Element 4

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ELEMENT

Health and Safety Monitoring and Measuring 4 71

ELEMENT 4

HEALTH AND SAFETY 04


MONITORING AND
MEASURING

Learning Outcomes:

4.1.  iscuss common methods and indicators used to monitor the effectiveness of
D
management systems

4.2. Explain why and how incidents should be investigated, recorded and reported

4.3.  xplain what an audit is and why and how it is used to evaluate a management
E
system

4.4.  xplain why and how regular reviews of health and safety performance are
E
needed

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72 NEBOSH International General Certificate in Occupational Health & Safety

4.1 Active and Reactive Active monitoring methods (health


Monitoring and safety inspections, sampling
and tours) and their usefulness
The Differences between Active and
Reactive Monitoring Following is the list of different active monitoring methods.
We have seen previously that an organizations health  Safety Inspections
and safety management system is based on the P-D-C-A
 Safety Tour
Cycle. In this element we will be introducing ourselves to
the Check part or the monitoring of the health and safety  Safety Sampling
management system. Most of the active monitoring methods gather information
Managers need to check the organizations performance by looking at the following three aspects:
so as to verify whether the targets set have been met or  Documentation: by examining records, reports and
still something needs to be done to achieve them. This documents.
check can be done by active and reactive monitoring.
 Interview: by speaking to people concerned to gauge
Health and Safety Monitoring Methods: their views and opinions and,
Active Monitoring:  Observation: by looking at peoples’ behaviour and the
This is done actively before something goes wrong, conditions present, in other works looking at unsafe
involves routine inspections and checks to ensure that acts and conditions.
standards are met, policies are implemented and the Active monitoring will thus help us in actively monitoring
controls are adequate to take care of the risks present. It the workplace and help us prevent any untoward incidents.
measures the Progress Now the questions rises is, what is to be measured and
how are they going to be measured. We will now answer
both of these questions.

What is Going to be Measured: Creating


our Own Performance Standards:
Every organizations work type and culture is different
and what is measured by one organization need not be
measured by another. As such the products, processes
and environment also differs. The following are some
examples of performance standards which can be used for
active monitoring:
Reactive Monitoring:  We can monitor whether health and safety training
This is done after something goes wrong, like for has been imparted as per the agreed training
example an accident or an ill health event. This helps the calendar.
organization to learn from mistakes and put measures in
 Housekeeping can be monitored by dividing the
place to prevent its recurrence. It measures the Failures.
organization into various zones and comparing each
zone against a set checklist
 Checking the quality and number of risk assessments
 Checking whether safety inspections are happening
as per the schedule
 Checking if safety rounds have been conducted
 Whether workers are undergoing medical surveillance
as per the schedule
Once the performance standards are set, then we can go
about systematically checking them.

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Health and Safety Monitoring and Measuring
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Active (Proactive) Monitoring Methods in How to Carry out Systematic Inspections?


Detail: To ensure that while carrying out an inspection, nothing is
1. Safety Inspections: missed out, one way of doing this is by using the concept
of the 4Ps.
The term, safety inspection means a regular, scheduled
 Plants and substances - which include work
activity and there is a comparison done to some standards
equipment, manual and mechanical handling
to confirm acceptability.
equipment, vehicles, dangerous and flammable
A safety inspection involves the straightforward materials and hazardous substances.
observation of a workplace and/or the activities or  Premises - which include access, egress, working
equipment within it with the aim of identifying hazards environment and housekeeping areas
& assessing the use and effectiveness of control
 Procedures - which include risk assessments, permit
measures. It is usually carried out by a manager, employee to work, contractor management etc.
representative and Safety Advisor and is often aided by
 People - which include primarily the behaviour of the
the use of a checklist.
people, their training and ability and if they are vulnerable.
Safety inspections could be ‘routine’ which could be done Now, the above 4Ps inspections might be done in such 04
to check say the housekeeping standards of a workplace. a way as to all four elements are covered in a single
It could be either a ‘periodic’ inspection which is done at inspection or each of these elements may be inspected
a regular interval or a ‘pre-use check which is done at the separately, for e.g:
start of every shift. It could also be ‘statutory’ inspection
 A daily inspection (plant) may be carried out of the
to fulfill a legal requirement. fork lift trucks before start of operation each day by
the operator.
 Supervisors can check the behaviour of the people
once every week or fortnight.
 There could be random check of the procedures used
maybe once every week.
 A weekly round may be carried out to ensure that the
normal entrances/exits and the fire exits (premises)
are free of any hindrances and hazards.
The Arrangements Required to carry out
the Workplace Inspection
Who will do the Inspection: Along with the type of
Types of Safety Inspections: inspection it is also necessary to give specific responsibility
 Routine Inspection: To determine if general for each type of inspection. For example pre-use inspection
standards of health and safety are acceptable or is done by the operators themselves, while monitoring
if corrective action is necessary (e.g. a quarterly the behaviour of the workers is done by supervisors and
housekeeping inspection in an office). likewise a thorough check of a portable electrical machine
is done by maintenance.
 Statutory Inspection is performed by a competent
person to fulfill a legal requirement (e.g. the  The competence of the inspector- this is essential
annual thorough examination of an item of lifting to meet the objectives of the monitoring. A person
equipment). needs to be trained on how to carry out the
inspection correctly and should be clear as to what is
 Periodic Inspection of plant and machinery as part
acceptable and what is not. He may also require to be
of a planned maintenance program (e.g. a mechanic
certified and a record needs to be maintained of any
inspects the brakes on a lorry on regular basis to
training given.
ensure they are not excessively worn).
 The objectivity of the inspector- An inspector needs
 Pre-use-checks carried out by workers before they to be impartial and objective while carrying out an
use certain items of plant and machinery (e.g. the inspection.
startup checks carried out by a forklift truck driver).
The person carrying out an inspection should have the

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74 NEBOSH International General Certificate in Occupational Health & Safety

necessary  A lesser competent inspector can do the inspection,


provided that the checklist is created by an expert.
 Training
 Checklists themselves become a standard, with which
 Knowledge and experience
the actual situation can be compared with and there
 Certification to a specific standard
is also consistency of approach.
 Understanding of the workplace
 Finally a filled up checklist becomes a record for
 Health & Safety principles future reference.
 Willingness to ask questions However, there are certain drawbacks of checklists that
 Impartial and objective in their approach even in a we should be aware of:
familiar area
 Checklists need to be reviewed and revised regularly
Frequency of Inspection: as processes and procedures change. This may not
This depends upon the type of inspection and the hazards happen and older checklists may be used, thereby
present. For example an office would require less frequent overlooking certain new hazards.
inspections compared to a workshop, while the inspection  Checklists could be filled up from the desk without
of a hazardous chemical storage area requires to be done any actual inspection.
even more frequently. Other things to be considered are  Inspectors may overlook certain hazards which not be
the manufacturers’ recommendations and if there is any mentioned in the checklist.
law to govern the frequency, for example a statutory
Typical Topics that might be Included in a
inspection of a crane needs to be done once every year.
Generic Safety Inspection Checklist
Factors to be taken into Account while
 Housekeeping- cleanliness of the aisle, proper storage
Determining the Frequency of Inspection: of material.
 The level of risks in the activity.  Fire- Escape routes, emergency procedures, fire
 The manufacturers’ recommendations. detection, firefighting, proper storage of flammable
 The companies’ own internal policy. materials.

 In some cases the countries laws may determine the  Chemicals- correct storage and usage, compliance to
frequency. PPE.

 Inspection and audit findings may suggest a higher  Electrical- proper usage of portable tools, use of
frequency. protective devices.

 Previous accident history and results of investigations.  Environment- adequate lighting, noise and dust
controls and space.
 Complaints from workers.
 Vehicles- segregation of pedestrians, pedestrian
 Risk assessments may suggest Inspections
crossing zones, vehicle parking areas.
Tools Required for Inspection - The
Action Plan for the Issues Identified:
Checklist:
Post inspection there should be arrangements to rectify
Checklists are good tools to ensure the systematic and
the problems that may have been identified during the
correct inspection of the workplace. The following are the
inspection. The problems identified should be prioritized
merits of using the checklist:
and the same should be followed up until the controls are
implemented.

Active Monitoring Techniques (Contd.):


2. Safety Sampling:
A safety sampling is done to save on time as the inspector
looks onto a representative sample and depending upon
the sample been acceptable or not the inspector could
decide on compliance or non-compliance. For ex: if a
construction site has 25 different types of ladders, 2 may
 Checklists ensure that nothing is missed out during
be picked up by an inspector to check for compliance for
inspection.
safety norms and thus concludes that all of the ladders

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Health and Safety Monitoring and Measuring
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are compliant. But safety sampling cannot replace 100%  Lessons learnt from a single incident or
inspection. It goes without saying that somebody had  Lessons learnt from incidents as a whole that has
to do the 100% inspection and only to ensure that this happened, say in the last three years.
Data can be converted into trends which can tell the
organization whether the numbers of incidents are
showing an upward or a downward trend or

Data can generate hot spots so as to know, what areas of


the organization require specific management attention
so as to improve the safety performance.

The data collected needs to be converted into certain


indices to enable meaningful comparison. There are
different indices that industries generate for comparison.
One among them is the ‘accident incidence rate’ or the
AIR. Following is the formula:

AIR = (Number of accidents in the given period/ the


04
average number of people in the given period) x 1000.

This formula converts the incident data into a figure that


inspection is been done correctly a random sample is would be equivalent for every 1000 workers, thus allowing
picked up and confirmed. for comparison of data within each organization and
across organization.
3. Safety Tours:
This term implies a routine unplanned round taken by a high
Benefits of Collecting Near Miss Data:
ranking manager. The manager can take along with him We can identify underlying causes which may allow
the line manager, supervisor and workers representative. preventative action to be taken before something more
The main objective of this tour is for the observation of serious occurs. It gives message to workforce that all
workers’ behaviour and promotes consultation and shows failures are taken seriously not just those leading to injury.
visible leadership of the management.
Generally accepted near misses greatly outnumber
accidents and can therefore produce more data from
Reactive Monitoring Measures and
which a greater understanding of the deficiencies in
their Usefulness: management systems can be identified and rectified

This is done to learn from past incidences and prevent it Evaluation of Performance by Looking at
from happening in the future. The reports generated from the Enforcement Action:
reactive monitoring denotes the failures of the systems
The number of enforcement actions over the last several
and ineffectiveness of the control measures
years can also be converted into trends so as to analyze
Reactive monitoring examines the following to measure whether it is rising and if yes to find out the reasons for the
health and safety performance same. The fines issued by courts are also worth analyzing.
 Accident data Evaluation of the Performance by Looking
 Ill health data at the Civil Claims:
 Absenteeism data Workers or others affected by the organizations activities
 Claims records can approach the civil court against the employer to
 Number of complaints reported claim for compensation. Organizations may also track the
 Prosecutions number of civil claims year on year and the total amounts
paid to compare their performance reactively.
 Enforcement notices
Evaluation of Performance by using
Incident Data Statistics:
The data on above reactive methods can be analyzed from:

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76 NEBOSH International General Certificate in Occupational Health & Safety

Why lessons need to be learnt from The Difference between Leading and
beneficial and adverse events. Lagging Indicators
What are Beneficial and Adverse Events?
Sr.
Organizations with positive culture are always striving Leading indicator Lagging indicator
No.
to improve their health and safety performance. The
steps thus taken may result in the safety performance to 1 A leading indicator is Lagging indicators are
improve, like for e.g. a reduction in reportable accidents, proactive in nature. measurements that
or a decrease in compensation payments as a result of They include safety include data from the
reduced incidents and claims etc. These events which lead initiatives or reported past. They include
to improved performance are known as beneficial events. activities, with the goal of incidents and accidents
preventing unfavourable statistics.
While adverse events are those that lead to deterioration
events before they
of the health and safety performance. For e.g. an increase
happen.
in ill health or a large number of fire incidents.
2 Leading indicators are Lagging indicators
 The Lessons learned from both beneficial and adverse
generated as a result are generated as a
events is the learning gained from the process that is
of active monitoring result of reactive
applied.
activities like safety monitoring activities
 Each failure or success needs to be analysed, so that inspections, preventive like measuring hours
what has been done correctly and what has been not maintenance etc. lost due to reportable
is known to the organization. injuries.
 Beneficial events will give the confidence to the
management to replicate the processes that lead to 3 Leading Indicators can Examples of Lagging
such benefits all throughout the organization. For e.g. include: Indicators:
if the organization finds that the implementation of  Number and type  Injury Frequency
a new fire checklist has drastically brought down the of Safety Trainings and Severity
number of fire incidents, then the same may be taken completed vs planned  Lost Workdays
up by all the departments.
 Results of  Reportable
 Similarly, adverse events are something which needs Behavioural Audits incidents
to be investigated and the root causes needs to be
 Results of Safety  Employees
evaluated. The learning’s from such events and the
Audits compensation cost
ways to prevent it should be communicated across
the organization so that it does not repeat again.  Number of Toolbox  Chemical releases
Talks done vs planned
 Organizations understand that they will benefit
from better knowledge of accidents if they, in turn,  Participation in Safety
commit to improve their approaches to investigation, Committee
including the way these generate recommendations  Equipment/Machinery
and reports. The consequence should be lessons Maintenance vs
being learned, improvements made, fewer accidents planned
and so reduction in losses.  Hazard Identification
 Lessons learnt need not be only from events within & Risk Assessments
the organization but also from adverse and beneficial
incidents outside the organization. 4 Leading indicators will The results of the
help to improve safety lagging indicators
Organizations, thus take advantage of the key learning
through awareness will prove to the
opportunities given by both adverse and beneficial events.
and prevention and will management that the
In fact, it is a key feature of the P-D-C-A cycle which leads
show stakeholders that steps taken to improve
to continual improvement.
the company is taking occupational health
proactive steps to achieve and safety is actually
excellence in safety. working.

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Health and Safety Monitoring and Measuring
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4.2 Investigating Incidents Role and Function of Investigation:


An incident investigation plays the following roles:

 It is a reactive monitoring technique and hence


presents the organization with valuable data for
analysis (trends).
 A proper investigation helps us understand why
the incident happened and what could be done to
prevent it in the future.
 An incident would generally point out to a failure in
the risk assessments, at the same time the results
of an incident investigation will tell us what changes
needs to be done in the risk assessment by means of
additional or enhanced control measures.
This course concentrated in prevention of accidents till
now, but in spite of our best efforts, still accidents may  An investigation ensures that the staff isn’t
happen and same could lead to injury or damage to demoralized by the incident. 04
property.  Internally a company has to decide on disciplinary
measures against workers who may have played a
When an incident happens, it is important on the part of
part in the accident. Investigations are not to be
the organization to record it correctly and investigate it to
avoid a recurrence. carried out for putting blame on workers, but it
definitely throws light on who needs to be disciplined.
Clearly, there are good financial reasons for reducing
 An incident investigation is also a legal requirement.
accidents and ill health. Costing show that for every Rs.
100/- a business spends on insured costs, it can be losing  To process a claim from the insurance agency, an
between Rs.800/- and Rs.3600/- in uninsured costs. investigation is required.
 Incident investigation helps in calculating the costs of
The same accidents happen again and again, causing
suffering and distress to an ever-widening circle of accidents.
workers and their families. The investigation and analysis
Reporting of Incidents Plays the following
of work-related accidents and incidents forms an essential
Role:
part of managing health and safety. However, learning
the lessons from what you uncover is at the heart of  To preserve the accident scene for future
preventing accidents and incidents. Identify what is wrong investigations.
and take positive steps to put it right.  To meet the legal requirement to report incidents.
Carrying out our own health and safety investigations  To trigger the provisions of first-aid treatment.
will provide us with a deeper understanding of the risks
associated with our work activities. Blaming individuals is Different Levels of Investigations:
ultimately fruitless and sustains the myth that accidents
Minimal, Low, Medium and High
and cases of ill health are unavoidable when the opposite
is true. Well thought-out risk control measures, combined (With reference to HSG245)
with adequate supervision, monitoring and effective
The table below will assist you in determining the level
management (i.e. our risk management system) will
of investigation which is appropriate for the adverse
ensure that our work activities are safe. Health and safety
event. Remember you must consider the worst potential
investigations are an important tool in developing and
consequences of the adverse event (e.g. a scaffold collapse
refining our risk management system.
may not have caused any injuries, but had the potential to
An effective investigation requires a methodical, cause major or fatal injuries).
structured approach to information gathering, collation
and analysis. The findings of the investigation will form the
basis of an action plan to prevent the accident or incident
from happening again and for improving our overall
management of risk. Our findings will also point to areas
of our risk assessments that need to be reviewed. This link
with risk assessment(s) is also a legal requirement.

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78 NEBOSH International General Certificate in Occupational Health & Safety

Observation:
The scene of the incident needs to be approached and
physical evidence needs to be gathered, investigators may
observe for ex; a patch of oil or a broken tool or a tripped
off circuit breaker etc. These will be vital clues and aid
finding out the root cause of the incident.

To aid in these observations an investigator needs to come


prepared with appropriate equipment like:

 Cameras to capture the scene.


 Measuring tape to take measurements.
 Pen and notebook to take down the observation and
make sketches.

 In a minimal level investigation, the relevant Interview:


supervisor will look into the circumstances of the
There may be one or several witnesses to an incident.
event and try to learn any lessons which will prevent
Interviewing these witnesses provides with substantial
future occurrences.\
clues as to what caused the incident. Witnesses need to
 A low-level investigation will involve a short be interviewed at the appropriate time, some witnesses
investigation by the relevant supervisor or line manager may be in shock and may not be able to respond to
into the circumstances and immediate, underlying and queries adequately- this needs to be considered by the
root causes of the adverse event, to try to prevent a investigators.
recurrence and to learn any general lessons.
Following is the technique to be followed while conducting
 A medium-level investigation will involve a more
a witness interview:
detailed investigation by the relevant supervisor
or line manager, the health and safety adviser and  Interview to be carried out in a quiet room away
employee representatives and will look for the from the accident spot, so that there can be proper
immediate, underlying and root causes. interaction with minimum distractions.

 A high-level investigation will involve a team-  The interviewer should then introduce himself, and
based investigation, involving supervisors or line clear the purpose of the interview as something of
managers, health and safety advisers and employee a fact finding mission, rather than a fault finding
representatives. It will be carried out under the mission. Emphasis should be laid out on the fact that
supervision of senior management or directors and will the interview is important so as to find out the cause
look for the immediate, underlying, and root causes. of the incident and avoid it from happening again.
 The interview is to be recorded and signed at the end
Basic Incident Investigation Steps:
of the session as a record.
Before an incident investigation can start, the following  The interview should be carried out using open ended
things needs to be considered: questions like ‘What’, ‘where’, ‘why’ etc. This is to
1. Gathering the information prevent putting words into the witnesses’ mouth and
allow him to openly express his opinion.
2. Analysing the information
 The interviewer should keep an open mind and not
3. Identifying risk control measures
jump into conclusions.
4. The action plan and its implementation  End the interview by thanking the witness.
Step 1: Gathering the Information Documentation:
Information can be gathered by looking at the following Records and documentation will have to be referred so
three things: as to substantiate the physical and verbal evidence with
 Observation. written records. The records could be varied and exhaustive
 Interviews. (depends upon the type of accident and the depth of
investigation). In general the following documents may be
 Documentation.
checked and examined:

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Health and Safety Monitoring and Measuring
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 The relevant policies of an unauthorized access aisle, not looking where he’s
 Employee training records going, and heads towards a fire exit – a short cut to the
 Maintenance records car park.

 Sickness and absenteeism records The forklift truck driver sees the man at the last minute
 Risk assessments and brakes hard, but skids on a patch of oil left by a leaking

 Safe system of work forklift. He comes to an abrupt stop and the load falls onto the
warehouse operative, breaking his arm and bruising his leg.
 Site plans and layout
 Active monitoring records In this example the immediate causes are:

 Struck by the load


Step 2: Analysing the Information
 Load falling
The information gathered from the above, and then needs
to be analysed so as to find out the causes of the incident.  Forklift skidding
The causes of the incident are most commonly divided  Patch of oil
into:  Braking hard
 Immediate causes  Using the unauthorized aisle 04
 Underlying causes  Speed
 Root causes The underlying causes are:

Immediate Causes:  Forklift leaking

This as the name suggests is the immediate reason for the  Rushing to get the job done
cause of the accident. Let’s take that an operator hurt his  Speed limiter removed
finger while operating machinery. This would have been  Lack of maintenance or inspection
caused by a guard not present or the guard removed.
 Taking a short cut
The immediate causes are the result of ‘unsafe acts’ and
‘unsafe conditions’. In this case the unsafe act is removal  Leaving work early
of the guard, and the unsafe condition would be guard not The root causes are:
provided in the first place itself.
 Lack of supervision
Underlying Causes:  Work pressures
These are the causes which are behind the immediate  Poor customs and practices
causes. These could be like time pressures to complete the
task, not enough training or lack of maintenance. Step 3: Identifying Risk Control Measures
Control measures now need to be identified to remedy
Root Causes:
the situation. These measures should take care of both
These would normally point towards management the immediate and root causes. These control measures
deficiencies like no policy for training, no preventive should be well thought of for
maintenance of the machines, poor work practices.
 No control measures in place or if so not used
Let’s now take an example of an accident and try to find
 Prevent any wrong measures been implemented and
out the root causes:
thereby loss of time, cost and effort
You’re the manager of a distribution depot. It’s Friday
 Combinations of the above.
afternoon, close to the end of the working day.
Each possible risk control measure should be evaluated for:
One of your warehouse operatives has had enough for
the day and decides to pack up early. Meanwhile, in the  Their ability to prevent recurrences
warehouse one of your forklift truck drivers, who’s equally  Whether they are practical
keen to finish his work, is driving his truck loaded with
 Whether they will be used
boxes of paint. The forklift truck turns a corner and heads
 Whether they will remain effective
at speed along the aisle towards the loading bay.
It will be important to consider whether similar risks exist
At that very moment, the warehouse operative comes out
elsewhere in the premises or on another site.

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80 NEBOSH International General Certificate in Occupational Health & Safety

Information from the event, etc. should be circulated  Internal Incident Reporting:
to other areas. Organisations are particularly open to An organization through its incident reporting policy
criticism if a series of similar accidents occur. should put systems in place for incidents to be recorded
Example: and reported internally. It should specify the different
types of incidents that need to recorded, the means
 Immediate actions could be: cleaning up an oil spill, or
of reporting and the responsibilities of reporting and
replacing a guard.
recording the incident.
 Long term measures could be like: Creating a
A typical internal incident report would contain the following:
housekeeping policy and daily cleaning regime, or
preventive maintenance of the machines at regular  Name and address of the casualty
intervals.  Date and time of the incident
 Location of the accident
Step 4: The Action Plan and its
Implementation  Details of the injury
 Details of the treatment given
Remedial actions should be both corrective and preventive
and they need to be recorded in a systematic way so as  Description of the event causing injury
to make the plan actionable. The best way to do this is to  Details of any equipment or substances involved
create an action plan. Action plan in simple words can be  Witnesses’ names and contact details
described as “who will do what and by when”.  Details of the person completing the record
This action needs to be reviewed periodically so as to close  Signatures
out the action points within the stipulated period. The An organization having created a means of reporting the
action needs to be prioritized depending upon the severity incidents should then go about encouraging the workers
of the incident. Those actions, if not taken can lead to legal for reporting the incidents. But, unfortunately there are a
action, would obviously call for a higher priority. large number of barriers that may prevent a worker from
Following are the contents of a typical incident reporting incidents.
investigation form: Some of the barriers of incident reporting could include:
 Date and time of the incident.  No reporting policy in place.
 Location of the incident.  A work culture of not reporting.
 Details of the injured person/ persons involved.  Workers not aware that reporting of incidents is part
 Details of injury sustained. of their roles and responsibilities.

 Description of the activity carried out the time.  There is blame culture in the organization, workers
are afraid of disciplinary measures or of reprimand.
 Drawings or photographs used to convey information
on the scene.  Filling of the forms are too hard or takes too long.

 Immediate and underlying/ root causes of the  There is peer pressure that prevents reporting.
incident.  Once reported there is poor management response.
 Assessments of any breaches of legislation.  Some may not report so as to prevent the
 Details of witnesses and witness statements. departmental statistics from been affected which
may then further impact the earnings in the form of
 Recommended corrective action, with suggested
incentives.
costs, responsibilities and time scales.
Internally an incident may have to be notified to a range
 Estimation of the cost implications for the organization.
of personnel, the more dangerous the incident the
How occupational accidents and diseases are more higher up it will be have to be reported. Generally
recorded and notified by the organisation following are the personnel who would be notified about
(as per ILO Code of Practice – chapters 4–7) the incident:

When an incident happens, it needs to be recorded and  The top management.


reported. An incident would require to be reported both  The HR and personnel department.
 Internally within the organization and  The health and safety specialist.
 Externally to agencies.  Workers representative.

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Externally: Chapter III, Clause 11: Notice of certain


 To the family of the casualty. Dangerous occurrences
 Insurance companies. Where in an establishment there is any dangerous
 Public relations advisors. occurrence of such nature, (whether causing any bodily
injury or disability, or not) the employer shall send notice
Reporting of incidents to external agencies thereof to such authorities, and in such form and within such
Depending upon the type of incident, certain incidents time, as may be prescribed by the appropriate Government.
needs to be notified to the external agencies particularly Chapter III, Clause 12: Notice of Certain
the enforcement agencies. Following are the types of diseases
incidents that need to be reported to the enforcement
agency: (1) Where any worker in an establishment contracts any
disease specified in the Third Schedule, the employer
 Accidents that have resulted in major injuries or “Loss of the establishment shall send notice thereof to such
time injuries’’. authorities, and in such form and within such time, as
 Dangerous occurrences as notified in the law. may be prescribed by the appropriate Government.
 Occupational diseases.
These incidents need to be reported within a set time
4.3 Health and Safety Auditing 04
frame in the format prescribed by the enforcement Definition of the term ‘Audit’ (as per
agency.
Clause 3.32, ISO 45001:2018)
The ILO has published several international standards
on recommended reporting procedures. The principal
ISO 45001 defines audit as “a systematic, independent
and documented process for obtaining audit evidence
reference is the 2002 Protocol to the Occupational
and evaluating it objectively to determine the extent
Safety and Health Convention 1981 (P155); this greatly
to which the audit criteria are fulfilled.”
expands the general reporting standards of article 4 of the
occupational Safety and Health Convention 1981 (C155). It It is normally a lengthy process carried out by a trained
is supported by recommendation 194, which lists types of auditor, often someone from outside the organisation,
diseases that should be reported to national governments. looking at the strengths and weaknesses of the
organisation by using questionnaire.
The Indian connection: The Occupational Safety,
Health and Working Conditions Code - 2020 Why Health and Safety Management
Chapter III, Clause 10: Notice of certain accident Systems should be audited
1) Where at any place in an establishment, an accident An audit, if carried out systematically, would critically
occurs which causes death, or which causes any evaluate the organizations existing Health and Safety
bodily injury by reason of which the person injured is Management System (HSMS) and suggest for changes
prevented from working for a period of forty-eight which would bring about better results. It is a structured
hours or more immediately following the accident or way of assessing the health and safety performance of an
which is of such nature as may be prescribed by the organisation by multipronged approach as follows:
appropriate Government, then, — ― Documentation check
a) employer or owner or agent or manager ― Interview with staff
referred to in section 67of such establishment ― Direct Observation
if it is mine; or Post the audit, the auditor would present the findings of the
b) employer or manager in relation to such audit by means of a report and also give a gist of it during
establishment if it is factory or relates to dock the closing meeting. The findings of the audit could be
work; or a) Negative: failings of managements system.

This would normally be present in the report
c) the employer of a plantation or an
in the form of non-conformities (NC), which
establishment relating to building or other
could comprise of more serious issues like
construction or any other establishment, non- compliance to legal requirements or not
shall send notice thereof to such authorities, in following the requirements of certain clauses of
such manner and within such time, as may be the standards.
prescribed by the appropriate Government

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b) Positive: Also, there could be ‘Observations’ Some common causes of product design liability are:
or ‘Opportunities for Improvements’. These concealed or non-obvious hazards, lack of appropriate
are not so serious issues and infact represent safety devices, inadequate structural design, failure to
‘conformity’ but can be complied with for a more consider foreseeable misuses, inadequate warnings/
robust management system. Observations also
instructions and failure to comply with relevant safety
highlight the positive aspects of the management
standards. Strategies for minimizing these defects
system, which needs to be celebrated and
shared widely across the organization for parallel include: incorporating guarding and interlocks, structural
deployment. Such observations provide for analysis and testing and comparison with safety standards
‘organizational learning’ and also gives assurance and applicable regulatory guidelines. An effective product
to the stakeholders that things are in control and safety audit can identify many potential hazards, increasing
that the organization is proactively managing customer satisfaction and reducing the likelihood of
health and safety. injuries and safety recalls.
Whether the findings are negative or positive, the audit as
2. Process audit
a process helps the organization to continually improve.
This type of audit verifies that processes are working
Difference between Audits and within established limits. It evaluates an operation or
Inspections: method against predetermined instructions or standards
to measure conformance to these standards and the
effectiveness of the instructions. A process audit may:
Audit Inspection
 Check conformance to defined requirements such as
 Examines documents  Checks the workplace time, accuracy, temperature, pressure, composition,
 Examines procedures  Checks records responsiveness, amperage, and component mixture.
 Interviews workers  Usually quick  Examine the resources (equipment, materials, people)
 Verifies standards  Lower cost applied to transform the inputs into outputs, the
 Checks the workplace  May only require basic environment, the methods (procedures, instructions)
 Can be a long process competence followed, and the measures collected to determine
 Usually expensive  May be Part of an audit process performance.

 Requires a high level of  Done by a team  Check the adequacy and effectiveness of the process
competence (Manager, Safety Adv. controls established by procedures, work instructions,
Worker Rep) flowcharts, and training and process specifications.
 Done by Trained Auditor
3. System audit
Types of audit: Product/Services, An audit conducted on a management system. It can be
Process, System described as a documented activity performed to verify,
1. Product/ Service Safety Audit: by examination and evaluation of objective evidence,
that applicable elements of the system are appropriate
This type of audit is an examination of a particular product
and effective and have been developed, documented,
or service, such as hardware, processed material or
and implemented in accordance and in conjunction with
software, to evaluate whether it conforms to requirements
specified requirements.
(i.e., specifications, performance standards, and customer
requirements). A safety management system audit evaluates an
existing safety management program to determine its
The goal of a product safety audit is to identify design
conformance to company policies, contract commitments,
defects, which comprise a high percentage of product
and regulatory requirements.
liability claims. Compliance with government or industry
voluntary standards constitutes design minimums and may Similarly, an environmental system audit examines an
not be sufficient to ensure a “reasonably safe” product. environmental management system, a food safety system
Furthermore, in addition to ascertaining the potential audit examines a food safety management system, and a
hazards of a product when used as intended, auditing quality system audits examine the quality management system.
should attempt to identify foreseeable misuses of a
product as well. In addition, auditing applies not only to
the product itself, but also to accompanying instructions
and warnings, though these should only be used when a
hazard cannot be eliminated or guarded against.

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Advantages and Disadvantages of Pre- audit Preparations:


External and Internal Audits

Advantages Disadvantages

External  Independent of any  Expensive.


audits internal influence.  Time-
 Fresh pair of eyes. consuming.
 Already has audit  May not
experience. understand
 May have wider the business
experience of and so make This happens before an audit starts, and the following
different types of impractical needs to be defined upfront.
workplace suggestions.
 The scope of audit- which will tell us what needs to be
 Recommendations  May intimidate audited
workers and so
often carry more  The area of the audit- the departments in which this 04
weight. get incomplete
audit needs to be conducted.
evidence.
 May be more up to  The extent of the audit- whether a comprehensive
date with the law audit, companywide or selective audit, covering a few
and best practice. departments.
 May be more able  Who will be required - auditors will require a wide
to be critical, e.g. of variety of personnel with whom they would require to
management. conduct interviews, also the auditors would require
Internal  Less expensive.  Auditors may
escorts who will accompany them in their visits to the
audits  Auditors already not notice
workplace.
familiar with the certain issues.
 Information gathering - Normally an auditor would
workplace and  Auditors may
ask for a wide variety of documents which they would
what is practicable not have good
study upfront so they can prepare for the audit.
for the industry. knowledge
of industry or Competency of the Auditor:
 Can see changes
since last audit. legal standards. An audit can be done by a
 Improves  Auditors may single person or a group
ownership of issues not possess of people, nevertheless
found. auditing skills the auditors need to be
so may need competent to conduct
 Builds competence
training. the audit. A competent
internally.
 Auditors auditor would be
 Workforce may be someone who has the
are not
more at ease. relevant certification, has
independent so
 Familiarity with experience of conducting
may be subject
workforce and similar audits and has good knowledge of the companies’
to internal
individuals. processes. The above competence is required for both
influence.
internal as well as external auditors.
The Audit Stages:
During the Audit:
The process of audits involves several stages. Though
An audit would begin on the designated day at the
there are different types of audits but most would follow
designated time with an opening meeting. At this meeting
the following typical process:
both the auditors and the auditees will be present and
after the customary introductions, the auditors would
announce the scope and extent of the audit and the
schedule for the audit which is agreed mutually.

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Depending upon the schedule the auditor would then visit selecting the people to carry out the audit employers
each department and conduct the audit. The auditor would should be sure that the auditor is sufficiently strong of
gather factual information by looking at the following mind to deal with these situations. It is important when
evidences: carrying out internal audits that the auditor is impartial; this
will usually mean that the auditor does not audit a function
 Paperwork or
of the organisation that they have responsibility for.
documentation – the records
would indicate how well Time and Resources
the HSMS is working in the
Audits are an in-depth analysis of compliance with
organization. It would also
standards and must not be treated lightly. The planning
indicate to potential gaps.
of the audit alone can be very time consuming. Evidence
 Typically, an auditor may look gathering and verification can also take a long time,
at the following documents depending on the scope of the audit. Employers should
to gain evidence of conformity. not apply pressure on the auditor to get the job done in
– Health and safety policy. less time than is appropriate and must be prepared to
– Risk assessments and safe systems of work. allocate sufficient time to the task.

– Training records. Similarly, the auditor might need other resources than time,
such as access to documentation, measuring equipment,
– Minutes of safety committee meetings.
electronic storage facilities, and research facilities (internet,
– Maintenance records and details of failures. library, etc.) in order to do a thorough job.
– Active monitoring records.
– Reactive monitoring records. End of the Audit:
– Emergency arrangements and mock drill records. The audit would come to an end with a closing meeting
and the participants would generally be the same as that
– Inspection reports by insurance agencies.
of the opening meeting.
– Outputs of regulator visits.
The auditors will give a verbal feedback as to what their
– Records of any worker complaints.
main observations were and give a list of the improvements
 Interviews: An auditor would interview the workers required. The auditors would then follow up their verbal
and managers of each department audited to report with a written audit report which will in detail
understand how well the policies of the organization are speak about the recommendations for improvements and
understood at each level and whether they know their the timescales with priorities. An audit report may list a
roles and responsibilities towards health and safety. number of findings as follows.
 Observation: An auditor would take a round of the  Major non-conformance: These are significant issues
department audited and observe the behaviour of the which needs immediate attention. It would generally
workers and also to verify the correct implementation point out to legal issues or major failures in the HSMS
of the SSOWs. in avoiding accidents. In ISO terms, these would
mean denial of certification or even withdrawal of an
Selection of Staff already awarded certificate.
 Minor non- conformance: These are issues which are
less serious and would generally do not point to any
major weaknesses in the HSMS. These would require
corrective action to be taken in a set period of time.
They would not cause a failure in the system.
 Observations: Auditors may put forward their
opinions on certain issues pertaining to the HSMS.
These may or may not be implemented by the
organization.

If audits are to be carried out internally, organisations


should be mindful of the fact that, very often, the results
of the audit may appear to be critical of the organisations
and/or individual performance. This can lead to feelings of
resentment or even violence towards the auditor. When

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4.4 Review of Health and What the review should consider:


Safety Performance A wide variety of issues may be considered during the
review:
Why Health and Safety Performance
 Pending actions from previous reviews:
should be Reviewed The previous reviews would have a range of
recommendations which would have been converted
into action plans. Whether the targets set in the
action plan is achieved or not can also be reviewed.
 Legal compliance: Any legal compliance still pending
to be achieved should be reviewed and regularly
followed up for closure.
 Findings of active monitoring: The findings of safety
inspections/ surveys/ tours and sampling will feed into
the review which help the organization understand its
compliance with the set standards. 04
 Reactive monitoring data such as:
Following are the main purposes of Health and Safety
– Accident and incident data: This is a major
Performance review:
performance indicator for the organization
 Determine cause to prevent recurrence and would always form part of set targets.
 Identify weaknesses in management systems The number of incidents within the period of
discussion would be taken up and ascertained
 Identify weaknesses in risk assessment
whether it is within the set limits and whether
 Demonstrate management commitment the trends are encouraging or otherwise.
 Comply with country’s legal requirements – Absence and sickness data: This would help in
 Collect data to establish losses understanding whether the sickness is because
 Provide information for Civil/Criminal actions of occupational related diseases or otherwise.
 Provide information to insurance company Absence caused by workplace related stress
could also be reviewed.
 To meet the requirements of shareholders and
stakeholders  Quality assurance reports: In this the company’s
rejection and rework rates could be discussed
By ensuring that a cycle of continuous review takes place
and even the customer complaints. This helps the
at all levels at desired frequencies, the following purposes
company perform the role in the supply chain.
are achieved:
 Audit reports: Both internal and external audit
 The management keeps on continuously measuring reports will be discussed and major, minor non
its performance. conformities whether closed or yet to be closed
 It constantly updates their performance by comparing will be reviewed. Any worthwhile suggestions by
the set targets vs the achieved. the auditors can also be taken up and decided on
 It helps the management know whether enough is implementation.
been done to achieve the targets or more needs to be  Monitoring data/ records/ reports: Various
done. survey reports could be presented. For e.g. if dust
 It helps the management meet the commitments is considered to be problem for the organization,
set towards both their internal and external stake then the dust survey results could be presented and
holders. discussed.
 It demonstrates commitment of the management  External communications and complaints: Issues
towards continual improvement and thus boosts raised by the enforcement agencies or people living in
morale of the workmen and aid in the creation of the vicinity could be discussed.
positive health and safety culture.  Consultation: Issues discussed in the safety
committee meeting can be summarized.
 Objectives met: A wide range of objectives set at

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the planning stage can be discussed. Objectives could


be checked for achievement or the gaps could be
discussed and further course of action decided to
achieve the same within the set period.
 Legal and best practice developments: New
national and international laws may have been passed
and could require organizations to implement them
within the set time frame. These could be reviewed
and plans to implement them could be frozen during
the review.

Reporting on Health and Safety


Performance:
Review results on health and safety performance should
be communicated to the senior management level. This is
especially useful to enable all of senior management to

 Understand the existing workplace scenario and


necessary initiatives to be taken
 Determine whether the health and safety
management system elements are in place and
operating effectively across the organisation
In addition, results of the review should also be
communicated widely in the organization and especially
for those having responsibility to respond.

Feeding review outputs into action


and development plans as part of
continuous improvement:
The results of the discussion during the review meeting
are recorded in the minutes of minutes. These minutes
should feed into creating action plans which will help the
organization to achieve the decisions made.

The minutes as well as the action plan, needs to be


cascaded down the line to the line managers level and may
even be discussed in the safety committee meeting, so that
everyone is aware of the management’s commitments.
The minutes will help different levels as follows:

 Top management to set new targets and aid in


continual improvement.
 Middle management to review their own
performance and set enhanced targets at their levels.
 Line management to review their performance
and further cascade down the targets to the
workers level.

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Summary
 Positive health and safety culture of the organization can be achieved by proper monitoring of the health and safety
management system
 In general, health and safety performance of the organisation is monitored by two methods. They are
– Active (Proactive monitoring)
– Reactive monitoring
 Active (Proactive) monitoring – Evaluating health and safety standards before the occurrence of unwanted event. It
includes
– Safety inspections
– Safety tour
– Safety sampling
 Active monitoring gathers information in the following ways
– Documentation – Examine records, reports and documents
– Interview – Communicate with people to get views and opinions
04
– Observation – Watching people’s behaviour
 The following are some of the examples to derive standard of performance in an organisation
– Check health and safety training imparted to the workers as per the training calendar
– Monitor housekeeping activities in different zones again a set checklist
– Ensure safety inspections are happening as per the schedule
– Make sure workers are undergoing medical surveillance regularly
 Methods of active monitoring

– Safety Inspection
 It is a regular and scheduled activity that is carried out in comparison with accepted performance standards
 It involves straightforward observation of a workplace, activities, and equipment to identify hazards
 It is usually carried out by a manager, employee representative and Safety Advisor
 Types of safety inspections
Routine inspection Determines if general standards of health and safety are acceptable or if corrective
action is necessary
Statutory inspection Performed by a competent person to fulfill a legal requirement
Periodic Inspection This is to ensure that the plant and machinery are maintained properly
Pre-use-checks To ensure the equipment or system is in good condition and safe to operate before
operation

 Systematic inspections focus on four Ps for active monitoring of health and safety performance.
Types of P’s Areas to be inspected
Plant Work equipment, machinery and vehicles
Premises Workplace and its environment
People People’s working method and behaviour
Procedures Safe system of work, permit to work
 Allocating specific responsibility is essential for each type of inspection. This should be based on the relevancy and
competency of the individuals E.g: Pre-use inspection is done by the operators themselves, while monitoring the
behaviour of the workers is done by supervisors
 The person carrying out an inspection should have the necessary
– Relevant training, knowledge and experience
– Certification to a specific standard

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– Understanding of the workplace


– Health & Safety principles
– Willingness to ask questions
 Frequency of inspection is mainly determined by the nature of the work and level of risk. For example
– Frequent inspection is needed in case of work involving higher risks like scaffolding, forklift operation, and rigging
and dogging
– Inspection can be carried out once in a month or year for work involving lower risk like office-based environments
 The following factors should be taken into account while determining the frequency of inspection
– Level of risks in the activity.
– Manufacturers’ recommendations.
– Companies’ own internal policy.
– In some cases the countries laws may determine the frequency
– Inspection and audit findings may suggest a higher frequency.
– Previous accident history and results of investigations.
– Complaints from workers.
– Risk assessments may suggest inspections
 Checklist is a valuable tool to check the whether the inspection is covered in all aspects. It becomes a record for future
reference when it is filled.
 Checklist has some limitations like ignoring of other issues that are not included in it
 Appropriate action plan must be implemented for the issues identified during the inspection. It has to clearly define the
following
– Corrective action required
– Information of persons who executes the action plans
– Priorities/timescales
 Methods of active monitoring (Contd.)
– Safety Sampling
 It is a technique which uses list of standards or regulations to monitor whole workplace compliance by exam-
ining at a representative sample E.g: Effectiveness of 100 fire extinguishers can be analysed by examining and
testing the 2 fire extinguishers.
– Safety Tours
 It is a type of inspection which involves walking around the workplace to examine work environment, safety
practices and worker’s behaviour.
 It is usually carried by a group which includes worker representative, safety specialists, managers, and compe-
tent persons.
 Its main purpose is to reveal management’s commitment to health and safety.
 Reactive monitoring – This is done to learn from past incidences and prevent it from happening in the future.
(Reacting after things have gone wrong). It usually refers the following things to measure the health and safety
performance
– Accident data
– Ill health data
– Absenteeism data
– Claims records
– Number of complaints reported
– Prosecutions
– Enforcement notices

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 Analysing the database of reported accidents and incidents helps to identify trends in WSH and identify hotspot areas
(particularly those with high accident records) for enhancing the overall safety of the organisation
 Accident incidence rate (AIR) is used to compare organisation’s safety performance against a pre-defined standard.
Following is the formula
AIR = (Number of accidents in the given period / the average number of people in the given period) x 1000.
 Generally accepted near misses greatly outnumber accidents and can therefore produce more data from which a
greater understanding of the deficiencies in management systems can be identified and rectified
 Total number of enforcement actions and civil claims are also constitutes for measuring the safety performance of the
organisation.
 The investigation and analysis of work-related accidents and incidents forms an essential part of managing health and
safety
 When an incident happens, it is important on the part of the organization to record it correctly and investigate it to
avoid a recurrence
 Lessons need to be learnt from beneficial and adverse events because of the following reasons
– The Lessons learned from both beneficial and adverse events is the learning gained from the process that is
04
applied.
– Each failure or success needs to be analysed, so that what has been done correctly and what has been not is known
to the organization.
– Beneficial events will give the confidence to the management to replicate the processes that lead to such benefits
all throughout the organization.
– Similarly, adverse events are something which needs to be investigated and the root causes needs to be evaluated.
The learning’s from such events and the ways to prevent it should be communicated across the organization so
that it does not repeat again.

 Leading and lagging indicators


– Leading indicator is proactive in nature. They include safety initiatives or reported activities, with the goal of
preventing unfavourable events before they happen.
– Lagging indicators are measurements that include data from the past. They include incidents and accidents
statistics.

 Role and function of investigation


– It is a reactive monitoring technique and hence presents the organization with valuable data for analysis (trends).
– A proper investigation helps us understand why the incident happened and what could be done to prevent it in the
future.
– It plays a major role to process a claim from the insurance agency
– Incident investigation helps in calculating the costs of accidents

 Levels of Investigations (With reference to HSG245)


– Minimal
– Low
– Medium
– High

 The following are the basic steps that can be followed for carrying out an effective accident investigation:
– Gathering the information - Information can be gathered by the following three things
 Observation
 Interviews
 Documentation
– Analyzing the information. – Gathered information needs to be analyzed to find out the causes of the incident.

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The causes of the incident are commonly divided into


 Immediate causes – Acts or condition that leads to a particular result or event
 Underlying causes – Acts or condition that leads to the development of immediate causes
 Root causes – Initiates a condition or acts that leads to dangerous outcomes
– Identifying risk control measures
 Control measures need to be identified to remedy the situation. These measures should take care of both the
immediate and root causes
– Action plan and its implementation
 Remedial actions should be both corrective and preventive and they need to be recorded in a systematic way
so as to make the plan actionable
 When an incident happens it needs to be recorded and reported. An incident would require to be reported both
− Internally within the organization and
− Externally to agencies.
 Internal incident reporting - An organization through its incident reporting policy should put systems in place for
incidents to be recorded and reported internally. A typical internal incident report would contain the following:
− Name and address of the casualty
− Date and time of the incident
− Location of the accident
− Details of the injury
− Details of the treatment given
 Reporting of incidents to external agencies - Depending upon the type of incident, certain incidents needs to be
notified to the external agencies like enforcement agencies. Some examples of incidents that need to be reported
− Accidents that have resulted in major injuries or “Loss time injuries’’.
− Dangerous occurrences as notified in the law.
− Occupational diseases.
 Some of the barriers of incident reporting includes
− No reporting policy in place.
− A work culture of not reporting.
− Workers not aware that reporting of incidents is part of their roles and responsibilities.
− Filling of the forms are too hard or takes too long.
− There is peer pressure that prevents reporting.
 The following are the personnel and agencies who would be notified about the incident:
Internal Incident Reporting External Incident Reporting
Top Management Enforcement agencies
HR and personnel department Insurance companies
Health and safety specialist Public relations advisors
Workers representative To the family of the casualty

 Each incident report as well as a set of incident reports will present to the management of an organization with
invaluable data which will help them in its analysis and help them in managing the prevention of incidents even better
 Finally all these reporting, recording and analysis of the incidents should culminate into lesson learnt, which can then
translate into awareness amongst the workers and overall health and safety improvement.
 ISO 45001 defines audit as “a systematic, independent and documented process for obtaining audit evidence and evaluating
it objectively to determine the extent to which the audit criteria are fulfilled.”
 The scope and purpose of the audit is to verify that
− Organization has an appropriate health and safety management system

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− Whether the implementation is done correctly with appropriate risk controls in place.
− Results obtained through implementation of the system matches with the goals set by the organization
 Health and Safety Management Systems should be audited because of the following reasons
Negative: Identifies the failings of management system. This would be non-conformities (NC), non- compliance to
legal requirements and not following the requirements of certain clauses of the standards.

Positive: Highlights the positive aspects of the management system and provides assurance to the stakeholders
that things are in control and that the organization is proactively managing health and safety.

 Difference between audit and inspection


− Audits are usually performed to check the effectiveness of health and safety management system like safety
policies, arrangements, procedures, and safe systems of work
− Inspections are carried to determine the hazards and risks associated with the particular type of work
 Types of Audit
– Product/ Service Safety Audit:
This type of audit is an examination of a particular product or service, such as hardware, processed material or
software, to evaluate whether it conforms to requirements (i.e., specifications, performance standards, and
04
customer requirements).

– Process audit
This type of audit verifies that processes are working within established limits. It evaluates an operation or method
against predetermined instructions or standards to measure conformance to these standards and the effectiveness
of the instructions.

– System audit
An audit conducted on a management system. It can be described as a documented activity performed to verify,
by examination and evaluation of objective evidence, that applicable elements of the system are appropriate
and effective and have been developed, documented, and implemented in accordance and in conjunction with
specified requirements

 Before commencement of the audit process, the following things should be ensured.
The scope of audit  It should specify what needs to be audited. It may be company policy, health and safety
policy and so on
The area of the audit  Information about the departments or sites needs to be audited
The extent of the  Whether a comprehensive audit, companywide or selective audit, covering a few
audit departments
Who will be required  Auditors will require a wide variety of personnel with whom they would require to conduct
interviews
Information  Normally an auditor would ask for a wide variety of documents which they would study
gathering upfront so they can prepare for the audit

 Competency of the Auditor


− Auditors need to be competent to conduct the audit. He/she must be familiar with audit techniques, familiar
with work practices, have the ability to interpret standards and be in a position to be able to keep up to date
with new information and standard
− When selecting the people to carry out the audit, employers should be sure that the auditor is sufficiently
strong of mind to deal with any kind of situations
 During the audit, the auditor would gather factual information by looking at the following evidences

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Paperwork or documentation  Records would indicate how well the HSMS is working in the organization.
Typical record includes
– Health and safety policy
– Risk assessments and safe systems of work
– Training records
– Minutes of safety committee meetings
– Maintenance records and details of failures
– Active monitoring records
– Reactive monitoring records
Interviews  Interact with workers and managers to ensure how the policies of the
organization are understood and implemented
Observation  Observe behavior of workers and system of work to identify and analyse
problematic safety and other issues
 An audit report may list a number of findings as follows.
Major non-conformance  These are significant issues which needs immediate attention
Minor non- conformance  These are issues which are less serious
Observations  Auditors may put forward their opinions on certain issues pertaining to the
HSMS

 It is the responsibility of the organisation to implement all the recommendations and corrective actions recommended
in the health and safety audits
 Depending upon the audit report, the management team needs to come out with an action plan by assigning
responsibilities and approving resources to achieve them in the desired time.
 Monitor and analyse of activities related to organization’s operations like business structure, employee behavior is
called internal audit. It is normally carried out by competent person of the organization.
 Advantages and disadvantages of internal audits
Advantages Disadvantages
 Less expensive. Auditors are not independent so may be subject to internal influence
 Auditors already familiar with the Auditors may not notice certain issues
workplace and its processes and
operations

 Organization’s performance standards and health and safety policy is audited by third party is called external audit
 Advantages and disadvantages of external audits
Advantages Disadvantages
 No internal influence  Expensive
 Have wider experience auditing different  Time-consuming
types of workplace

 The purpose of reviewing health and safety performance to:


– Determine cause to prevent recurrence
– Identify weaknesses in management systems
– Identify weaknesses in risk assessment
– Demonstrate management commitment
– Comply with country’s legal requirements
– Collect data to establish losses
– Provide information for Civil/Criminal actions

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– Provide information to insurance company


 A wide variety of issues may be considered during the review
– Actions from previous reviews
– Legal compliance
– Findings of active monitoring
– Reactive monitoring data such as Accident data. Absence and sickness data etc
– Quality assurance reports
– Audit reports
– Monitoring data/ records/ reports
– External communications and complaints
– Consultation
– Objectives met
– Legal and best practice developments
 Review results of the health and safety performance should be informed to the senior management for necessary
04
actions, processes and controls to be put into place
 The results of the discussion during the review meeting are recorded in the minutes of minutes. These minutes will
help different levels as follows:
– Top management to set new targets and aid in continual improvement.
– Middle management to review their own performance and set enhanced targets at their levels.
– Line management to review their performance and further cascade down the targets to the workers level.

© NIST INSTITUTE PRIVATE LIMITED NIST/TSD/LD/IG/Version 1/2020

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