A HSE Management System is an integrated approach where all the 3 HSE factors are effectively managed to reduce risks in the workplace and environment. The objective of a HSE Management System is to provide a structured management approach to control health, safety and environmental risks.
International standard ISO 45001:2018 Occupational Health and Safety Management Systems lists down requirements with guidance for use. ISO 14001;2015 Environment Management Systems sets out the criteria for an environmental management system.
Regardless of the industry you are in, all organisations need a comprehensive, well-documented HSE management system to ensure that all personnel are safe and environment are protected. A HSE management system must be written down, communicated and practised.
The key elements of a successful HSE management system include:
A HSE plan is a strategic action plan which sets out all current and prospective risks for the company. It provides an analysis of all risks present, with an outline of how to remove said risks. This HSE plan helps to set up a framework for all workers to follow and be held accountable to maintain the HSE record of the workplace. A HSE plan also comprises of HSE inspection checklists and emergency response plans.
Risk assessments document all risks in the workplace. This helps in protecting all workers and surrounding people from potential hazards. All areas of HSE non-compliance are outlined in the assessment and aid in ensuring proper solutions are in place. After risk assessment, risk monitoring is to be conducted depending on the risk level to maintain HSE in place.
Reporting of HSE elements is needed to monitor the performance of HSE elements. HSE key performance indicators (KPI) are needed to measure the performance of the HSE aspects. These KPI help to identify areas that need improvement. KPI for HSE include Lost Time Injury (LTI), number of accidents and incidents, productive days, near misses, etc.
All workers need to receive adequate training on the various HSE rules and procedures at the worksite. A thorough training program includes all HSE aspects e.g. PPE training, fire drills, scheduled waste management, management of pollution control equipment, etc. These trainings must be recorded to keep track of the trainings to ensure a successful HSE management system.
In conclusion, management plays a critical role in making HSE management system a success.
Demonstration Of Safe Operation (DOSO) assessment is for non-major hazard installation as stipulated in Occupational Safety and Health (Control of Industrial Major Accident Hazards) Regulations 1996 or CIMAH regulations. DOSO is applied to an industry activity where the hazardous substance in the CIMAH regulations is less than the specified threshold quantity and more than 10% of the threshold quantity.
A manufacturer who falls under DOSO shall, at any time, show that he has-
identified the possible major accident hazards; and
taken adequate steps to:
prevent any major accident or minimize its consequences to persons and the environment; and
provide persons working on the site with the information, training, and equipment necessary to ensure their safety; and
prepared and kept up to date an adequate on-site emergency plan detailing how major accidents will be dealt with.
The content of the DOSO safety report shall be in accordance to the requirements of Schedule 6, CIMAH Regulation 1996. The main elements of the report are as follows:
Information relating to every hazardous substance involved in the industrial activity and its relevant quantity as listed in Schedule 2 of the CIMAH regulations, namely:
The name of the hazardous substance as given in Schedule 2 or, for a hazardous substance included under a general designation, the name corresponding to the chemical formula of the hazardous substance;
A general description of the analytical method available to the manufacturer in determining the presence of the hazardous substance or references to such method in the scientific literature;
A brief description of the hazards which may be created by the hazardous substance; and
The degree of purity of the hazardous substance, the names of its main impurities and their percentages;
A map of the site and its surrounding area to a scale large enough to show any feature that may be significant in the assessment of the hazard or risk associated with the site;
A scale plan of the site showing the locations and quantities of all significant inventories of the hazardous substance;
A description of the processes or storage involving the hazardous substance and an indication of the conditions under which it is normally held;
The maximum number of persons likely to be present on the site;
Information about the nature of the land use and the size and distribution of the population in the vicinity of the industrial activity to which the report relates; and
Information on the nearest emergency services (fire station, hospital, police station, community hall, etc.);
The staffing arrangements for controlling the industrial activity with the name of the person responsible for safety on the site and the names of the persons who are authorised to set emergency procedures in motion and to inform outside authorities;
The arrangements made to ensure that the means provided for the safe operation of the industrial activity are properly designed, constructed, tested, operated, inspected and maintained; and
The arrangements for training persons working on the site; and
Information relating to a potential major accident in the form of consequence assessment which contains the following:
A description of the potential sources of a major accident and the conditions or events which could be significant in giving rise to one;
A diagram of the plant in which the industrial activity is carried on sufficient to show the features which are significant as regards the potential for a major accident or its prevention or control;
A description of the measures taken to prevent, control or minimise the consequences of a major accident;
Information about the prevailing meteorological conditions in the vicinity of the site;
An estimate of the number of people on-site and off-site who may be exposed to the hazards considered in the report; and
The consequences to the surrounding areas in the form of appropriate mitigation measures where possible.
Although DOSO requirement may not be from a major hazard installation but if it is next to a major hazard installation, it could be a potential initiating event of major accidents to its neighbor, hence why care must be taken for DOSO site so as to minimize the impact to the people onsite and offsite.
A HSE Management System is an integrated approach where all the 3 HSE factors are effectively managed to reduce risks in the workplace and environment. The objective of a HSE Management System is to provide a structured management approach to control health, safety and environmental risks.
International standard ISO 45001:2018 Occupational Health and Safety Management Systems lists down requirements with guidance for use. ISO 14001;2015 Environment Management Systems sets out the criteria for an environmental management system.
Regardless of the industry you are in, all organisations need a comprehensive, well-documented HSE management system to ensure that all personnel are safe and environment are protected. A HSE management system must be written down, communicated and practised.
The key elements of a successful HSE management system include:
A HSE plan is a strategic action plan which sets out all current and prospective risks for the company. It provides an analysis of all risks present, with an outline of how to remove said risks. This HSE plan helps to set up a framework for all workers to follow and be held accountable to maintain the HSE record of the workplace. A HSE plan also comprises of HSE inspection checklists and emergency response plans.
Risk assessments document all risks in the workplace. This helps in protecting all workers and surrounding people from potential hazards. All areas of HSE non-compliance are outlined in the assessment and aid in ensuring proper solutions are in place. After risk assessment, risk monitoring is to be conducted depending on the risk level to maintain HSE in place.
Reporting of HSE elements is needed to monitor the performance of HSE elements. HSE key performance indicators (KPI) are needed to measure the performance of the HSE aspects. These KPI help to identify areas that need improvement. KPI for HSE include Lost Time Injury (LTI), number of accidents and incidents, productive days, near misses, etc.
All workers need to receive adequate training on the various HSE rules and procedures at the worksite. A thorough training program includes all HSE aspects e.g. PPE training, fire drills, scheduled waste management, management of pollution control equipment, etc. These trainings must be recorded to keep track of the training to ensure a successful HSE management system. In conclusion, the management plays a critical role in making HSE management system a success.
Layer of Protection Analysis also known as LOPA is a risk management technique commonly used in the chemical process industry that can provide a more detailed, semi-quantitative assessment of the risks and layers of protection associated with hazard scenarios. LOPA is a means to identify the scenarios that present the most significant risk and determine if the consequences could be reduced by the application of inherently safer design principles. LOPA can also be used to identify the need for safety instrumented systems (SIS) or other protection layers to improve process safety.
LOPA is a risk assessment methodology which uses simplified, conservative rules to define risk as a function of both frequency and potential consequence severity. LOPA is defined as a simplified risk assessment of a one cause – one consequence pair.
Conceptually, LOPA is used to understand how a process deviation can lead to a hazardous consequence if not interrupted by the successful operation of a safeguard called an independent protection layer (IPL). An IPL is a safeguard that can prevent a scenario from propagating to a consequence of concern without being adversely affected by either the initiating event or by the action (or inaction) of any other protection layer in the same scenario.
LOPA can be used at any point in the lifecycle of a project or process, but it is most cost effective when implemented during front-end loading when process flow diagrams are complete and the P&IDs are under development. For existing processes, LOPA should be used during or after the HAZOP review or revalidation. LOPA is typically applied after a qualitative hazards analysis has been completed, which provides the LOPA team with a listing of hazard scenarios with associated consequence description and potential safeguards for consideration.
The six major steps to the LOPA process are as follows:
Record all reference documentation
Document the process deviation and hazard scenario under consideration by the team
Identify all of the initiating causes for the process deviation and determine the frequency of each initiating cause
Determine the consequence of the hazard scenario
List the IPLs that can completely mitigate all listed initiating causes
Provide specific implementable recommendations
There are four primary benefits to implementing LOPA over other SIL assignment methodologies procedures.
Due to its scenario-related focus on the process risk, LOPA often reveals process safety issues that were not identified in previous qualitative hazards analysis.
Process hazards are directly connected to the safety actions that must take place, providing clear identification of the safety instrumented systems and associated SIL.
It has been proven effective in resolving disagreements related to qualitative hazards analysis findings.
LOPA often identifies acceptable alternatives to the SIS, such as adding other layers of protection, modifying the process, or changing procedures. This provides options for the project team to evaluate using cost/benefit analysis, allowing the most cost effective means of risk reduction to be selected.
In conclusion, LOPA allows the safety review team an opportunity to discover weaknesses and strengths in the safety systems used to protect employees, the plant, and the public.
Emergency response plan is a definite plan to deal with major emergencies.
Emergency response plan includes:
All possible emergencies, consequences, required actions, written procedures, and the resources available.
Detailed lists of emergency response personnel including their cell phone numbers, alternate contact details, and their duties and responsibilities.
Floor plans.
Large scale maps showing evacuation routes and service conduits (such as gas and water lines).
An emergency response plan specifies procedures for handling sudden or unexpected situations to:
Prevent fatalities and injuries.
Reduce damage to buildings, stock, and equipment.
Protect the environment and the community.
Accelerate the resumption of normal operations.
The emergency response plan includes the forming of an Emergency Response Team (ERT). Each of the ERT members will have specific roles and responsibilities during an emergency. ERT generally consists of:
Emergency Commander
Emergency Coordinator
First Line Crew / Rescue Squad
First Aider
Security Team
Floor Warden
Completing a comprehensive plan for handling emergencies is a major step toward preventing disasters. Exercises and drills may be conducted to practice all or critical portions (such as evacuation) of the plan. The plan should be revised when shortcomings have become known and should be reviewed at least annually.
Everything maintenance teams need to know about OSHA, its regulations, compliance standards and how to avoid OSHA violations.
Here’s a scary stat: 85 health and safety violations were committed every day across the US in 2018. In total, there were more than 31,000 fines doled out for breaking the Occupational Safety and Health Administration’s (OSHA) top 10 health and safety violations alone.
Besides the potential for accidents, injury, and death, these fines inflicted a heavy toll on the bottom line, costing businesses over $400 million last year.
Many of the top OSHA violations have a connection to everyday maintenance tasks, especially for those working in manufacturing. Another thing they had in common? They were all preventable.
With solid planning and some helpful technology, it’s easy for maintenance teams to avoid health and safety violations while creating a better health and safety program.
What is OSHA?
OSHA is the government-run organization in charge of assuring safe and healthy working conditions for millions of public and private sector employers and workers across the US. They do this by setting and enforcing standards and by providing training, outreach, education and assistance.
What is the purpose of OSHA?
OSHA is responsible for the hefty price tags attached to noncompliance and is the organization that maintenance teams have to impress most often when it comes to health and safety audits.
OSHA regulations, OSHA compliance, and OSHA penalties
The following is a brief rundown of the rules and responsibilities mandated by OSHA and the impact of breaking these regulations.
What are employers responsible for?
Under OSHA law, employers are responsible for providing a safe and healthy workplace for their workers. Employers must provide workers with a hazard-free workplace and must follow all OSHA standards. Employers must find and correct all safety and health problems, first by changing working conditions, like switching to safer chemicals, and then by providing protective equipment.
Besides the potential for accidents, injury, and death, OSHA violations inflicted a heavy toll on the bottom line, costing businesses over $400 million last year.
Other guidelines that employers must follow include:
Prominently displaying official OSHA requirements, OSHA citations, and injury and illness data.
Informing workers about hazards in a language they can understand through training, labels, alarms, and other methods.
Keeping accurate records of work-related injuries and illnesses.
Performing tests in the workplace, such as air sampling.
Providing the required personal protective equipment at no cost to workers.
Not retaliating against workers for using their rights under the law.
These are some examples of the broad policies employers at production facilities need to follow. However, there are many OSHA regulations that apply to specific industries or in certain regions. Some examples of these standards include providing fall protection, ensuring safety in confined spaces, putting guards on dangerous machines, and providing respirators to employees.
What rights and responsibilities do workers have?
Workers also have a responsibility to attend training, ensure they report unsafe work, and follow guidelines set out by employers and OSHA. In addition to their responsibilities, workers also have several rights under OSHA laws, including:
The right to file a confidential complaint to have their workplace inspected.
The right to receive copies of the results from health and safety tests and monitoring.
The right to participate in an OSHA inspection and speak in private with the inspector.
The right to file a complaint with OSHA if they have been retaliated against by their employer.
The right to file a complaint if punished or retaliated against for acting as a whistleblower.
How are OSHA standards created?
OSHA standards-setting process is a multi-step activity that relies heavily on public engagement. New standards can be recommended either by OSHA itself or through third-party petitions from organizations like the National Institute for Occupational Safety and Health, state and local governments, and labour representatives.
After deciding to move forward with a new standard, OSHA often asks the public for their feedback and insight. After considering all information and testimonies, OSHA develops and issues a final standard that becomes enforceable.
What happens during an OSHA inspection?
When OSHA finds employers who are in violation of the regulations, inspections are initiated without advance notice by compliance officers. Here’s how the on-site inspections usually happen:
The compliance officer presents their credentials.
They explain why the workplace was selected for inspection and describe the inspection process, including walkaround procedures, employee representation, and employee interviews.
The compliance officer and facility representatives walk through the workplace, inspecting for hazards.
The compliance officer talks with the employer and employee representatives about their findings.
If no hazards or OSHA violations are found, the inspection is over. If an inspector finds violations or serious hazards, they may issue a citation and/or fine. A citation outlines methods that can be used to fix a problem and a deadline for correcting the issue, as well as the date by which the corrective actions must be completed.
What are the fines for OSHA violations?
Fines for non-compliance of OSHA regulations can vary based on the seriousness of the violation and the organization’s record and the industry. However, OSHA has outlined maximum fines, which for 2018 include $13,260 for minor and serious violations and $132,598 for willful or repeat violations.
The most common OSHA violations
Below are the 10 OSHA violations most frequently committed by workplaces in 2018:
Fall Protection – General Requirements (Standard 1926.501)
7,270
Hazard Communication (Standard 1910.200)
4,552
Scaffolds – General Requirements (Standard 1926.451)
3,336
Respiratory Protection (Standard 1910.200)
3,118
Lockout/Tagout (Standard 1910.147)
2,944
Ladders (Standard 1926.1053)
2,812
Powered Industrial Trucks (Standard 1910.178)
2,294
Fall Protection – Training Requirements (Standard 1926.503)
1,982
Machine Guarding (Standard 1910.212)
1,972
Personal Protective and Lifesaving Equipment – Eye and Face Protection (Standard 1926.95)
1,536
How maintenance teams can prevent OSHA violations
Here are a few tools and techniques maintenance teams can use to steer clear of violating some OSHA regulations. Each of these tips can be implemented through maintenance management software, such as a CMMS.
Hazard communication
It’s never easy to tear yourself away from a job when your to-do list is a mile long. Then again, when you don’t make time for health and safety tasks, it can result in a huge fine. Over 4,500 companies faced this exact situation in 2018 after they violating the OSHA’s hazard communication standard by failing to provide proper hazard training and maintain the necessary data sheets.
OSHA is also responsible for the hefty price tags attached to noncompliance, and is the organization maintenance teams have to impress most often when it comes to health and safety audits.
Maintaining records and providing health and safety training is often a hassle, even if it’s extremely important. Having an efficient method for storing employee information can go a long way in saving you time and helping you stay compliant. Create employee profiles for everyone on the maintenance team. On each profile, list the training that person has, the dates they completed training, and the training they still need. Make sure to note deadlines for certification renewals on each profile. Create a notification system so both you and the employee are alerted about any training that is about to expire. Lastly, use these profiles to communicate any hazardous situations or changes in policy to all staff.
Lockout/tagout
Lockout/tagout violations ranked as the fifth-most-common breach of OSHA regulations during 2018, even with it being standard procedure across the maintenance and manufacturing world. Facilities were cited for failing to implement an energy control program and to provide training.
Energy control programs help maintenance staff avoid being injured by the massive amounts of hazardous energy that is often stored by equipment. Although many facilities have an energy control program, they are often not implemented properly.
One of the biggest obstacles to policy implementation is a lack of accessibility. Technicians are extremely busy and are often overwhelmed on a daily basis. If they are working on an asset, need to conduct a lockout/tagout and don’t know the proper procedure, it’s not likely that they will spend valuable time looking for the information. Making an energy control program document available digitally and accessible through a mobile device eliminates this problem, is a factor in the successful implementation and helps facilities avoid a costly OSHA violation.
Fall protection – training and general requirements
Companies were handed over 9,000 fines for inadequate fall protection in 2018, with these violations scoring top spot and eighth place on the OSHA’s list. The most common rules that were broken were failing to provide sufficient training and proper protective equipment.
Training your whole workforce might be the end goal of your fall protection plan, but it might not be realistic in the short term. However, there are a few ways employers can better manage their existing pool of trained maintenance staff to avoid violating OSHA regulations. You must be able to cross-reference work orders with staff who are certified (and who have proof of certification). The best way to do this is through a digitalmaintenance work order system. This system can tell you who is available and the best person to do the job, so no one is working at heights without the proper training.
Equipment for fall protection often includes harnesses, guardrails, anchors, and other, larger pieces. These items need to be maintained and stored properly. That is why a well-built inventory management system is a must for safety and to avoid OSHA violations. The ability to track where parts are stored, their history of use, and how often they’ve been maintained is crucial. It ensures that workers know where to find the proper protective equipment when they need it and that they know it will be in optimal working condition. Having a digital inventory system makes this information more accessible and creates a more efficient process.
Machine guarding
Machine guarding was another common OSHA violation in 2018, averaging 5.5 infractions per day. Inspectors cited companies for point of operation and for guards that were not attached to machines.
It’s easy to assume this violation can be avoided by simply walking around your facility, installing guards where needed and training staff to always use them when necessary. However, this isn’t a set-it-and-forget-it issue. It requires an ongoing effort to ensure guards are installed and maintained properly. A guard may rust over time, diminishing its effectiveness. An employee may remove a guard for a project and not replace it properly or at all. That is why you and your maintenance team must be diligent about machine guarding.
One way to ensure consistency with machine guarding at your facility is through automated work orders and maintenance triggers. Determining a maintenance trigger for each guard will help you plan an inspection, repair, or replacement well ahead of time. For example, a certain guard may be slated for replacement every three months. These maintenance triggers can then be scheduled using an automated work order system to ensure you’ll be alerted of upcoming maintenance or inspection for machine guards so tasks don’t fall through the cracks and leave you vulnerable to citations or fines.
Personal protective and lifesaving equipment
The last entry on the OSHA’s list of top violations is one that can apply to many maintenance activities and can have a huge impact on safety. There were over 1,500 instances of facilities failing to provide personal protection equipment (PPE) and lifesaving equipment or failing to ensure employees used them in the right situation.
PPE can vary from job to job in a facility. One maintenance task may require an individual to wear hearing protection while another may call for a dust-blocking face mask. It can be difficult for staff to remember what PPE is associated with which job, which means tasks are not always completed in the safest way (or in accordance with OSHA regulations).
Solving this problem can be as easy as attaching a checklist to each maintenance task or asset that outlines the required PPE. Not only will this standardize PPE practices at your facility, but it also reminds the staff what they should be doing. If the checklist is available in a digital format, it is even more accessible to staff, which means that the protocols are more likely to be followed.
Recent Comments