JFA The Health and Safety Audit – Chemical Industry Experience John Freeman Associates 2005 Basis of Presentation The following notes are based on experience.

John Freeman Associates 2005

JFAJFAThe Health and Safety Audit – Chemical Industry Experience

Basis of Presentation

The following notes are based on experience of audits in the Chemical Industry – both operational audits and acquisition due diligence.

Much of the experience in this field has been for a multi-site international manufacturer based in Australia, and has covered sites in the UK, France, Spain, Austria, The Netherlands, Egypt, the USA, and Canada.

The plants concerned involve medium scale organic synthesis, are not large, but are complex, and use a wide range of flammable, toxic, corrosive and environmentally sensitive materials.

Based on a multi-site organisation, it is nevertheless relevant to any large industrial enterprise with multiple operations.

It is not unusual to combine such audits with a simultaneous audit of environmental issues.



Preamble

The author has little knowledge of, and no

experience of High Energy Physics facilities. It is

hoped however that the audience can draw

something useful from experience in a world

where molecules are of more concern than are

particles.

A gentle disclaimer



Typical factory layout



A selection of typical plant details



What is it?

Similarities It provides an external overview It aims to confirm due propriety of “internal” procedures

Differences It is Management initiated – not a regulatory imposition A principal aim is improvement, training and development The downside is human suffering – not negative dollars!

It’s a bit like a financial audit



Why do we have them?

To justify fine words in policy statements

A duty of care to employees and neighbours

To reduce risks to the business of untoward events

Management being seen to be serious about safety

For consistent interpretation of management policy

To improve safety by training and development

Internal cross-fertilisation of experience and ideas



Corporate Concerns

Hatfield UK

High Speed DerailmentOct. 2000

July 10 2003 Two rail companies and six of their executives and staff have been chargedwith manslaughter following apolice investigation into the 115 mph Hatfield rail crash…….

Four fatalities and 100 injured


JFAJFAThe Health and Safety Audit – Chemical Industry ExperienceWhere in the overall safety scheme of

things?

Tools for Ensuring Safety

MAJORHAZARDS

OPERATIONALINTEGRITY

WORKPLACESAFETY

DESIGNHazard Analysis

Risk AnalysisHAZOP

Protection Systems

SYSTEMS Procedures ReportingStatisticsSupport

ACTIVITIES Housekeeping

VigilanceNotificationCompliance

Health and Safety Audit

InspectionTour

DesignTeam



Who is involved?

GroupManagement

Group HSEManager

Site AManagement

Site BManagement

SafetyOfficer

SafetyOfficer

Operations Operations

Audit Team Site BGroup HSE Manager (Chair)Safety ManagerOperations rep (varies)Management repSite A rep (option)(Third Party Independent)

Third PartyIndependent(Occasional)

Typical Organisation Structure

Data andStatistics



How do we go about it?

Typically annual, the main steps are:

1 – Collation of statistics and comparative performance review

2 – Circulate self-audit questionnaire to each site

3 – On-site review of responses and Action Progress

4 – Site tour by Audit Team

5 – Round up discussion and Action Plan



What is the Auditor looking for?

Throughout the process, the Audit Team

should be asking itself: Are Systems and Procedures appropriate and

adequate? Are Systems and Procedures correctly followed? Are the correct Documentary Records available? Are the H&S Facilities and Equipment appropriate

and adequate? Is there a general awareness of Safety as an

issue? Is there a programme for safety training? Could the organisation respond to a serious

emergency?



Typical Audit Team

Leader – Senior Safety Manager Responsible directly to Top Management (e.g. Group

Board) Not responsible for operations

Local personnel Local safety officer and a management representative Operating supervisor of a specific area under review Visiting representative from another site/area

Others (if needed) To give full experience cover of specialist technology and

general operation/engineering (e.g. Chemist + Engineer)

Independent Neutral (Say every third audit or so)



Actions and Feedback

Action Programme to correct deficiencies

identified Agreed actions (Where the team has authority to decide) Recommended Actions (If 0ther authorisation is needed) Include Target dates

Progress Reviews of previous action programme Record Completions Provide early prompts Highlight missed dates Record decisions not to proceed – with reasons



Safety Statistics

Typical statistical analysis would include Injury Frequency Rates – Lost time, Medical

treatment Injury Severity Index – extent of lost time Injury analysis - by type, location, worker group

To be meaningful, statistics must be consistent and accurate

Central recording and analysis ensures consistencyCare with definitions such as “Lost-time injury” – how many days?Figures are only useful if lessons are learned and improvement targets imposedRigorous recording is essential



Procedures – availability and adherence

Standard Operating Procedures Default procedures for all main operations Are they Available, Accessible and Clear Use them or change them – don’t ignore them Obtain user views

Maintenance Safety Procedures Permit to Work System – hot work, confined spaces,

heights Isolation and Lock-off arrangements – a critical area Authority to sign – training essential

Defined procedures must be set down



Training Procedures

Safety Training Management, Factory workers, Office workers Specialist functions (e.g. Fire, Rescue)

Induction programmes New Employees Temporary Employees Contractor’s personnel Visitors



Safety Systems

Change Control System Design vetting of any modification to plant, process or alarm

and trip functions

Accident Reporting, Investigation and Remedial

Actions

Abnormal Incident Reporting Reporting, Investigation and Remedial Actions as for Accidents

Inspection and Testing programmes Pressure Systems, Lifting Equipment, Access Equipment, etc.

Some of the more important Systems to check



Change Control

Failed flexible connector

Aftermath

Flixborough – UK 1974

Plant modification destroysoriginal design integrity



Emergency Procedures

Response Plan for a major emergency Does it exist and is it well known and understood Liaison with local services – e.g. Fire Service?

Internal Emergency Actions Fire fighters – trained? equipped? First aiders – availability and training Evacuation drill – clearly posted? practiced?

Notifications – to management, authorities, local

services Nominated person? Standard routine?

Investigate preparedness for emergencies



Health and Safety Facilities

First aid Location and Equipment Trained personnel and call-out arrangements

Fire fighting and Rescue Extinguishers, breathing equipment, trained

personnel

Security Visitor control – record of people on the site Intruder prevention



Health monitoring policy

Occupational Health Issues General medical checks and hearing tests

• On first employment• At regular intervals

Specific Risk Areas Exposure to chemicals – measurement of ambient

levels Known potential health hazards

• Biological checks

Requirements depend on local circumstances



Some general comments

Avoid a “blame” culture Encourage positive approach Inter site participation helps

Numerical basis for performance assessment Not generally successful unless based on objective

measures Subjective assessment is not usually satisfactory

Site visits help to reinforce comments Photographs of areas of concern

Review meetings are as much about Training as

Communication



Especially Vulnerable Situations

Growth by Acquisition

High Staff Turnover

Regular use of Temporary Staff

Extensive use of Contractors

Language Differences



In Conclusion

A systematic and regular audit of Safety Systems and Performance can lead to significant improvements.

Benefits include:Consistent and effective implementation of policy.Protection against corporate exposure.Reductions in accident rates.Improvements in Safety Training and Development.Cross fertilisation in Safety thinking.Increased awareness of the importance attaching to Safety issues.



Don’t be like this guy!

JFA The Health and Safety Audit – Chemical Industry Experience John Freeman Associates 2005 Basis of Presentation The following notes are based on experience.

Documents

experience of audits

financial audit slide

injured slide

gentle disclaimer slide

typical factory layout

operational audits

multisite organisation

policy statements