manager should contact The Divisional General Manager.
NOTE: Only the Business Unit Manager or equivalent can talk to/liaise with media.
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Internal Requirements
Emergency Services
Activate
Phone ???
Siren
Police
First Aid
Fire Brigade
Extinguishers
Water Truck
Etc
Site Manager/Supervisor
Ambulance
Other Emergency
Services
Managing Director
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1.
Assess
eg. What, Where, How many, How badly, Is the danger passed?
2.
Alert
The local and site numbers are beside the office phone.
External:
3.
Dial Number
????
Assist / Evacuate
If all danger has passed, secure the accident scene and render assistance as necessary. If any
danger exists, make your way immediately to the evacuation area.
If you detect an emergency situation, NEVER place yourself in danger - Dont panic!
Make yourself aware of the emergency procedures and evacuation area at any site where you
work or visit; eg. Know that a siren sounding continuously means to make your way quickly and
calmly to the evacuation point.
Never leave the accident scene or evacuation area without letting someone know. Lives have
been lost trying to save someone who was safe but had not been accounted for.
Act calmly and dont panic.
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Evacuation Procedures
1.
2.
(Excepting for Flood, Storm or Cyclone/Hurricane threat) Leave immediately by the nearest exit
- Do not stop to collect personal belongings.
3.
Go straight to your head count area and report to the Emergency Coordinator.
4.
Do not leave your evacuation area until told by the Emergency Coordinator.
If safe, a designated person should:
a)
For fire
i)
Shut down machinery and all ENERGY sources.
ii)
Close all windows.
iii)
Close all doors behind them.
b)
c)
d)
For flood
i)
Shut down machinery and all except emergency ENERGY sources.
ii)
Close all windows and doors.
iii)
Sandbag entrances as appropriate
iv)
If possible, move computers and other electrical equipment to the highest area
inside the buildings.
v)
Stay indoors.
e)
EVACUATION AREAS are site specific and you must know where these are for any site that you are
on.
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4.
5.
Quickly assess the scene, noting the type of accident, possible hazards, and the number of
injured people and the nature of the injuries.
Check for any danger at the scene and try to anticipate further possible danger.
If there are any dangers - control them eg. turn off all electricity, control petrol spillage, and
secure unstable elements. traffic control.
DO NOT PLACE YOURSELF OR OTHERS IN DANGER.
Administer First Aid if qualified - Remain with the victim and arrange for immediate transport to
medical assistance ie. Ambulance.
Where the accident involves live electrical contact, do not touch any victim.
Turn off the power at its source if possible.
If not, use an unpainted wooden pole to break electrical contact or remove live wires.
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Fire on Neighboring or nearby Public Land - If you are told a fire is approaching your site
1.
2.
3.
4.
5.
Explosion
1.
2.
3.
4.
5.
6.
7.
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A mobile phone should be available at each site where no other communication exists to
ensure continued ability to communicate.
Notify the service provider.
Advise Business Unit/Site Manager.
Civil Disorder
1.
2.
3.
4.
5.
6.
7.
Recovery Plans
1.
2.
3.
The Business Unit Manager , Site Manager / Supervisor and others as required shall determine
the action to be taken based on individual requirements.
All requests for information by external bodies, including the media, shall be referred to the
Business Unit/Site Manager. Note however that many Government Personnel (e.g. Police and
Environmental or Occupational Health & Safety Inspectors) have very wide powers to require
the provision of information and/or actions to be taken during any emergency situations. Hence
all individual employees should always co-operate fully with such authorized personnel
The Corporate Crisis Management Team will be involved only at the request of the Chief
Executive Officer/Managing Director or the Divisional General Manager.
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A Lost Time Injury (LTI) is a work-related injury after which the injured person cannot
work for at least one full shift or full working day anytime after the shift or day on which
the accident causing the injury occurred.
Injuries causing Death or Permanent Disability are not counted as LTI's and so are not
in the Frequency or Severity Rates.
APPLICATION OF TARGETS
All Targets will be applied for all our own employees in all segments and business units
The Death/Permanent Disablement Rate Target will be applied for all sub-contractors, third parties
(contractors) and others where Holcim caused the accident
The Lost Time Injury Frequency Rate Target will be applied for all sub-contractors
While there are no specific Targets defined, records will be kept of the:
Total number of Accidents; and
The number of Lost Time Accidents
Involving all sub-contractors, third parties (contractors) and others where it is shown that Holcim
caused the accident
Hours Worked
Hours Worked includes the actual hours worked by the non-exempt hourly personnel, as well as
those for salaried exempt personnel.
Hours worked shall not be counted for vacations, holidays, sick leave, and any other off-duty time.
For salaried personnel, the hours shall be calculated by using a given value of 8 hours per day
times the number of days worked (as per HARP).
Number of Work Days Lost
Number of Work Days Lost is the number of work days (consecutive or not) after, but not including
the day injury occurred, during which the person would have worked but could not do so; ie. could
not perform the major duties of the work during all or any part of the workday or shift. The counting
of workdays lost ceases when the person returns to productive work.
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Sub Contractors
Sub contractors are persons who are engaged in work for Holcim and meet all three of the following
criteria:
Holcim directly controls the number of hours worked;
Holcim directly supervises the daily work activity; and
The subcontract personnel fulfill the functions normally performed by Holcim employees
with Holcim expertise or know-how.
(NOTE: This is the HARP definition)
Occupational Disease
An occupational disease is defined as a condition produced in the work environment over a period
longer than one workday or shift; ie. usually such a disease is due to repetitive factors over a period
of time. It may result from systemic infection, repeated stress or strain, chronic exposure to toxins,
poisons or other ongoing aspects of the work environment.
Occupational Injury: This is any injury such as a cut, fracture, sprain, amputation, or other harm
resulting from a work-related event or a single instantaneous exposure in the work environment.
T
Occupational Illness
Occupational illness is any abnormal condition or disorder, other than one resulting from an
occupational injury, caused by exposure to factors associated with employment. It includes acute
illnesses or syndromes and immediate reactions which may be caused by a harmful exposure due
to inhalation, absorption, ingestion or direct contact.
T
In order to report on their performance against the Targets, it will be necessary for all Group
companies to collect the following data:
Total number of Injuries causing Death
Total number of Injuries causing Permanent Disability
Total number of Lost Time Injuries
For all own employees and subcontractors, as well as 3rd parties (contractors) and any
others where it is shown that Holcim caused the accident
Total amount of time worked
Total FTE personnel
For all own employees and subcontractors separately
Total working hours lost in Lost Time Accidents
For all own employees only
NOTES:
Cement plants already collect and report this data in the Annual Technical Report (ATR) each year.
This requirement is now being extended to all parts of the Group, and will be done via HIP.
External reporting (outside Holcim) of both the Lost Time Injury Frequency Rate and the Lost Time
Injury Severity Rate will be done on a 24 month rolling average basis.
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Phone
+41 58 858 54 51
Im Schachen
Fax
+41 58 858 54 52
CH-5113 Holderbank/Switzerland
ohs-hgrs@holcim.com
www.holcim.com
11/2002