The Health and Safety Audit – Chemical Industry Experience JFA

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.

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Preamble

A gentle disclaimer

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.

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Typical factory layout

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
A selection of typical plant details

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
What is it?

It’s a bit like a financial audit

 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!

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
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

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Corporate Concerns

Hatfield UK
High Speed
Derailment
Oct. 2000

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

Four fatalities and 100 injured

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Where in the overall safety scheme of things?

Tools for Ensuring Safety

MAJOR OPERATIONAL WORKPLACE

HAZARDS INTEGRITY SAFETY
DESIGN SYSTEMS ACTIVITIES
Hazard Analysis Procedures Housekeeping
Risk Analysis Reporting Vigilance
HAZOP Statistics Notification
Protection Systems Support Compliance

Design Inspection
Team Health and Safety Audit Tour

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Who is involved?
Typical Organisation Structure
Group Group HSE
Management Manager
Third Party
Independent
(Occasional)
Data and
Statistics
Site A Site B
Management Management Audit Team Site B
Group HSE Manager (Chair)
Safety Manager
Safety
Safety Operations rep (varies)
Officer
Officer Management rep
Site A rep (option)
(Third Party Independent)
Operations Operations
John Freeman Associates 2005
 The Health and Safety Audit – Chemical Industry Experience JFA
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

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
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?

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
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)
John Freeman Associates 2005
 The Health and Safety Audit – Chemical Industry Experience JFA
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

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Safety Statistics

To be meaningful, statistics must be consistent and accurate

 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

Central recording and analysis ensures consistency

Care with definitions such as “Lost-time injury” – how many days?
Figures are only useful if lessons are learned and improvement targets imposed
Rigorous recording is essential

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Procedures – availability and adherence
Defined procedures must be set down
 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

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
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

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Safety Systems

Some of the more important Systems to check

 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.

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Change Control

Flixborough – UK 1974
Plant modification destroys
original design integrity

Failed flexible connector

Aftermath

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Emergency Procedures

Investigate preparedness for emergencies

 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?

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
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

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Health monitoring policy

Requirements depend on local circumstances

 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

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
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

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Especially Vulnerable Situations

 Growth by Acquisition
 High Staff Turnover
 Regular use of Temporary Staff
 Extensive use of Contractors
 Language Differences

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
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.

John Freeman Associates 2005

 The Health and Safety Audit – Chemical Industry Experience JFA
Don’t be like this guy!

John Freeman Associates 2005