1026 Int Diploma IA5 v2

Element IA5: Risk Control


© Santia 2013 ® – restricted use only

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Contents Risk Control Risk Control Systems (RCS) Risk Management Strategies 1. Avoidance 2. Reduction 3. Retention 4. Transfer

Selecting Risk Control Measures General Principles of Prevention: Technical, Procedural, Behavioural Cost Benet Analysis

Safe Systems of Work and Permits To Work

5 5 7 7 7 8 8 9 9 11 12

Safe Systems of Work Permits To Work

15 15 17

References

21


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Risk Control Risk Control Systems (RCS) The ultimate goal of any health and safety management sys tem is to prevent injury and ill-health in the workplace, through the effective management of risk. Risks arise at each stage of the business process. Figure 1 illustrates the concept of the organisation as a system, consisting of inputs, processes and outputs. Figure 1: Risk Control System

Inputs

Processes

Outputs

Physical Resources, Human Resources and Information

Routine operations, Maintenance, Emergencies, Process change, Decommissioning and Demolition

Products, Services, Information and By products

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 arising during business operation. At the output stage, the concern is preventing the export of risks off-site, or in the products and services generated by the business. An effective health and safety management system has three components, which from the bottom up, can be summarised as: 1)

Workplace Precautions

Adequate workplace precautions have to be provided and maintained to prevent harm to people at the point of risk. Examples of workplace precautions include machine guards, local exhaust ventilation, safety instructions and systems of work. Workplace precautions are devised through a process of risk assessment and control. 2)

Risk Control Systems (RCS)

Risk control systems are the basis for ensuring that adequate workplace precautions are provided and maintained. Examples include safe systems of work, training, monitoring etc. The control systems should reect the hazard prole of the organisation, the greater the hazard or risk, the more robust and reliable the control systems need to be.


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3)

Management Arrangements

A simple management control loop (Plan-Do-Check-Act), or the basic elements of our management system (Policy, Organising, Planning and Implementing, Measuring Performance, Review and Audit ) can be used as a framework for designing the Risk Control Systems. The scope and complexity of the management arrangements should reect the business needs and hazard prole. What is suitable for a large multi-site organisation may not be appropriate for a small rm. The effectiveness of the system depends upon co-ordination of the different activities at each level. When developing the system it is useful to envisage the business as a system – a series of inputs, processes and outputs. The key considerations at each stage are summarised in the following diagram. Figure 2: Key Considerations

Inputs

Process

Where are we now?

Information on current conditions and status Suitable benchmarks and legal standards

Where do we want to be?

Comparisons with frameworks and legal standards Is the system adequate?

Competent people Is the system working as intended? Is the system providing cost effective, proportionate prevention in the workplace?

Output

How do we get there?

Gap analysis leading to: Improving existing components of safety management system, or Devising new components

Health and Safety plans developing, maintaining and improving the management system. Specifications for: Workplace precautions; Risk control systems; Management arrangements; and Performance standards.


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Risk Management Strategies Common approaches to managing risk include the following strategies: Figure 3: Risk Management

Risk Control

Loss

Risk

Control

Financing

Risk

Risk

Risk

Risk

Avoidance

Risk Reduction

Retention

Transfer

1. Avoidance Risk Avoidance is the decision of the organisation to change an operational mode, consequently remove the presence of or ‘avoid’ the presence of a particular risk. In order for this method of control to be successful the organisation must rst have clearly identied any hazards and subsequently evaluated the relevant risks. By redesigning a task based on the ndings of task analyses, hazards may be simply and cheaply removed. Similarly, the automation of certain tasks using robots or programmable electronic systems may remove, to a large extent, the need for human intervention in the process thereby avoiding the hazards and subsequent risks in the workplace. These are of course examples of avoidance in an overall risk management strategy. Another example of risk avoidance as a risk control measure could be the substituting of a particular hazardous chemical for one which has no harmful potential.

2. Reduction The application of risk reduction as a control measure relies on the implementation of a loss control program which would subsequently reduce consequences of failure or realisation of the risk to the organisation to an acceptable level, e.g. reduced concentration of chemical, or engineering modications to reduce noise emissions.


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3. Retention Risk retention within a risk control strategy refers to the retention within the organisation of any nancial loss associated with the realisation of identied risks. Two important areas to consider within the role of risk retention would be: ▪

Risk retention with knowledge whereby the organisation makes a conscious decision to meet the costs of any loss which are realised from within the organisational assets. The conscious decision must of course be based on effective risk identication and evaluation; and

▪

Risk retention without knowledge relates to the organisational retention of risk having failed to provide adequate coverage through insurance as a result of their lack of identication or evaluation of the existence of particular risks.

4. Transfer The concept of risk transfer as a risk control strategy relates to the redistribution of risk consequence realisation to a third party. In many circumstances this may relate to transferring the consequence of risk to an insurance company who will then pay compensation to the insured party in the event of realisation of the risk and subsequent loss. In a contract arrangement the consequences of risk realisation are transferred to a third party. This is also a form of risk transfer.


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Selecting Risk Control Measures Workplace precautions and risk control systems are required to either: ▪

Eliminate the hazard;

▪

Reduce the hazard at source to a level below the acceptable threshold; or

▪

Control exposure to the hazard, by means of physical and organisational barriers.

There are several strategies available when selecting appropriate risk controls. These being: ▪

General Principles of Prevention; and

▪

Technical, Procedural, Behavioural

These strategies are normally applied in a set order or hierarchy.

General Principles of Prevention: The general principles consist of the following and should be applied in this order when selecting appropriate risk control measures: ▪

Avoiding risks;

▪

Evaluating the risks, which cannot be avoided;

▪

Combating the risks at source;

▪

Adapting the work to the individual, especially as regard the design of work places, the choice of work equipment and the choice of working and production methods, with a view, in particular, to alleviating monotonous work and work at a predetermined work-rate and to reducing their effect on health;

▪

Adapting to technical progress;

▪

Replacing the dangerous by the non-dangerous or less dangerous;

▪

Developing a coherent overall prevention policy, which covers technology, organisation of work, working conditions, social relationships and the inuence of factors relating to the working environment;

▪

Giving collective protective measures priority over individual protective measures; and

▪

Give appropriate instructions to employees.

The action that must be taken to deal with a particular hazard may be dened by specic standards. In planning to control hazards, employers should consider action in accordance with the principles of prevention in the order in which they are listed. This approach should be adopted even if all specic legislative requirements have been complied with as legislation generally sets minimum standards. A combination of this hierarchy (list) is usually necessary in some cases.


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Application of General Principles of Prevention The ‘mnemonic’ ERIC Prevents Death or ERIC PD is useful when applying the concepts of the general principles of prevention in the selection of appropriate risk control measures. Figure 4: ERIC PD Eliminate the hazard – the very best thing to do if possible Reduce the risk from the hazard

Safe Place Strategies Isolate the hazard from people Control the extent of exposure / contact with the hazard(s) Personal Protective Equipment – as a last resort Discipline

Safe Person Strategies

Eliminate the Hazard Can the hazard be removed completely? This is the most effective method, e.g. use water based adhesive or paint instead of solvent based, use compress ed air tools instead of electrical, provide a socket outlet at the point of use, thus eliminating the need for a trailing cable.

Reduce the Hazard Can the risk be reduced at source? Is there a safer alternative? Examples include choosing a solvent with a higher ash point or a substance which is merely ‘harmful’ to replace one which is ‘very toxic’; using a machine which emits lower levels of noise and using low voltage tools. The two methods above deal with the hazard itself and are therefore more effective than the following measures which do nothing with the hazard other than try to control it.

Isolate the Hazard from People Can the hazard be enclosed or contained? Examples include guarding dangerous parts of machinery, covering holes in the oor such as vehicle inspection pits, tting a noise reducing enclosure around a machine, processing hazardous substances in enclosed equipment. Can people be kept away from the hazard? Examples include placi ng a barrier around an excavation or hole in the oor, tting guard rails to scaffold, placing un-insulated high voltage (HV) electrical conductors on high level pylons.

Control the Extent of Exposure / Contact with the Hazards Where contact with a hazard cannot be completely prevented (as with isolation) it may be practicable to reduce the contact to an ‘acceptable’ level. Can the time or degree of contact be reduced? Examples include using vibrating or noisy machinery for a short time each day, developing job rota systems, providing ventilation systems where fumes are present and tting residual current devices (RCDs) to electrical equipment.


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Personal Protective Equipment (PPE) Can something be provided to the person to lessen the injury effect, e.g. helmets, ear defenders, rubber gloves, respirator, etc. This method on its own is the least effective means of controlling hazards and must be considered as a last resort. All other options above should be considered rst and provided where possible. PPE may then be used as a means of protecting from the risks that remain or as a back up to the measures provided. PPE protection may also be appropriate in certain low risk circumstances as an interim step while other options are being introduced.

Discipline Clearly the safe place strategy is the preferred option as controls are subsequently aimed at the workforce generally rather than individual workers. Discipline in this context refers to the discipline of the individual worker to follow the systems of work in place and their training. Effective organisational and behavioural controls are also essential in preventing harm.

Technical, Procedural, Behavioural The order of applying risk control measures can be broken down and considered as having three levels of protection which move from the most to the least effective, Technical, Procedural and Behavioural.

Technical Technical control strategies would generally deal with risks from the perspective of the physical controls related to the workplace or the activity in question. Such strategies would include physical barriers such as machinery guarding, or guard rails on walkways, etc.

Procedural Procedural control strategies consider a less physical approach and would normally be associated with the structure of the organisation or the systems of operation within the structure. Examples of procedural controls would include implementation of safe systems of work, operational aspects of permit systems, specication of equipment standards, etc.

Behavioural Behavioural controls as the title suggests relate specically to the behaviour of the individuals within the workplace. By taking into account the inuences on behaviour then safe behaviour can be encouraged. Examples of behavioural controls would include raising awareness and perceptions of the individuals through effective training, and communication and supervision. Practically whilst the distinction of the control levels is useful a combination of controls is usually appropriate.


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Cost Benet Analysis There are, of course, going to be signicant costs involved in introducing, implementing and maintaining an acceptable level of risk control. Historically, managers have tended to focus on these costs, regarding them as a drain on their budgets. How then can the expenditure be justied? Cost-benet analysis (CBA) is a framework for evaluating the costs and benets of a project. CBA takes account of both internal and external costs and benets and attempts to measure them in monetary terms. It can be broken down into the following steps: Step 1: Identify all costs and benets using the principle of opportunity cost. Step 2: Measure the costs and benets using money as a unit of account. Costing factors could include: ▪

Anticipated costs if no risk management action was taken;

▪

Costs involved to eliminate or reduce risk;

▪

The lifetime of the investment;

▪

The ongoing cost of maintenance, training, etc.;

▪

Qualitative and quantitative benet costs; and

▪

The payback or breakeven period.

Benets of effective risk management could include: ▪

Fewer injuries and damage incidents;

▪

Less absenteeism and sickness with fewer claims, resulting in lower premiums;

▪

Improved levels of health;

▪

Higher productivity / efciency;

▪

Improved plant utilisation (less downtime);

▪

Legislative compliance;

▪

Improved levels of quality and safety;

▪

Improved perception of risk and risk acceptability;

▪

Improved employee morale and motivation;

▪

Cost control / reduction; and

▪

Improved company image.


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Step 3: Consider the likelihood of the cost or benet occurring (i.e. sensitivity analysis). Step 4: Take account of the timing of the cost and benet (i.e. discounting). A £1,000 benet now is worth more than £1,000 benet in 10 years time. A project is only worth undertaking if the discounted benets outweigh the discounted costs. Several authors have explored the links between the costs of accidents and the management of health and safety. Fisher compared health and safety management with quality management, classifying the costs associated with quality and safety functions into prevention, appraisal and failure costs. He argued that even for relatively unsophisticated organisations, failure costs could be greater than the combined prevention and appraisal costs. A costing model derived from this work is presented in Figure 5.This combines the prevention and appraisal costs as the total costs of the control programme.The second component represents the costs of the programme failure. At some point further investment in the control programme will not give a net return (point A). However few, if any, leading companies consider that they have reached this point: many believe that they need to invest further in the managerial control of accidental loss. Figure 5: Economics of Management Control

Cost Total Costs

Cost of Programme Failure

Cost of Control Programmes A

The graph is derived from BS 6143 ‘Guide to The Economics Of Quality’. The following extrapolations have been made. Table 1: Economics of Management Quality Management

Health and Safety Management

Cost of conformance

Costs of control programme

Cost of non-conformance

Costs of programme failures

Process costs

Total costs


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Examples of the costs considered are presented below: Table 2: Cost Balance of Factors Costs of the Control Programme

Costs of Programme Failures

Decision making.

Major and minor personal injury accidents.

Safety hardware, e.g. ventilation systems, guards.

Occupational ill-health. Equipment and material damage events.

Communication and training time. Product losses. Publicity campaigns. Ongoing inspection and auditing effort.

Process and technical breakdowns damage to the environment.

or

Maintenance. Programme co-ordinator and support staff costs. These programme failure losses arise primarily from failures of management control, and if not prevented or contained, can interact and escalate into larger losses. There are also intangible costs due to programme failures, for example loss of business image, customer satisfaction, employee morale, goodwill and reduced productivity. The outcome of any particular accident is often a matter of chance. Factors combine and take effect so that a near miss, minor injury or serious injury may all result from similar sets of circumstances. If the circumstances that lead to minor accidents can be controlled, those same controls will also prevent other accidents with more serious consequences, resulting from the same management failings.


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Safe Systems of Work and Permits To Work Safe Systems of Work One of the main aims of the risk assessment and subsequent control measures is to ensure that a safe system of work exists. The following denition is given in HSE leaet “Safe Systems of Work” (IND (G) 76L). “A safe system of work is a formal procedure which results from a systematic examination of the task in order to identify all the hazards. It denes safe methods to ensure that hazards are eliminated or risks minimised.” ▪

The system must be planned in advance of the work (i.e. risk assessment).

▪

Systems are required for isolated tasks and non-routine tasks, not just the day-to-day operations or process.

▪

The system must take into account the ability or experience of the individual workers.

▪

The employer cannot rely on the fact that his workers are experienced. A safe system must be planned taking into account other i nfluences on behaviour “familiarity breeds contempt”.

▪

The system must be established by instruction, training, in writing or other method, and enforced.

Developing a Safe System of Work As specied in the HSE denition of a safe system of work a ‘systematic examination of a task’ is required to prepare a safe system of work. Arguably a derailed risk assessment is needed to carry out a systematic examination of the task or activity. The interpretation of the meaning of a safe system of work has been determined over many considered cases long before the requirement for formal risk assessments was introduced. Work activities should be broken down into individual activities so that hazards, conditions or actions at each stage can be identied. This is relatively easy in the case of routine process work but it is essential that a similar approach be adopted for non-routine tasks such as ▪

Cleaning and maintenance;

▪

Emergency breakdowns:

▪

Mobile workers; and

▪

Contractors on the premises.


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The degree of detail of analysis should depend on the level of risk involved. The system will include consideration of the following (depending on circumstances). ▪

Layout.

▪

Co-ordination of different work.

▪

Methods of performing specic processes.

▪

Protective equipment.

▪

Fire precautions.

▪

Environment.

▪

Hygiene, welfare arrangements.

▪

Criminal attack.

▪

Hazards associated with materials.

The above is not an exhaustive summary and what makes up a safe system may be rened as case law develops. The technique of Job Safety Analysis, or the MEEP (Materials, Equipment, Environment, People) approach may be used to achieve this initial step. The planning process should produce a denition of the safe method, use of plant, processes, etc. to be followed for the task. To be effective a safe system of work needs to be in writing setting out the work to be done and the precautions to be taken. When written down it is a formal record that all foreseeable hazards and risks have been considered in advance. The safe procedure consists of all appropriate precautions to be taken in the correct sequence. A permit to work may be required as part of the safe system of work.


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Permits To Work A permit to work system is a formal written system used to control certain types of work that are potentially hazardous. A permit to work is a document that species the work to be done and the precautions to be taken to ensure the safety of a particular activity when safety critical functions are needed such as isolation of power supplies. Permits to work can form an essential part of safe systems of work for many maintenance activities. They allow work to start only after safe procedures have been dened and they provide a clear record that all foreseeable hazards have been considered. A permit is needed when maintenance work can only be carried out if normal safeguards are removed or when new hazards are introduced by the work. Examples are entry into vessels, hot work and pipeline breaking. Piper Alpha is a prime example of the consequences of a failure / erosion of a Permit to Work control system. Some organisations use one form to cover all situations for which a permit is issued; others have specic permits for electrical, mechanical, hot work, conned space entry, etc. Procedures for some activities may require certain things to be done before work is allowed to begin, for example, the electrical system must be isolated before a light tting is changed, a machine must be switched off and isolated before certain adjustments can be made. This system may rely on instructions to workers in the correct procedures to adopt or in addition may require locks and signs to be tted to isolators. For low or medium risk situations these systems may be adequate. Where the failure to carry out certain actions might expose people to a high risk of serious injury or death a permit-to-work system may be considered necessary. Permit systems are particularly valuable where the safety of one individual depends on correct actions being taken by others. Examples of activities often covered by a Permit-to-Work system are: ▪

Work on electrical systems;

▪

Maintenance work on machinery;

▪

Entry into conned spaces;

▪

Excavation work in areas where there are buried services;

▪

Hot work - work involving ames or sparks in areas where there are ammable materials;

▪

Work on or near overhead cranes; and

▪

Work on operational pipelines.


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A denition of a Permit to Work system is: “A formal written system and is usually required where there is a reasonably foreseeable risk of serious injury.” This denition distinguishes a permit to work from a ‘Limitation of Access’, ‘Work Authorisation’ type of documentation which is aimed only at controlling entry into work premises, often issued to visitors or contractors. In some organisations this authorisation document is also called a ‘Permit to Work’, or ‘Contractors Permit’. It is important that the difference between the two types of document is fully understood by the contractor to avoid confusion. It may be preferable to use the word ‘Permit’ only for documents meeting the denition of a Permit to Work above.

Limitations of a Permit To Work System A HSE survey showed that one third of all accidents in the chemical industry were maintenance related, the largest single cause being a lack of, or deciency in, the permit to work systems. A study of small and medium sized chemical factories showed: ▪

Two-thirds of companies were not checking systems adequately;

▪

Two-thirds of permits did not adequately identify potential hazards;

▪

Nearly half dealt poorly with isolation of plant, electrical equipment etc;

▪

A third of permits were unclear on what personal protective clothing was needed;

▪

A quarter of permits did not deal adequately with formal hand-back of plant once maintenance work had nished; and

▪

In many cases little thought had been given to permit form design.

(HSE INDG 98, Chemical and Hazardous Installations Division)


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Format of Permit To Work System The format of the permit needs to be considered. The most important guideline is that any permit form should be as simple as possible to avoid confusion and time consuming bureaucracy and yet must include the essential elements as follows:

Issue All persons involved must be aware of the hazards and precautions relating to the activity; ▪

Each permit issued should have a unique identication number or code;

▪

The permit must be clearly limited to a specic place, activity, piece of equipment, etc. Unique plant identication numbers should be used wherever possible;

▪

The nature of the work must be clearly specied;

▪

There must be a date / time limit for the permit;

▪

Any restrictions on types of activity, equipment, etc. while carrying out the work for which the permit is issued must be clearly dened. (There may be reference to a different type of permit being required for other work.);

▪

The precautions that have been taken must be clearly dened, e.g. isolation, locking off, test of atmosphere etc;

▪

Any further monitoring, etc. that will be required during or after the work must also be clearly dened (e.g. regular or continuous air monitoring); and

▪

Any further actions required during the work must be dened. Many accidents happen when individuals decide to carry out some additional work.

Receipt The individuals who are to carry out the carried out the actions above should personally sign the permit. Some permit systems allow for supervisors, etc. to sign on their behalf. This is only acceptable where the individual signing has conrmed beyond any doubt that the control measures as stated have been put in place and the work can start. The individual issuing the permit must sign to conrm that all necessary isolation, testing, etc. has been carried out and that it is safe for the work or entry to commence; and the individuals who will be carrying out the work must sign to conrm that they fully understand the work required, the restrictions, the precautions to be taken and the PPE to be worn.

Clearance / Return to Service When the work is completed the individuals must sign to that effect and to conrm that the plant may be returned to service.


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Cancellation Where the work is not completed and the permit is cancelled, the ‘owner’ of the plant must sign to accept the plant back into service.

Extensions Should the work not be completed by the end of the shift, some permit systems provide for extensions; since this might involve other employees in the work, many systems insist on a new permit being issued to avoid safety issues being overlooked or misunderstood.

Organisation of the Permit To Work System Personnel selected to issue permits must be trained in the operation of the permit system. There should be clear operational and managerial accountability for the permit process. The likely number of permits to be issued must be estimated and this related to the number of personnel issuing permits and the time available. Failure to consider this point can result in the issue of permits becoming a paperwork exercise with no time to check the precautions. All personnel on a site must be aware of the permit procedure and when a permit is necessary. This will extend to any contractors or visitors. A program of instruction, induction training, issue of booklets and other methods are used to achieve this requirement. Permits must not be altered after they have been issued.

Other Features of an Effective System are: ▪

The procedure must not just be aimed at contractors or at employees, it must cover everyone carrying out a certain high-risk activity;

▪

The system must require a stoppage of work if new hazards are identied or deciencies in the precautions taken are found;

▪

There must be clear rules in the event of the work having to be abandoned for a general site emergency;

▪

A person should not be able to issue a permit to himself;

▪

There must be detailed procedures if the permit is allowed to extend beyond a shift and handed over to another person;

▪

The recipient should retain the permit, preferably on display at the work area and records of all ‘live’ permits be kept at the point of issue; and

▪

A system for reporting any incidents that arise during the activity.

Monitoring the Permit To Work System Checks must be made at regular intervals to ensure that permits have been issued for appropriate work. Any difculties in managing the system must be reported and followed up by management. The permit procedure should be reviewed regularly in the light of any difculties or incidents reported and improved where necessary.


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References ILO

1981

C155, International Labour Standards, Occupational safety and Health Convention.

ILO

1981

R164, International Labour Standards, Occupational safety and Health Recommendation.

HSE

2010

HSG250, Guidance on permit-to-work systems.

HSC

1991

Human Reliability Assessment – a critical overview, Advisory Committee on the Safety of Nuclear Installations Study Group.

HSE

INDG76L, Safe Systems of Work.

HSE

1996

HSG96, The Cost of Accidents at Work.

BSI

1990

BS 6143-2:1990; Guide to the Economics of Quality.

HSE

2002

INDG 98, Permits to Work.


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1026 Int Diploma IA5 v2

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