Below is a summary of an interview conducted with senior executives of BSI in March of 2009 concerning the safety culture at BSI, HSSE, and some of the policies, practices and proceedures in place companywide. Section 1: Management, Leadership, Commitment and Accountability Questionnaire items (i) Commitment to HSSE through leadership
Responses A) Senior managers receive extensive HSSE training and must commit to excellence in compliance.
a)
b)
c) d)
e)
Are senior managers personally involved in HSSE management? Is there evidence of commitment at all levels of the organisation? Is there there a positive culture towards HSSE matters? How do managers promote and demonstrate their personal commitment? Are clear goals and and objectives objectives established for measurement and evaluation of HSSE performance
B) The commitment to HSSE is evident through company objectives. C) A positive culture is evident through management’s continual support of the HSSE policy and has been formally recognized by our insurance carrier. D) Managers promote their personal commitment by enforcing the HSSE policy, attending safety meetings and safety fairs, continual education and certifications, and leading by example. E) Written goals and objectives are required in the HSSE policy.
Section 2: Policy and Strategic Objectives (i)
HSSE policy documents
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a) Does your company have an HSSE policy document signed and dated by the Chief Executive?
A) Yes
Section 2: Policy and Strategic Objectives (continued)
(i)
HSSE policy documents
(ii) Availability of policy statements to employees
Questionnaire items
Responses
c)
Who has overall and final responsibility for HSSE in your organization?
C) The position of Vice President has the final responsibility for HSSE.
d)
Who is the most senior person in the organization responsible for this policy being carried out on field personnel?
D) The position of Safety Director is responsible for field personnel.
a)
Itemize the methods by which you have drawn your policy statement to the attention of all your employees, including all those on field personnel.
b)
What are your arrangements for advising employees of changes in the policy?
A) HSSE policy is reviewed during employee orientation and the review is conducted by Safety Director. The policy is presented to all employees by the Safety Director on an annual basis.
B) Management of Change procedures is outline in the HSSE policy. Additionally, any changes are covered in the Weekly Safety Meetings at which time all employees are required to sign policy change Acknowledgements.
Section 3: Organization, Responsibilities, Resources, Standards and Documentation (i) Organization - commitment and communication
a)
How is management involved in HSSE activities, objective setting and monitoring?
b)
How is your company structured to manage and communicate HSSE effectively?
c)
What provision does your company make for HSSE communication meetings?
A) A number of manages hold positions on the HSSE Committee. A number of managers receive a variety of annual certifications. Management is also involved in setting goals, organizing and creating safety awareness and objectives, monitor compliance and implement policy. Managers perform job site monitoring and job site safety analysis and submit safety inspection reports. B) HSSE policy is communicated through the Safety Director during weekly safety meetings. Crew Foreman conducts toolbox topic safety meetings. Outside consultants provide training and information regularly to our employees through special programs set up by management. C) The company supports HSSE communication meetings through the monthly HSSE Committee meetings and weekly company wide Safety meetings and daily jobsite safety meetings.
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(II) Competence and Training of managers/ supervisors/senior site staff/ HSSE advisers
Have the managers and supervisors at all levels who will plan, monitor, oversee and carry out the work received formal HSSE training in their responsibilities with respect to conducting work to HSSE requirements? If YES please give details. Where the training is given in-house please describe the content and duration of courses.
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Yes. Training is provided inhouse during Orientation. The company Safety Director instructs managers and supervisors during Orientation and ongoing training is provided including training and certification by outside consultants and by OSHA. For inhouse training see attached matrix.
Section 3: Organization, Responsibilities, Resources, Standards and Documentation (continued)
(iii) Competence and General HSSE training
Questionnaire items
Responses
a)
What arrangements does your company have to ensure current and new employees including Short Service Employees (SSE <6mos) have knowledge of basic industrial HSSE, and to keep this knowledge up to date?
A) HSSE policy is presented to all employees and a Policy Acknowledgement form must be signed and is kept in the employee file. Annual training is given to all employees and acknowledgement forms are signed and filed.
b)
What arrangements does your company have to ensure current and new employees including Short Service Employees (SSE <6mos) have knowledge of your HSSE policies and practices?
B) We utilize the arrangements as above.
c)
What arrangements does your company have in place to ensure that all employees are competent to do their job in a safe and environmentally acceptable manner?
d)
What arrangements does your company have to ensure current and new employees including Short Service Employees (SSE <6mos) have been instructed and have received information on any specific hazards arising out of the nature of the activities?
e)
What training do you provide to ensure that all employees are aware of Company requirements?
f)
What arrangements does your company have to ensure existing staff HSSE knowledge is up to date?
same
C) All employees are trained to do their job safely, including spill protection, secondary spill containment systems, employment of effective erosion control methods, use of municipal dumpsites for jobsite waste and use of waste collection services. Collection of oil and other petroleum based waste by licensed company. Licensed recycler picks up used batteries and tires. All scrap aluminum and other metals are recycled. Biohazardous waste materials are disposed of through the local fire department. D) HSSE policy is communicated through the Safety Director during weekly safety meetings. Crew Foreman conducts toolbox topic safety meetings. Outside consultants provide training and information regularly to our employees through special programs set up by management. Supervisors give all employees JSA’s according to the job they are assigned. E) Training is scheduled periodically to ensure that employees are aware of company requirements. A training matrix is updated after every training session. F) The Safety Director monitors all OSHA alerts and communicates the alert to the employees. Additionally, we utilize third party resources and insurance agents and carriers for any changes in Safety requirements or practices. A training matrix ensures that
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employees are trained according to company HSSE policy and that each employee receives all the updates. (iv) Specialized training
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a)
Have you identified areas of your company's operations where specialized training is required to deal with potential dangers?
A) Yes. An example of specialized training would be the certification of aerial lineman safe pole climbing practices and aerial lift training. Another example would be confined space training. A third example could be environmental training dealing with jobsite hazards such as heat related illness or what to do in case of snake and spider bites. st CPR, AED and 1 Aid training is given annually to all employees.
Section 3: Organization, Responsibilities, Resources, Standards and Documentation (continued)
(iv) Specialized training (continued)
Questionnaire items
Responses
(If YES please itemize and provide details of training given.)
B) Hazards are identified in pre and post engineering jobsite surveys and notated on the work orders. A report is generated and delivered to the Safety Director who will verify the hazards, make any engineering controls and equipment changes/additions needed to create a safe work environment. Safety Director personally meets with the crew to discuss the safety concerns before commencement of work. Chemicals are disposed of through licensed third party vendors.
b)
If the specialized work involves, chemical or other occupational health hazards, how are the hazards identified, assessed and controlled?
(v) HSSE qualified staff additional training
Does your company employ any staff that possesses HSSE qualifications that aim to provide training in more than the basic requirements?
Yes. Safety Director has multiple designations and certifications and holds chairs on other Safety Committees outside our industry. Safety Director is a certified Emergency Medical Technician and Firefighter.
(vi) Assessment of suitability of subcontractors.
a) How do you assess: i) HSSE competence ii) HSSE record of the subcontractors with whom you place contracts? b) Where do you spell out the standards you require to be met?
A) I) By evaluating while training and performing regular jobsite evaluations and Safety quizzes. Ii) OSHA 300 and 301 logs are requested and reviewed. We review their safety policy and we perform jobsite safety inspections that are archive.
c)
How do you ensure these are met and verified?
d)
How do you manage the contractor - subcontractor interface?
B) In the contract we state they must, at minimum, match our safety requirements as spelled out in our safety manual. C) Job site inspections are conducted daily and we review their safety manuals and safety records. Moreover, we invite their employees to participate in our safety events and safety fairs. D) We issue work orders to subcontractor management. We conduct quality control and safety inspections at the jobsite. We set deadlines for work to be completed. We provide one main point of contact for them. We require they provide us with an escalation contact list.
(vii) Standards
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a)
Where do you spell out the standards you require to be met?
A) The subcontractor contract spells out all standards and requirements. A copy of the prime contract/general contract is
b)
How do you ensure these are met and verified?
c)
Is there an overall structure for producing, updating and disseminating standards?
provided to the subcontractor and language in the subcontract is provided that requires the subcontractor to perform to the standards set forth in the general contract. B) Supervisors are high profile on all jobsites and quality control personnel perform daily jobsite inspections. Jobsite inspectors are assigned to specific crews when necessary to insure integrity of the product placement and methods. C) HSSE Committee meets every month to produce, update and disseminate standards. Managers, supervisors and employees provide input from field observations.
Section 4: Hazards and Effects Management (i) Hazards and effects assessment
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What techniques are used within your company for the identification, assessment, control and recovery of hazards and effects?
Inspections and jobsite surveys. Once hazards are identified, engineering and safety assessments are made and operating procedures are drafted and distributed to the work crews and management team. Trauma care instructions and extrication is created and distributed.
Section 4: Hazards and Effects Management (continued) Questionnaire items
Responses
(i) Hazards and effects assessment (continued)
Provide detail on Risk Assessment procedures.
Identification, verification through inspection, then communication to employees, then resolution and education.
(ii) Exposure of the workforce
Do you have in place any systems to monitor the exposure of your workforce to chemical or physical agents?
Yes.
(iii) Handling of chemicals
How is your workforce advised on the properties of chemicals encountered in the course of their work?
MSDS training and additionally walk thru after safety orientation.
(iv) Personal protective equipment
What arrangements does your company have for provision and upkeep of protective clothing, both standard issue, and that required for specialized activities?
Company issued PPE including shirts, hard hats, lineman boots, hot gloves, safety glasses, vests, gloves other than hot gloves, particulate filter/masks, asbestos masks, hearing protection, welding hoods, jackets, rain gear including pull over rubber boots. For upkeep, we perform annual training in PPE, inspection and cleaning.
(v) Waste management
Does your company have in place systems for identification, classification and management of waste?
Yes. For example, Blood Borne Pathogens, motor oil and other fluid disposal.
Section 5: Planning and Procedures (i)
HSSE or operations manuals
a)
b)
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Do you have a company HSSE manual (or Operations Manual with relevant sections on HSSE) that describes in detail your company approved HSSE working practices relating to your work activities?
How do you ensure that the working practices and procedures used by your employees or field personnel are consistently in accordance with your HSSE policy objectives and arrangements? Provide a copy of a typical JSEA.
A) Yes, and it is available for review. B) We have full time personnel, in addition to the safety director, who perform daily jobsite inspections and track the time, crew type and crew member names, results and findings of each jobsite inspection on a excel spreadsheet daily, which is then submitted to the vice president at the end of each week for review, comment, and recommendations.
Section 5: Planning and Procedures (continued) Questionnaire items
Responses
(ii) Equipment control and maintenance
How do you ensure that plant and equipment used within your premises, on-site, or at other locations by your employees are correctly registered, controlled and maintained in a safe working condition? Provide details and evidence of preventative maintenance programs.
Vehicle Inspection reports are required from all drivers every week before receiving one’s paycheck. Daily jobsite inspections by Safety Director include equipment inspections. Lockout Tagout program is in place to control malfunctioning equipment. We have a fleet policy addendum that covers vehicle maintenance procedures; the accountability clause makes the employees accountable for the regular maintenance of vehicles and equipment.
(iii) Road Safety Management
What arrangements does your company have for combating road and vehicle incidents?
(iv) Emergency Preparedness
a)
What emergency plans does your company have in place for field personnel?
b)
Who is responsible for ensuring every crew has an emergency plan?
c)
(v) Meetings with Field Personnel
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What is the policy on carrying out emergency drills and simulations? Is there a forward drill schedule?
a)
What meetings are held with employees on field personnel to discuss HSSE? What is the average frequency?
b)
Are records of crew level HSSE meetings maintained?
c)
Is individual participation at crew level in HSSE performance achieved? If so, how?
New Hire drives evaluations, annual and post accident driver evaluations. Also Safety Meeting topics include Driver Awareness. Seasonal training through Toolbox Topics relevant to the current weather conditions. Employees are held accountable through our drivers point policy. A) Emergency Plans include: General Emergency procedures, Evacuation plan, Weather Emergency plan, and Terrorist Threat plan. B) The Safety Director distributes the Emergency plans at the New Hire Orientation and annually. C) Emergency drills are carried out annually. The drill schedules are listed on the training matrix. A) Field personnel are required to attend weekly safety meetings at the corporate office. Field personnel attend daily safety meetings on the jobsite if necessary. The average frequency is one to two times per week. B) Yes. Employees sign Safety meeting rosters, job site inspection forms and all other trainings, copies of training certificates that are issued are filed in the employee personnel file. Safety test results are also filed in the employee personnel file.
C) Yes. Every employee participates in Safety training and employees are retrained and reevaluated until the employee meets all requirements for the training.
Section 6: Implementation and Performance Monitoring (i) Management and performance monitoring of work activities
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a)
What arrangements does your company have for supervision and monitoring of performance?
A) Safety Director performs daily jobsite inspections and annual performance evaluations. Managers and supervisors evaluate field personnel daily and report to the Safety Director employee safety issues. The Safety Director, managers, and supervisors work together to make sure we have a safe working environment for all employees.
Section 6: Implementation and Performance Monitoring (continued)
(i) Management and performance monitoring of work activities (continued)
Questionnaire items
Responses
b)
What types of performance criteria are used in your company; give examples of all quantitative performance measures in use.
c)
What arrangements does your company have for passing on any results and findings of this supervision and monitoring to your:
B) Examples of performance criteria used are the Drivers Point Policy in which drivers must meet the minimum point to qualify them as a driver. Safety tests are graded on a percentage basis and employees must meet a minimum test grade.
i)
base management
ii)
site employees?
Ci) and Cii) Results to base management and site employees needing immediate attention are notified to Safety Director via direct connect or cell. All other non-urgent findings are communicated through email, safety meetings or safety committee meetings.
(ii) HSSE performance achievement awards
Has your company received any award for HSSE performance achievement?
Yes. The most recent was the 2007 “Best in Class” Award from Amerisure, for outstanding safety practices and no loss-time incidents in 2007.
iii) Statutory notifiable incidents /dangerous occurrences
Has your company suffered any statutory notifiable incidents in the last five years, safety, occupational health and environmental?
In 2005, we were cited for failing to certify an employee owned (personal) hot glove that was in one of our company trucks but not a company issued PPE. The company issued gloves had been certified. Follow up preventative measures put in place include we do not allow employees to bring personal PPE on company property, all PPE on company property or jobsites must be company provided.
(iv) Improvement requirement and prohibition notices
Has your company suffered any improvement requirement or prohibition notices by the relevant national body, regulatory body for HSSE or other enforcing authority or been prosecuted under any HSSE legislation in the last five years?
No.
(v) HSSE performance records
a)
A) Yes.
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Have you maintained records of your incidents and HSSE performance for the last five years?
Section 6: Implementation and Performance Monitoring (continued)
(v) HSSE performance records (continued)
(vi) Incident investigation and reporting
Questionnaire items
Responses
(If YES, please give following details for each year, number of Non Lost Time Injuries, number of Lost Time Injuries, number and type of injuries, total hours worked by workforce for each corresponding year, Frequency Rates, TRIRs for previous 12 months and rolling, plus your company definition of a Lost Time incident).
B) Health performances are filed in HR files separate from employee files.
b)
How is health performance recorded?
c)
How is environmental performance recorded?
d)
How often is HSSE performance reviewed? By whom?
a)
Who conducts incident investigations?
b)
How are the findings following an investigation, or a relevant incident occurring elsewhere, communicated to your employees?
c)
Are near misses reported?
d)
Does senior management receive formal accident investigation training? Give examples.
a)
Do you have a written policy on HSSE auditing and how does this policy specify the standards for auditing (including unsafe act auditing)?
C) Environmental Phase II study at corporate headquarters. D) HSSE performance is reviewed monthly by the Safety Director and Vice President.
A) Safety Director and project managers conduct incident investigations. B) At weekly safety meetings, toolbox topics, email, telephone and employee conference. C) Yes. D) Yes, certifications through OSHA and private consulting firms.
Section 7: Auditing and Review (i)
Auditing
b)
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Do your company's HSSE Plans include schedules for auditing and what range of auditing is covered?
A) Yes. The audit must include in its report cause and effect, cost, and resolution, prevention and education. B) We audit annually for safety awards and the Vice President audits periodically for reasons highlighted above.
Section 7: Auditing and Review
(i)
Auditing (continued)
Questionnaire items
Responses
c) How is the effectiveness of auditing verified and how does management report and follow up audits?
C) The positive or negative impacts on the safety culture are gauged and verified by the safety committee at the safety committee meetings, and director proposed policy changes to make effective improvements.
d) How often are formal inspections of field personnel carried out and by whom? Provide forward schedule of inspections. e) What records are kept of crew inspections? Provide examples. f) What follow up procedures are in place for actions identified during crew inspections?
D) Daily by Jobsite Safety Officer. For example, for one of our Texas jobsites, the Safety Officer is currently required to inspect 5-10 crews per day. E) Please see attached Crew Jobsite inspection report form. These forms are triplicate. One copy goes to crew foreman, one copy is filed at corporate office and one copy is given to employee. F) If there is a violation that warrants a verbal or written warning the Safety Director will forward the warning to the employee’s supervisor. The supervisor will have a consultation with the employee and the signed form will be placed in the employee file. The employee will continue to be inspected for safety frequently, and placed in additional training if it is determined necessary.
Section 8 : Management of Change (i)
Content
a) Is there a system in place for the management of temporary and permanent change? Give examples. b) What change management procedures are in place?
A) HSSE changes are managed by the Vice President. The Safety Director will get approval from the Vice President and make appropriate changes to the Safety Manual, the New Hire Orientation, Employee Handbook, and training matrix. B) Changes are first evaluated the approved by the Safety Director at Safety Committee meeting. Final approval is obtained by the Vice President then communicated to company employees.
Section 9: HSSE Management - Additional Features (i)
Memberships of Associations
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Does your company hold membership of any industry, trade or HSSE organization?
Yes, TESS, National Safety Council, American Red Cross and SCTE. The Safety Director is a member of NREMT and NFPA.
If so, which ones? ii) Additional features of your HSSE management
Does your company have any other HSSE features or arrangements not described elsewhere in your response to the questionnaire?
The Safety Director sits on other Safety Committee boards and brings valuable information. The Safety Director and Vice President have a close working relationship with Loss Control Service departments of the insurance company and the insurance agency. The agency and the carrier are involved multiple times per year in trainings and evaluations. A Market Probe Study is performed every 18 months to identify issues of the safety culture.
iii) Use of Industry or Trade Guidance Documents
Does your Company use industry or trade HSSE guidance documents? If so, how is this information utilized?
Industry or trade guidance documents and information is incorporated into our Safety program.
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