Element IA1: Principles of Health and Safety Management
Element IA1: Principles of Health and Safety Management
© Santia 2013 ® – restricted use only
Page 1 sc/1026/v2
Element IA1: Principles of Health and Safety Management
© Santia 2013 ® – restricted use only
Page 2 sc/1026/v2
Element IA1: Principles of Health and Safety Management
© Santia 2013 ® – restricted use only
Page 2 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Contents Reasons for Managing Health and Safety 1) Moral Reasons 2) Legal Reasons 3) Economic Reasons
Societal Factors Which Inuence Health and Safety Standards and Priorities Economic Climate Government Governme nt Policy and Initiatives Globalisation Globalisati on of Business Migrant Workers Levels of Sickness Absence and Incapacity Societal Expectatio Expectations ns Corporate Social Responsibili Responsibility ty (CSR)
Effective Health and Safety Management Systems Denitions Health and Safety Management Systems Principles of Quality Management Systems and Environmental Management Systems Integrated Management Systems Benets of Introducing a Management System
The Role and Responsibilities of the Health and Safety Practitioner
4 4 5 6
7 7 8 9 9 11 11 12 15 15 16 28 32 33
The Health and Safety Practiti Practitioner oner and Health and Safety Management Systems Inuencing Ownership and Conduct Within the Organisation Competence and Continuing Professiona Professionall Development Evaluating and Developing Their Own Practice Professionall Ethics Professiona Conict of Interest
34 34 35 36 37 38 39
References
40
© Santia 2013 ® – restricted use only
Page 3 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Reasons for Managing Health and Safety There is a complex web of social pressures driving the agenda for the effective management of health and safety. Typically these are considered in three broad categories: ▪
Moral;
▪
Legal; and
▪
Economic.
1) Moral Reasons Everyone has a moral obligation not to cause harm to others. Employers have a moral obligation, based on the concept of a duty of reasonable care, towards their employees and other persons who may be affected by their business products, services and activities. The right to life is the most fundamental right. Yet according to ILO 2005 gures every year 2.2 million men and women are deprived of that right by occupational accidents and workrelated diseases. By conservative estimates workers suffer 270 million (as of ILO 2005 gures) occupational accidents and 160 million occupational diseases each year. Deaths and injuries take a particularly heavy toll in developing countries, where large numbers of workers are concentrated in primary and extractive activities such as agriculture, logging, shing and mining - some of the world’s most hazardous industries. This social and economic burden is not evenly distributed. Fatality rates in some European countries are twice as high as in some others, and in parts of the Middle East and Asia fatality rates soar to four-fold those in the industrialised countries with the best records. Certain hazardous jobs can be from 10 to 100 times riskier, depending on the country. Employers should not place any person at risk of death, injury or ill-health. Society demands that employers demonstrate a positive moral attitude towards health and safety.
© Santia 2013 ® – restricted use only
Page 4 sc/1026/v2
Element IA1: Principles of Health and Safety Management
2) Legal Reasons Law is a body of rules designed to regulate the behaviour of society. The effects of law can either be preventative, punitive or compensatory. In many parts of the world, law is divided into two sections criminal and civil law.
Criminal Law A crime is an offence against the state, which can be addressed within the legal framework of each particular country with punitive consequences. Punitive - nes and prison sentences may be imposed with the aim of punishment, deterrence and reformation.
Civil Law A civil action is brought between individuals, or groups of individuals, for compensatory reasons - whereby the claimant is seeking either nancial compensation or a court order to prevent a certain activity or settle a grievance from the respondent. In some countries civil actions by the claimant have to demonstrate that the employer was negligent in some way i.e. the employer was at fault. In other countries such as Australia and New Zealand they operate a no fault compensatory system where if somebody is injured at work they receive compensation from the State.
Self Regulation Modern health and safety laws tend to set targets following a style based on ‘goal setting’ which encourages organisations to self regulate, rather than relying on compliance with specic technical requirements. These place more emphasis on the duty holder to comply with the principles and requirements of the law rather than the enforcing authority laying down, and then enforcing prescriptive technical rules. In this goal setting environment, the enforcing authority not only takes on a role of enforcer and punisher where these laws have been broken but also a role of adviser, providing guidance and information on how these laws may be complied with. The broad target is the adequate control of risks to the health and safety of employees and others.
© Santia 2013 ® – restricted use only
Page 5 sc/1026/v2
Element IA1: Principles of Health and Safety Management
3) Economic Reasons The ILO gures of workers suffering 270 million occupational accidents and 160 million occupational diseases each year would suggest a signicant cost to both the employer and the state. The costs of accidents will vary from country to country depending upon many factors such as the country cost base, the social security system and the medical care regimes. The true cost of accidents is a lot higher than most people realise, with indirect costs being substantially more than the direct costs involved. It is therefore difcult to estimate the cost of accidents on a country by country basis but for illustrative purposes an example is the UK’s HSE Guidance Note HSG 96, ‘Cost of Accidents at Work’ which illustrates the signicance of the cost of accidents. Further costs to an organisation may result from absenteeism, compensatory insurance costs, preventative enforcement action, legal costs and punitive nes, loss of business reputation and business opportunity. The costs of health and safety control programmes (precautionary and preventive measures) are usually easily recognised and calculated as a bottom-line expense. The cost of failure is less easy to calculate, as the losses tend to be absorbed into operating costs. Costs include: ▪
Accident investigation;
▪
Payments for non productive time (injured persons);
▪
Payments for non productive time (witnesses, investigators, rst-aiders, clearing up, etc.);
▪
Replacement labour (probably less effective);
▪
Training for replacement labour;
▪
Business interruption / disruption;
▪
Loss of reputation;
▪
Damage repair;
▪
Replacement plant;
▪
Compensation payments;
▪
Legal costs and fees; and
▪
Insurance.
The true costs would be very difcult and time consuming to calculate.
© Santia 2013 ® – restricted use only
Page 6 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Societal Factors Which Inuence Health and Safety Standards and Priorities Health and Safety standards and priorities can be inuenced by many societal factors, these include; ▪
Economic climate;
▪
Government policy and initiatives;
▪
Globalisation of business;
▪
Migrant workers;
▪
National levels of sickness absence and incapacity; and
▪
Corporate social responsibility
Economic Climate Research by the Institute of Employment Research (IER, 2005) at the University of Warwick, has suggested that the injury and ill health incident rates are counter cyclical, with rates decreasing during recessions. Subsequently a paper published by the HSE Economic Analysis Unit in May 2009 entitled “HSE Strategy Launch, Background Paper: the economic evidence”, suggests that during recessions injury rates usually fall due to fewer newly hired workers being used, thus leading to higher than average levels of experience within the workforce. This can also be combined with less product demand resulting in less hours being worked and therefore less fatigue and work production pressures. (HSE, 2009). Against this however is possible corner cutting by employers and less investment and training which could lead to more injuries. However, past recessions have shown that injury rates have fallen despite this possibility. The paper suggests there is however less evidence when it comes to ill-health. Less product demand might have a positive effect on work-related stress and more experienced workers might have a better risk perception regarding health risks. However, health/welfare issues could be subject to cost-cutting by the employer and non-work factors including unemployment / deprivation and general ill-health could have an adverse effect possibly leading to stress. In the recession of 2010 there is evidence that injury rates have fallen. However, the paper suggests there are differences to previous recessions: ▪
The origins of the credit crunch, nancial and housing markets;
▪
The speed and depth of the downturn; and
▪
The scale and nature of response –scal and regulatory.
© Santia 2013 ® – restricted use only
Page 7 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Turning to the response by employers, the paper reports that there is a “mixed picture with regard to ‘corner cutting’”. One survey showed that employees were reluctant in raising health and safety concerns in the current economic climate while half of company directors surveyed said they would cut bonuses rather that cut health and safety spending. The paper predicts that as the UK comes out of recession there may be a rise in injury rates due to an increase in hours worked and new workers hired – possibly with little previous experience as those laid off may have left the labour market.
Government Policy and Initiatives Each countries government will inuence through its policies the perception of health and safety by each countries employers and employees
The Health & Safety of Great Britain – Be Part of the Solution In 2009 the HSE launched its Strategy “The Health & Safety of Great Britain – Be Part of the Solution”. However, no measurable targets for the reduction of accidents or ill health, were laid out in either the Strategy or the Business Plan.
EU Strategy Occupational accidents should be cut by a quarter across the EU under a new ve-year strategy for health and safety at work through a series of actions at European and national levels in the following main areas: ▪
Improving and simplifying existing legislation and enhancing its implementation by exchange of good practices, awareness-raising campaigns and better information and training;
▪
Dening and implementing national strategies adjusted to the specic context of each Member State;
▪
Mainstreaming of health and safety at work in other national and European policy areas (education, public health, research) and nding new synergies; and
▪
Better identifying and assessing potential new risks through more research, exchange of knowledge and practical application of results.
© Santia 2013 ® – restricted use only
Page 8 sc/1026/v2
Element IA1: Principles of Health and Safety Management
ILO Five Pillars Strategy The ILO have developed a ve pillars strategy for a culture of preventing workplace accidents in business and society: 1.
Reducing work accidents and occupational diseases (Vision Zero);
2.
Raising awareness, developing competencies and capacity building;
3.
Cooperation between public health and OSH;
4.
Health and safety as an integral part of lifestyle; and
5.
Integrating prevention into the social security system.
Globalisation of Business Two departments of the United Nations recently warned that globalisation may considerably increase the number of work-related diseases and injuries in the next century. They said the pressures for deregulation of the basic standards for health and safety is growing. Dr Richard Helmer of the World Health Organisation (WHO) said, “in order to reduce costs, industries with their accompanying occupational hazards are being relocated to developing countries - home to 75 per cent of the global workforce.” There are about 2.6 billion workers in the world as a whole. Dr Jukka Takala, Chief of the International Labour Organisation’s (ILO) Health and Safety Programme, estimates that there are 250 million accidents in the workplace each year, leading to 335,000 fatalities. One million people die each year from the 160 million illnesses caused by pollution and toxic materials and processes. One hundred thousand chemicals are in use. Of these 350 are known to be carcinogens and 3,000 are allergenic. Illnesses include respiratory and cardiovascular disease, cancer and reproductive and neurological problems. In the least developed countries most workers are involved in production of raw materials—agriculture and mining. This means heavy and noisy physical work and exposure to pesticide sprays, dusts and parasitic and infectious diseases. In industrialising countries, less advanced and more hazardous technologies are used. The extent of illnesses and injuries is unknown. In industrialised countries and increasingly elsewhere, more than half the workers suffer from psychological stress.
© Santia 2013 ® – restricted use only
Page 9 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Migrant Workers Research from the Migration Research Unit, University College London, shows that of those entering the UK on work permits, the biggest group was from India (mainly health and IT), followed by the USA (mainly business). In addition, over 80 per cent of migrant workers are under 35. Many migrant workers face no, or very little, increased risk. They speak uent English, may have worked in the UK for many years and have the same working conditions and security as non-migrant workers. Nevertheless there is no doubt that migrant workers with low English language skills or with vulnerable employment or residency status are at greater risk. HSE Research Document RR502 – “Migrant workers in England and Wales: An assessment of migrant worker health and safety risks”, states that there is no current method of identifying whether there are any specic health and safety risks for migrant workers. Existing Health and Safety Executive (HSE) programmes and recording systems only report a limited number of workplace incidents and there is no systematic way of identifying whether someone is a recent migrant. Consequently it is impossible to document, on the basis of the available statistics, whether migrants are in a higher risk category than local workers. However, RR502 does reveal that migrants are more likely to be working in sectors or occupations where there are existing health and safety concerns and that their status as new workers that may place them at added risk, due to a range of factors including: ▪
Relatively short periods of work in the UK;
▪
Limited knowledge of the UK’s health and safety system;
▪
Different experiences of health and safety regimes in countries of origin;
▪
Motivation to earn as much as possible, in the shortest possible time;
▪
Inability to communicate effectively with other workers and with supervisors, particularly in relation to their understanding of risk;
▪
Access to limited health and safety training and their difculties in understanding what is being offered, where prociency in English is limited;
▪
Failure of employers to check on their skills for work and on their language skills; and
▪
Lack of knowledge of health and safety rights and how to raise them.
The research was primarily qualitative and much of the data was collected through in-depth, face-to-face interviews with 200 migrant workers and with more than 60 employers, together with over 30 key respondents who worked with, advised, employed or organised migrants. These interviews were conducted in ve regions of England and Wales and were mainly carried out between May and November 2005.
© Santia 2013 ® – restricted use only
Page 10 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Levels of Sickness Absence and Incapacity There are many ways of calculating the rates of sickness absences making comparisons difcult. At the global level, the ILO reports that as many as 145 countries provide for paid sick leave,but the benet schedules for paid sick leave differ widely among countries. Globally, the replacement rates – that is the ratio of the total resources received when out of work to those received when in employment – vary between lump sums and up to 100 per cent of wages. The majority – more than 50 per cent of countries – provide for replacement rates that vary between 50 and 75 per cent of the wage received before. The period of paid sick leave spans from more than one month (and up to two years) to less than 7 days.
Societal Expectations Research into discrimination within the workplace to such groups as women and the disabled suggests that the pattern of ndings is similar to those found in the broader society
ILO Declaration on Fundamental Principles and Rights at Work, 1998 All ILO Members, even if they have not ratied the Conventions to respect, and promote the principles concerning the fundamental rights including the elimination of discrimination in respect of employment and occupation, are required to observe these fundamental principles. This is further amplied within ILO Vocational Rehabilitation and Employment of (Disabled Persons) Convention which requires each Member to, in accordance with national conditions, implement a national policy on vocational rehabilitation and employment of disabled persons. This should be based on the principle of equal opportunity between disabled workers and workers generally.
© Santia 2013 ® – restricted use only
Page 11 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Corporate Social Responsibility (CSR) The growth of the global economy has seen benets across the world but also increasing public concern about business activities and a decline in trust. At the World Summit on Sustainable Development (WSSD) in Johannesburg in September 2002 there was as much focus on business as on poverty and the environment. Today’s heightened interest in the proper role of businesses in society has been promoted by increased sensitivity to, and awareness of environmental and ethical issues. Issues like environmental damage, improper treatment of workers, and faulty production leading to customers inconvenience or danger, are highlighted in the media. In some countries government regulation regarding environmental and social issues has increased, and standards and laws are also often set at a supranational level (e.g., by the European Union). Some investors and investment fund managers have begun to take account of a corporation’s CSR policy in making investment decisions (so called “ethical investing”). Some consumers have also become increasingly sensitive to the CSR performance of the companies from which they buy their goods and services. These trends have contributed to the pressure on companies to operate in an economically, socially and environmentally sustainable way. The Confederation of British Industry (CBI) describes CSR as; “……the acknowledgement by companies that they should be accountable not only for their nancial performance, but for the impact of their activities on society and/or the environment.”(www.cbi.org.uk) Corporate Social Responsibility requires organisations to conduct their activities in an ethical fashion and to report annually on their progress against previously set targets. Topics to be reported upon included: ▪
Health and safety.
▪
Environment.
▪
Ethical trading.
▪
Community involvement.
▪
Employment standards.
CSR can be considered as a form of corporate self-regulation. It would be integrated into a business model which would function as a built-in, self-regulating mechanism whereby businesses would monitor themselves to ensure its support to law, ethical standards, and national / international norms. Consequently, businesses would consider the impact of their activities on the environment, consumers, employees, communities, stakeholders and all other members of the public. They would also proactively promote the public interest by encouraging community growth and development. Essentially, CSR is the deliberate inclusion of public interest into corporate decision-making.
© Santia 2013 ® – restricted use only
Page 12 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Social Accountability 8000 (SA8000) Standard In 1997, Social Accountability International (SAI) was established to develop standards and systems to address workers’ rights. Representatives of trade unions, human rights organisations, academia, retailers, manufacturers, contractors, as well as consulting, accounting, and certication rms, by consensus, cooperated to develop the Social Accountability 8000 (SA8000) Standard. Published in late 1997 and revised in 2001, the SA8000 Standard and verication system is an auditable certication standard based on international workplace norms of International Labour Organisation (ILO) conventions, the Universal Declaration of Human Rights and the UN Convention on the Rights of the Child. A summary of the Standard elements follows: ▪
Child Labour;
▪
Forced Labour;
▪
Health and Safety: (Provide a safe and healthy work environment; take steps to prevent injuries; regular health and safety training for workers; systems to detect threats to health and safety);
▪
Freedom of Association and Right to Collective Bargaining;
▪
Discrimination;
▪
Discipline;
▪
Working Hours;
▪
Compensation; and
▪
Management Systems.
ISO 26000 ISO 26000 is the recognized international standard for CSR. This standard offers guidance on socially responsible behaviour and possible actions; it does not contain requirements and, therefore, in contrast to ISO management system standards, is not certiable. ISO 26000:2010 provides guidance to all types of organisations, regardless of their size or location, on: ▪
Concepts, terms and denitions related to social responsibility;
▪
The background, trends and characteristics of social responsibility;
▪
Principles and practices relating to social responsibility;
▪
The core subjects and issues of social responsibility;
▪
Integrating, implementing and promoting socially responsible behaviour throughout the organisation and, through its policies and practices, within its sphere of inuence;
▪
Identifying and engaging with stakeholders; and
▪
Communicating commitments, performance and other information related to social responsibility.
© Santia 2013 ® – restricted use only
Page 13 sc/1026/v2
Element IA1: Principles of Health and Safety Management
The Global Reporting Initiative (GRI) The Global Reporting Initiative was initially convened by the Coalition for Environmentally Responsible Economies (CERES), a non-prot coalition of over 50 investor, environmental, religious, labour and social justice groups. The GRI has developed a set of core metrics intended to be applicable to all business enterprises, sets of sector-specic metrics for specic types of enterprises and a uniform format for reporting information integral to a company’s sustainability performance. The main reason for starting the GRI project was that there was no guideline on what a voluntary CER or CSR should contain. Because of this, there was no possibility to compare reports from different companies. The guidelines are constructed to be applicable to the ISO 14001 standard. The guidelines recommend the following parts to be included in the report: 1.
EO statement, including a statement from the organisation’s CEO describing the key elements of the report;
2.
Prole of reporting organisation, including an overview of the reporting organisation;
3.
Executive summary and key indicators, showing an overview of the GRI report;
4.
Vision and strategy, giving the organisation’s vision and how the vision integrates economic, environmental and social performance;
5.
Policies, organisation, and management systems, including an overview of the organisation’s governance structure and the management systems that are in place to implement the vision, and
6.
Performance, covering a report of the organisation’s economic, environmental and social performance.
© Santia 2013 ® – restricted use only
Page 14 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Effective Health and Safety Management Systems Many management systems exist throughout the world. Organisations often fail to manage health and safety effectively as they view it as something distinct from other management systems such as systems for the environment or quality. However, before considering management systems in detail it is important that the denitions of key terms used in such systems is clearly understood.
Denitions Various similar denitions exist for health and safety terminology. The denitions offered below arise from a combination of authoritative sources.
Hazard A hazard is something with the potential to cause harm; hazards can be physical, chemical, biological, ergonomic or psychological in nature. HSE publication HSG 65 denes a hazard as: “The potential to cause harm, including ill-health and injury; damage to property, plant, products or the environment; and production losses or increased liabilities.” OHSAS 18001 gives the following denition: “A source or situation with a potential for harm in terms of injury or ill-hea lth, damage to property, damage to the workplace environment, or a combination of these.”
© Santia 2013 ® – restricted use only
Page 15 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Danger The Concise Oxford Dictionary denes danger as: “Liability or exposure to harm; a thing that causes or is likely to cause harm.”
Risk Risk is the likelihood that the harm from one or more particular hazards is realised (the extent of the risk covers the population affected and the consequences for them). HSE publication HSG 65 denes risk as: “The likelihood that a specied undesired event will occur due to the realisation of a hazard by, or during, work activities or by the products and services created by work activities.” OHSAS 18001 denes risk as: “A combination of the likelihood and consequence(s) of a specied hazardous event occurring.”
Health and Safety Management Systems A management system is a proven framework for managing and continually improving an organisation’s policies, procedures and processes. The modern approach to health and safety management is systems based. Successful management of health and safety results from the application of sound management principles and business expertise. Management systems are generally constructed in accordance with a Plan, Do, Check, Act (PDCA) cycle providing a framework for problem solving, organisational learning and continual improvement. The process, simply involves: ▪
Planning what is needed;
▪
Doing it;
▪
Checking that it worked; and
▪
Acting to correct any problems and improve performance
The PDCA cycle was originally developed by Walter Shewart in the 1930’s and was taken up and championed in the 1950’s by William Edwards Deming, the quality management authority.
© Santia 2013 ® – restricted use only
Page 16 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Figure 1: PDCA Cycle
Various commercial health and safety management systems are discussed in this section including: ▪
BS OHSAS 18001 Occupational Health and Management Systems: Specication. British Standards Institution, 1999.
▪
ILO-OSH-2001 Guidelines on Occupational Health and Safety Management Systems. ILO, 2001.
Whichever individual system is selected, all effective health and safety management systems amplify the Plan-Do-Check-Act model.
© Santia 2013 ® – restricted use only
Page 17 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Elements of a Health and Safety Management System The key elements of any effective health and safety management system will include: ▪
Policy;
▪
Organisation;
▪
Planning and implementation;
▪
Measuring performance;
▪
Performance review;
▪
Audit; and
▪
Continual improvement.
Policy A health and safety policy should inuence all workplace activities, including the selection of people, equipment and materials, the way the work is done and how goods and services are designed. Effective health and safety policies set a clear direction for the organisation to follow and are a vehicle for the effective communication of health and safety information. They contribute to all aspects of business performance as part of a demonstrable commitment to continuous improvement. Responsibilities to people and the environment should be met in ways that full moral duties and any legal requirement. The health and safety policy should include cost effective approaches to preserving and developing physical and human resources, which reduce nancial losses and liabilities. The policy requires consideration of a corporate strategy, including the setting of objectives, allocation of resources, monitoring and appraisal of performance. Stakeholders’ expectations in the undertaking (whether they are shareholders employees, or their representatives, customers or society at large) should be satised.
Organisation The policy sets the direction for health and safety, but organisations need to create a robust framework for management activity and to detail the responsibilities and relationships that will deliver improved performance. To make a health and safety policy effective, staff (permanent and temporary) must become involved and committed to health and safety matters. This is often referred to as a positive health and safety culture. To promote a positive health and safety culture organisations should address the following: ▪
Control:
By allocating responsibilities, accountabilities, securing commitment, instruction and supervision.
▪
Competence:
In recruitment, training and advisory support.
▪
Co-operation:
Between individuals and groups, including consultation with employees and other persons, such as contractors and other employers who share the site.
▪
Communication:
Spoken, written and visible. Effectively owing in all directions.
© Santia 2013 ® – restricted use only
Page 18 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Planning and Implementing Planning is essential for the implementation of health and safety policies. Adequate control of risks can be achieved through the co-ordinated action by all members of the organisation. An effective planning system for health and safety requires organisations to establish and operate a health and safety management system that: ▪
Generates objectives;
▪
Identies hazards, assesses risks and establishes priorities according to risk;
▪
Controls risk;
▪
Reacts to changing demands;
▪
Establishes, monitoring arrangements to ensure standards are met; and
▪
Sustains a positive health and safety culture.
A systematic approach is necessary to answer three key questions: 1.
Where are we now?
2.
Where do we want to be?
3.
How do we get there?
Although health and safety management systems vary in detail, they have some general characteristics, such as: ▪
Designing, developing and installing suitable management arrangements, risk control systems and workplace precautions, which are proportionate to the needs, hazards and risks of the organisation; and
▪
Operating, maintaining and improving the system to suit changing needs and process hazards / risks.
© Santia 2013 ® – restricted use only
Page 19 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Risk Control Systems (RCS) The Risk Control Systems ensure that appropriate workplace precautions are provided and maintained for all aspects of the undertaking. At the input stage the aim is to minimise hazards and risks entering the organisation. At the process stage the focus is on containing risks associated with the process. At the output stage the aim is to prevent the export of risks off site, or in the products generated or services provided by the business. The nature and relative importance of the RCS will vary according to the nature and hazard prole of the business and the workplace. Example RCS include policies, standard operation procedures, safety method statements, safe systems of work, communication systems, consultation systems, training, workplace and activity monitoring systems, environmental and personal monitoring, record keeping, maintenance schedules, induction and competency assessments, control of contractors, etc.
Workplace Precautions The purpose of the health and safety management system is to prevent injuries and ill health due to work-related activities. Adequate workplace precautions are required to prevent harm at the point of risk. Workplace precautions should match the hazards and risks of each business activity. They can include a combination of: ▪
Avoiding the risks completely by using alternatives, e.g. avoid exposure to solvents by using water based paints;
▪
Reducing the nature of the hazard, e.g. the use of granular materials rather than ne powders that create a dust hazard;
▪
Isolating the hazards from people by preventing access by means of guards, barriers and screens;
▪
Reducing exposure to the hazards by ventilation, job rotation and personal protective equipment; and
▪
Safety information instruction and training on hazards, precautions and safe systems of work.
© Santia 2013 ® – restricted use only
Page 20 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Measuring Performance Measurement is essential to maintain and improve health and safety performance. There are two ways to generate information on performance: Active (pro-active) monitoring, which monitors the achievement of plans and the extent of compliance with standards before an accident, incident or ill-health. Examples would be: ▪
Progress monitoring of objectives;
▪
Performance reviews;
▪
Review of training assessment, records and needs;
▪
Examination of documents;
▪
Workplace inspections;
▪
Management system audits;
▪
Environmental monitoring;
▪
Health surveillance;
▪
Behavioural observation;
▪
Safety tours (a general impression gained on the tour);
▪
Safety sampling (scoring compliance and non-compliance);
▪
Safety survey (concentrates on a specic topic); and
▪
Consideration of regular reports by the board of directors.
Reactive monitoring, which monitor accidents, ill health and incidents, e.g. ▪
Accident incident rates;
▪
Ill health incidence rates;
▪
Accident frequency rates;
▪
Accident severity rates;
▪
Sickness absence; and
▪
Property or product damage.
© Santia 2013 ® – restricted use only
Page 21 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Reviewing Performance Organisations can maintain and improve their ability to manage risks by learning from experience through the use of audits and proactive and reactive performance reviews. Monitoring provides the information in order to review activities and improve performance.
Auditing Internal and external audits complement the monitoring activities by determining whether the health and safety policy, organisation and systems are actually achieving the required reliability and effectiveness.
Continual Improvement The requirement for continual improvement for many reasons employee morale, insurance costs, liability, etc. not to mention simple human concern for the welfare of others, nothing in a business is more important than improving health/safety performance.
© Santia 2013 ® – restricted use only
Page 22 sc/1026/v2
Element IA1: Principles of Health and Safety Management
BS OHSAS 18001; 2007 entitled ‘Occupational Health and Safety’ BS OHSAS 18001 is the internationally recognised assessment specication for occupational health and safety management systems. It was developed to address a gap where no thirdparty certiable international standard exists. OHSAS 18001 has been designed to be compatible with ISO 9001 (quality) and ISO 14001 (environmental). It is not related to the safety of products and services, nor is it a British Standard for accreditation purposes, but rather it is a specication for certication purposes. Figure 2: The Elements of OHSAS 18001
Continual Improvement
OH&S Policy Management Review Planning Checking Corrective Action
Implementation and Operation
The OHSAS specication is applicable to any organisation that wishes to: ▪
Establish an OH&S management system to eliminate or minimise risk to employees and other interested parties; implement, maintain and continually improve an OH&S management system;
▪
Assure itself of its conformance with its stated OH&S policy; and
▪
Demonstrate such conformance to others by seeking certication/registration of its OH&S management system by an external organisation or making a self-declaration of conformance.
© Santia 2013 ® – restricted use only
Page 23 sc/1026/v2
Element IA1: Principles of Health and Safety Management
OH&S Policy An OH&S policy establishes an overall sense of direction and sets the principles of action for OH&S objectives, responsibility and performance required. The OH&S policy should be documented, implemented and maintained and it should be consistent with the organisation’s overall business policies, including policies for other management disciplines, e.g. quality management and environmental management.
Planning OHSAS 18001 requires the establishment and maintenance of documented systems that are kept up to date for: ▪
Occupational health and safety objectives at each relevant function and level within the organisation. A management programme for achieving its OH&S objectives should be established and maintained. This includes documentation of responsibilities and authorities for achievement of the objectives at relevant functions and levels of the organisation, and the means and time-scale by which objectives are to be achieved;
▪
Procedures for ongoing identication of hazards, the assessment of risks, and the implementation of control measures as necessary for the activities of all persons having access to the premises; and
▪
Procedures for identifying and accessing the legal and other OH&S requirements that are applicable to it. This information should be communicated to its employees and other relevant interested parties.
Implementation and Operation The roles, responsibilities and authorities of personnel who manage, perform and verify activities having an effect on the OH&S risks of the organisation’s activities, facilities and processes, should be dened, documented and communicated. To make an effective health and safety policy, a positive health and safety culture should be established whereby staff are involved and committed to health and safety. Employee involvement and consultation arrangements should be documented and interested parties informed. OHSAS 18001 states that personnel should be competent to perform tasks that may impact on OH&S in the workplace. Competence in the specication is dened in terms of appropriate education, training and/or experience. OHSAS 18001 requires procedures for ensuring that pertinent OH&S information is communicated to and from employees and other interested parties. The specication requires that the organisation establishes and maintain plans and procedures to identify the potential for, and responses to, incidents and emergency situations, and for preventing and mitigating the likely illness and injury that may be associated with them. The organisation should review its emergency preparedness and response plans and procedures, in particular, after the occurrence of incidents or emergency situations and periodically test such procedures.
© Santia 2013 ® – restricted use only
Page 24 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Checking and Corrective Action The OHSAS specication requires that the organisation establishes and maintains procedures to monitor and measure OH&S performance on a regular basis. Any corrective or preventive action taken to eliminate the causes of actual and potential non-conformances should be appropriate to the magnitude of problems and commensurate with the OH&S risk encountered. Procedures for periodic OH&S management system audits should be established, maintained and an audit programme carried out.
Management Review Each organisation’s top management should, at intervals that it determines, review the OH&S management system, to ensure its continuing suitability, adequacy and effectiveness. The management review process should ensure that the necessary information is collected to allow management to carry out this evaluation and this review should be documented. The management review should address the possible need for changes to elements of the management system, in the light of management system audit results and changing circumstances, e.g. legislative requirements or societal expectations. Any changes introduced should be communicated as soon as practicable.
© Santia 2013 ® – restricted use only
Page 25 sc/1026/v2
Element IA1: Principles of Health and Safety Management
ILO-OSH 2001: Guidelines on Occupational Safety and Health Management Systems This standard was introduced by the International Labour Organisation in 2001. It’s aim is to provide guidance on management systems for: ▪
National policy;
▪
National guidelines; and
▪
Tailored guidelines.
The guidance’s most practical use is in the use of this standard as a framework to develop tailored occupational health and safety systems for an organisation reecting a framework that is multi-national and can be adopted for national legislation. Despite being an international standard and developed with representatives from worldwide health and safety organisations, BS OHSAS 18001 has become the leader in terms of popularity of standards, possibly because unlike the International Labour Organisation standard it is capable of certication. Figure 3: ILO Health and Safety Management System
© Santia 2013 ® – restricted use only
Page 26 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Policy The main difference between this and other systems is the emphasis on standard basis and worker participation in the development of the policy. The OSH policy should include, as a minimum, the following key principles and objectives to which the organisation is committed: ▪
Protecting the safety and health of all members of the organisation by preventing workrelated injuries, ill health, diseases and incidents;
▪
Complying with relevant OSH national laws and regulations, voluntary programmes, collective agreements on OSH and other requirements to which the organisation subscribes;
▪
Ensuring that workers and their representatives are consulted and encouraged to participate actively in all elements of the OSH management system; and
▪
Continually improving the performance of the OSH management system.
Organising Here the main difference between this and other organisationa l policy systems is the requirement for health promotion and prevention.
Planning and Review The key differences with the ILO system is the emphasis placed upon: ▪
The requirement for money and the initial review;
▪
Contains any legal register (country specic);
▪
Includes management of change;
▪
Includes procurement; and
▪
Includes specic requirements of contracting and contractors.
Evaluating This section contains the specic requirement that the development of performance indicators that are both qualitative and quantitative. There is a requirement for both reactive and active data along with the need for audit programmes as OHSAS 18001.
Actions for Improvement This, like OHSAS 18001 has a commitment to continuous improvement.
© Santia 2013 ® – restricted use only
Page 27 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Principles of Quality Management Systems and Environmental Management Systems Quality Management Systems (BS EN ISO 9001: 2008) Quality is dened within ISO 9001 as the degree to which a set of inherent characteristics (or distinguishing features of a product or service) fulls requirements (i.e. a need or expectation be it stated, generally implied or obligatory). ISO 9001 advocates a process approach for developing, implementing and improving the effectiveness of a quality management system, and enhancing customer satisfaction by meeting customer requirements The approach emphasizes the importance of: ▪
Understanding and meeting requirements;
▪
The need to consider processes in terms of added value;
▪
Obtaining results of process performance and effectiveness; and
▪
Continual improvement of processes based on objective measurement.
Customer satisfaction is monitored through the evaluation of customer perception of how well the organisation has met the customer requirements. Customers therefore play a signicant role in dening requirements as inputs. Figure 4 models a customer driven, process based quality management system. It is important to note that the “Plan-Do-Check-Act” (PDCA) methodology can be applied to all processes.
© Santia 2013 ® – restricted use only
Page 28 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Figure 4: Customer Driven, Process Based Quality Management System
© Santia 2013 ® – restricted use only
Page 29 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Environmental Management Systems (BS EN ISO 14001: 2004) ISO 14001 is intended to provide organisations with the elements of an effective environmental management system (EMS) that can be integrated with other management requirements and help organisations achieve environmental and economic goals The Standard contains only those requirements that can be objectively audited and does not establish absolute requirements for environmental performance beyond the commitments, in the environmental policy. The key differences with OHSAS 18001 lies in the planning stage and relate to the identication of signicant environmental aspects and impacts rather than health and safety hazards and risks (see table 1) ▪
Environmental aspect is dened as an element of an organisation’s activities or products or services that can interact with the environment. A signicant environmental aspect has or can have a signicant environmental impact; and
▪
Environmental impact is any change to the environment whether adverse or benecial, wholly or partially resulting from an organisation’s environmental aspects
The key elements in the system are shown in Figure 5. Figure 5: ISO 14001 Environmental Management System
Continual Improvement
Management Review
Environmental Polic
Planning
Checking
© Santia 2013 ® – restricted use only
Implementation and Operation
Page 30 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Table 1: Comparison of Management Systems OHSAS 18001: 2007
ISO 14001:2004
ISO 9001: 2008
OH&S Policy
Environmental policy
Quality policy, Management commitment, and Continual improvement
Planning Hazard ID, risk assessment and controls Legal and other requirements Objectives and programmes
Planning Environmental aspects Legal and other Requirements Objectives, targets and programme(s)
Planning Customer focus Determination of product related requirements Quality objectives Management system planning and continual improvement
Implementation and operation Resources, roles, responsibility, accountability and authority Competence, training and awareness Communication, participation and consultation Documentation Control of documents Operational control Emergency preparedness and response
Implementation and operation Resources, roles, responsibility, and authority Competence, training and awareness Communication Documentation Control of documents Operational control Emergency preparedness and response
Product realisation Management commitment Responsibility and authority Provision of resources Infrastructure Competence, awareness and Training Internal and customer communication Documentation requirements Control of documents Planning of product realisation and customerrelated processes Design and development processes Production and service provision Preservation of product Control of non-conforming product
Checking Performance measurement and monitoring Evaluation of compliance Incident investigation Nonconformity, corrective and preventive action Control of records Internal audit
Checking Monitoring and measurement Evaluation of compliance Incident investigation Nonconformity, corrective action and preventive action Control of records Internal audit
Measurement, analysis and Improvement Monitoring and measurement of processes and product Control of nonconforming product Control of records Internal audit
Management review
Management review
Management review Review input and output Continual improvement
© Santia 2013 ® – restricted use only
Page 31 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Integrated Management Systems There is increasing recognition that a developed approach to quality is an essential feature of a successful organisation, not just an optional extra. The advent of the quality management systems, ISO 9000 series and its counterpart BS5750, led to organisations producing quality manuals and procedures, which did not consistently regard other business aspects such as health and safety and environmental issues. Emphasis was, and in many cases still is, placed upon quality of goods and services to the detriment of other business activities. The introduction and adoption of ISO 14000 addressed environmental integration, yet still health and safety was not always systematically considered. BS 18000 was designed to enable the integration of occupational health and safety management within an overall management system, however the quality, environmental and health and safety functions within an organisation were often separate. Quality, environmental and health and safety line managers were often in different departments reporting to different managers, leading to inconsistent approach and emphasis, a lack of communication and hence integration. Similar procedures were produced for each discipline often with conicting results leading to confusion and reduced performance. The integration of health and safety with quality management and environmental protection is a sensible business strategy, if properly resourced and managed, for achieving business efciency and the associated benets. Integrated management systems are most effective with large, complex, multi-hazard industrial organisations. They are less benecial for other types of organisation, particularly when the degree of risk posed by their operations to either the health and safety of individuals or to the environment is low. For these organisations the costs of introduction would be disproportionate to the benets. The various management systems however do not necessarily specify how to achieve conformance, nor do they guarantee legal compliance. Competent, specialist personnel must undertake the implementation and integration of the management systems to develop a series of detailed standards for non-specialist personnel to use. Many organisations today have health, safety and environment al managers or quality and health and safety managers in recognition of past failings to integrate the functions and disciplines. Anomalies between the standards will inevitably exist because of the very nature of the risks, e.g. the risk assessment methodology cannot be developed as a fully integrated system because health and safety risk assessment requires a task-based approach, whereas the environment usually requires a ‘global’ approach, although partial integration is possible. The effectiveness of integrated management systems is generally found to be variable. At most levels of implementation, integrated management systems are effective. However, integrated risk assessment and audit methodologies prove to be the least effective, particularly when used by non-specialist personnel.
© Santia 2013 ® – restricted use only
Page 32 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Table 2: Benets of Integrated and Separate Management Systems Integrated Management Systems
Separate Management Systems
Consistency / avoidance of duplication and unnecessary cost in procedural, recordkeeping, auditing and software areas.
Existing systems may work well and may lose some effectiveness during and after integration.
Avoids narrow decision making that solves a problem in one area but creates a problem in another area.
Safety and quality systems cannot be treated exactly the same, e.g. safety standards must meet legal minima, and quality standards can be set internally. Separate systems can be operated more easily with a different philosophy.
Encourages priorities and resource utilisation that reects the overall needs of the organisation rather than individual disciplines.
Business needs may demand systems of different complexity, e.g. a complex safety system and a simple quality system, so bureaucracy can be more easily tailored to the needs of the subject.
Initiatives in one area may benet other areas.
Separate systems may encourage a more detailed and focused approach to auditing and standards.
Encourages closer working and equal inuence amongst specialists / career development.
Separate systems are clearer for regulators to work with.
Provides scope for the integration of other areas, e.g. security, production safety, etc.
Change to integration will require resource input / time to develop.
Encourages the spread of a positive culture across three disciplines.
Benets of Introducing a Management System The benets of establishing an OH&S management system is to eliminate or minimise risk to employees and other interested parties who may be exposed to OH&S risks associated with its activities and to: ▪
Assure itself of its conformance with its stated OH&S policy;
▪
Demonstrate such conformance to others;
▪
Implement, maintain and continually improve an OH&S management system; and
▪
Seek certication/registration of its OH&S management system by an external organisation.
© Santia 2013 ® – restricted use only
Page 33 sc/1026/v2
Element IA1: Principles of Health and Safety Management
The Role and Responsibilities of the Health and Safety Practitioner The Health and Safety Practitioner and Health and Safety Management Systems The health and safety practitioner has a strategic role in the design, implementation, evaluation and maintenance of a health and safety management system. The key aspects of the role include: ▪
Advising the board or senior management on strategic health and safety issues;
▪
Formulating and developing health and safety policies, not just for existing activities but also with respect to new acquisitions or processes;
▪
Formulating and developing specic aspects of the health and safety management system, e.g. the practical arrangements for risk assessment;
▪
Promoting a positive health and safety culture and securing the effective implementation of health and safety policy;
▪
Developing and contributing to the implementation of arrangements to ensure effective consultation and communication of health and safety issues;
▪
Planning for health and safety including the setting of realistic short and long-term objectives, deciding priorities and establishing adequate systems and performance standards;
▪
Day-to-day implementation and monitoring of policy and plans including accident and incident investigation, reporting and analysis; and
▪
Reviewing performance and auditing of the health and safety management system.
To full the role effectively health and safety advisers need to have the status and competence to advise management and employees or their representatives with authority and independence.
© Santia 2013 ® – restricted use only
Page 34 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Inuencing Ownership and Conduct Within the Organisation In order for the practitioner to play an effective role in the development, maintenance and improvement of the organisation’s health and safety management system, they wil l naturally have to work with individuals at all levels with the organisation. The health and safety management system will not be effective in improving the organisation’s health and safety performance by itself, it needs individuals throughout the organisation to take ownership of it and play their part. This is where the practitioner can have a signicant inuence. During discussions and consultation with employees and management, the practitioner must be seen as the ‘champion’ or driving force for health and safety and must be able to convince managers – especially senior management - of the benets of improving health and safety performance. They must therefore themselves show commitment, ownership, enthusiasm and always conduct themselves in such a way that demonstrates they believe in what are talking about. Being positive about health and safety, making suggestions for improvements and not just highlighting problems, encouraging others to share their views and suggestions and actively getting people involved with health and safety programs will all make positive inuences on employees conduct and ownership of health and safety.
Competence and Continuing Professional Development Competence Competence, in the health and safety context, is legally dened within case law from the 1960’s onwards (Cooper, 1997) and more recently within the UK’s Management of Health and Safety at Work Regulations which denes competence as “the ability to perform to a required standard” , and states that:“A person shall be regarded as competent………. where he has sufcient training and experience or knowledge and other qualities to enable him properly to assist in undertaking the measures referred to….” (HSC,2000, p17) Professional competence must be obtained, maintained and developed by taking all reasonable steps to keep up to date with new developments in occupational safety and health. Acknowledgement of the limitations of personal competence is an important part of the process. Proper preparation and/or appropriate qualications may be essential in assuring competence for a specic activity. Within the USA the Certied Safety Professional or CSP is a safety professional who has met education and experience standards, has demonstrated by examination the knowledge that applies to professional safety practice, continues to meet Recertication requirements established by the Board of Certied Safety Professionals. Those holding the CSP certication must also be re-certied every ve years. The UK’s Institute of Occupational Safety and Health’s (IOSH) Continuing Professional Development (CPD) scheme provides a practical framework for demonstrat ing the maintenance of competence
© Santia 2013 ® – restricted use only
Page 35 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Continuing Professional Development Continuing Professional Development (CPD) is the term used to describe a commitment to structured skills enhancement and personal or professional competence. Commitment to CPD is an acknowledgement that becoming professionally qualied is not an end in itself - it is merely the beginning. IOSH’s CPD scheme provides a framework to identify personal and technical skill gaps and create an action plan to refresh or expand knowledge and experience. It is intended to enhance professional effectiveness, create a structured career path and safeguard professional status. Notions of learning through reection on past experience as an aid to personal continuous improvement are now common in many professions, notably those in education and medicine.
Evaluating and Developing Their Own Practice In order for the Health and Safety Practitioner to competently advise the organisation in its health and safety management system and general issues, they must evaluate and develop their own practice. This will ensure they are helping and not hindering the organisation’s health and safety performance. Evaluation of their own practice involves the practitioner analyzing their own performance and the health and safety impact they are having in the organisation. This can be done by: ▪
Measuring the effects of changes and developments they have introduced such as the effects of introducing behavioural safety programmes;
▪
Setting personal objectives and targets and measuring their performance against them;
▪
Reviewing failures or unsuccessful attempts to produce change such as reasons why a simplication of accident reporting procedures has not resulted in more minor accidents being reported;
▪
Benchmarking their practice against other practitioners and against good practice case studies and information;
▪
Seeking advice from other competent professionals such as occupational hygenists, engineers or chemists; and
▪
Seeking feedback from others such as clients and as part of annual appraisals from senior management.
© Santia 2013 ® – restricted use only
Page 36 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Developing their own practice may involve: ▪
Increasing their core knowledge and competence by obtaining a recognised qualication e.g. NEBOSH International Diploma in Occupational Health and Safety;
▪
Keeping up to date by undertaking training in relevant areas such as Conned Space Entry, Work at Height equipment training or other hazard specic training programme;
▪
Participating in CPD schemes;
▪
Access to suitable information sources;
▪
Networking with their peers at safety groups and conferences such as IOSH Branch Meetings or seminars;
▪
Seeking advice from other competent practitioners and consultants; and
▪
Initiating and following a personal development plan.
© Santia 2013 ® – restricted use only
Page 37 sc/1026/v2
Element IA1: Principles of Health and Safety Management
Professional Ethics Ethics may be considered to be the science, or systematic analysis, of morality where morality implies the codes of conduct or rules of behaviour imposed by a society regarding what is right and wrong. Professional bodies, such as IOSH (2009) issue codes of conduct to frame the expected standard of professional practice with regard to technical competence, as previously discussed, and professional conduct. The key ethical principles of professional conduct are broadly covered by the interrelated concepts of honesty, respect and integrity. In addition to maintenance and development of professional competence and not working beyond the boundaries of that competence, the IOSH ethics code requires professional safety practitioners to adhere to the following principles ▪
Perform according to the highest standards and ethical principles, maintaining respect for human dignity, loyalty to the workforce and professional independence in the execution of their functions;
▪
Ensure that any professional opinion is given honestly and is objective and reliable;
▪
Accept professional responsibility for all their work and shall take all reasonable steps to ensure the competence of those conducting tasks on their behalf;
▪
Take reasonable steps to ensure that persons overruling or neglecting their professional advice are formally made aware of potential adverse consequences which may result;
▪
Uphold the reputation and good standing of the Institution, other members, and profess ional practice and standards, and not bring them into disrepute;
▪
Not recklessly or maliciously injure, the professional reputation, prospects or business of another;
▪
Not behave in a way which may be considered inappropriate to other members or staff of the Institution;
▪
Not improperly use membership or position within the organisation of the Institution for commercial or personal gain;
▪
Not improperly disclose any information which may reasonably be considered to be prejudicial to the business of any present or past employer, client or the Institution;
▪
Make information they hold necessary to safeguard the health and safety of those persons for whom they have a legal and moral responsibility available as required;
▪
Comply with the data protection principles and notication requirements set out in the Data Protection Act 1998 or equivalent legislation;
▪
Maintain nancial propriety in all their professional dealings with employers and clients and shall ensure that they are covered by appropriate professional indemnity insurance;
© Santia 2013 ® – restricted use only
Page 38 sc/1026/v2
Element IA1: Principles of Health and Safety Management
▪
Be respectful of all people they come into professional contact with and not discriminate on grounds of race, colour, religion or belief, disability, sex, marital status, age, sexual orientation, nationality and ethnic or national origins;
▪
Act within the law and notify the Institution if convicted of any criminal offence. (A relevant conviction may lead to disciplinary proceedings); and
▪
Comply with the Institution’s Charter, Byelaws and Regulations
Conict of Interest Conict of interest refers to occasions where using professional judgment may lead to problems in securing future or continuing employment or contracts. A simple example of this type of conict might be where a consultant is aware that his recommendations aren’t being implemented, but continues to advise the organisation so as not to lose the income from the contract. The IOSH code of conduct requires members to seek to avoid their professional judgment being inuenced by any conict of interest and to inform their employer, client, or the Institution of any conict between personal interest and service to the relevant party.
© Santia 2013 ® – restricted use only
Page 39 sc/1026/v2