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HEALTH & SAFETY MANAGEMENT

SAFETY MANAGEMENT SYSTEM (SMS)

HAZARD IDENTIFICATION RISK ASSESSMENT CONTROL MEASURES

Prepared by Isaac Mintah – Professor page 1 of 122


PUBLISHED BY

ROYAL MINTAH INVESTMENT LTD


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Copyright © 2016

ALL Copyright Reserved.


No part of this publication may be paraphrased or reproduced in
any form, or by any means, for financial and other gains without
prior consultation with, and approval of, the author.
Piracy is punishable under the copyright laws of Ghana.
Beware!

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DEDICATION

To my Lovely mother Madam Elizabeth Amponsah and to my


respective family and friends
Ato Essel Amuaful

Nelson Agyapong

Emmanuel Boateng

Eva Naana Odei

Mary Amponsah

Mark Tengeh

Collins Kenyah

Issifu Akurugu

Also to all the Management of G4S Ghana Limited.

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TABLE OF CONTENTS
1 Who is this booklet for?...........................................................................................................5

2 What does the booklet aim to do?...........................................................................................5

3 Hazard identification, risk assessment and control measures introduction.............................5

4 Hazard identification................................................................................................................6
4.1 The importance of getting the hazard identification right..........................................6
4.2 Features of HAZID....................................................................................................8
4.3 Hazard identification processes and techniques.......................................................12
4.4 Review, revision and typical problems....................................................................27

5 Risk assessment.....................................................................................................................24
5.1 Risk assessment aims...............................................................................................24
5.2 Examples of risk assessment methods................................................................................34

6 Control measures...................................................................................................................46
6.1 Introduction..............................................................................................................46
6.2 What is a control measure?......................................................................................46
6.3 Understanding control measures..............................................................................48
6.4 Selecting and rejecting control measures.................................................................54
6.5 Additional or alternative control measures..............................................................56
6.6 Defining performance indicators for control measures............................................58
6.7 Critical operating parameters...................................................................................62
6.8 Involving employees in control measures................................................................63
6.9 Control measures within the safety report and SMS................................................64
6.10 Reviewing and revising control measures................................................................65
6.11 SMS - A suggested combination of key elements...................................................66
7 Health & Safety Abbreviations and Meanings,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 71

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1. Who is this booklet for?
This booklet has been produced for employers in control of a facility that
has been classified by Compare as a major hazard facility under the
Occupational Health and Safety (Safety Standards) Regulations 1994.

2. What does the booklet aim to do?


This booklet provides guidance on key principles and issues to be taken
into account when conducting an effective hazard identification and risk
assessment at a major hazard facility (MHF) that is subject to
Commonwealth legislation. It also describes the type and nature of
control measures that the employer in control of an MHF should
consider. These processes should be consistent with the safety
management system.
This booklet is a guide to the intent of the Regulations but employers in
control of an MHF should refer to the Regulations for specific
requirements. In addition, this booklet refers to hazard identification and
risk assessment techniques that may be appropriate for MHF purposes
but these may not be the only techniques in use at a facility, other
techniques include job safety analysis and task analysis.

3 Hazard identification, risk assessment and


control measures introduction
Hazard identification (HAZID) and risk assessment involves a critical
sequence of information gathering and the application of a decision-
making process. These assist in discovering what could possibly cause a
major accident (hazard identification), how likely it is that a major
accident would occur and the potential consequences (risk assessment)
and what options there are for preventing and mitigating a major accident
(control measures). These activities should also assist in improving
operations and productivity and reduce the occurrence of incidents and
near misses.
There are many different techniques for carrying out hazard
identification and risk assessment at an MHF. The techniques vary in
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complexity and should match the circumstances of the MHF.
Collaboration between

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management and staff is fundamental to achieving effective and efficient
hazard identification and risk assessment processes.

4 Hazard identification
The Regulations require the employer, in consultation with employees, to
identify:
a) all reasonably foreseeable hazards at the MHF that may cause a
major accident; and
b) The kinds of major accidents that may occur at the MHF, the
likelihood of a major accident occurring and the likely consequences
of a major accident.

4.1 The importance of getting the hazard identification


right
Major accidents by their nature are rare events, which may be beyond the
experience of many employers. These accidents tend to be low
frequency, high consequence events as illustrated in Figure 1 below.
However, the circumstances or conditions that could lead to a major
accident may already be present, and the risks of such incidents should be
proactively identified and managed.

Figure 1: HAZID focus on rare events

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HAZID must address potentially rare events and situations to ensure the
full range of major accidents and their causes. To achieve this,
employers should:
a) identify and challenge assumptions and existing norms of design and
operation to test whether they may contain weaknesses;
b) think beyond the immediate experience at the specific MHF;
c) recognise that existing controls and procedures cannot always be
guaranteed to work as expected; and
d) learn lessons from similar organisations and businesses.
Some significant challenges in carrying out an effective HAZID are:
a) substantial time is needed to identify all hazards and potential major
accidents and to understand the complex circumstances that typify
major accidents;
b) the need for a combination of expertise in HAZID techniques,
knowledge of the facility and systematic tools;
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c) the possibility that a combination of different HAZID techniques
may be needed, depending on the nature of the facility to ensure that
the full range of factors (e.g. human and engineering) is properly
considered;
d) obtaining information on HAZID from a range of sources and
opinions; and
e) ensuring objectivity during the HAZID process.
Authority must be satisfied that hazard identification has been
comprehensive and the risks are eliminated or controlled before granting
a licence or certificate of compliance to operate an MHF.

4.2 Features of HAZID


Compare’s expectations and some important features
of HAZID
Compare will expect:
a) a clear method statement or description of the HAZID process,
defining when it was conducted, how it was planned and prepared,
who was involved and what tools and resources were employed;
b) that the HAZID process was based on a comprehensive and accurate
description of the facility, including all necessary diagrams, process
information, existing conditions and modifications; and
c) That the overall HAZID process did not rely solely on data that was
historical or reactive and that employers ensured that predictive
methods were also used.
The HAZID process must identify hazards that could cause a potential
major accident for the full range of operational modes, including normal
operations, start-up, and shutdown, and also potential upset, emergency
or abnormal conditions. Employers should also reassess their HAZID
whenever a significant change in operations has occurred or a new
substance has been introduced. They should also consider incidents,
which have occurred elsewhere at similar facilities including within the
same industry and in other industries. Refer to the guidance material for

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Safety Report and Report Outline guidance material for the definition of
significant change.
Involving the right people
An effective HAZID process is dependent upon having the right people
participating in the process. The employer should:
a) involve Health and Safety Representatives (HSRs) in selecting staff
to participate in HAZID;
b) involve HSRs in determining if the HAZID techniques are suitable
for the staff selected;
c) ensure participants understand the relevant HAZID methods so that
they can fully participate in the process; and
d) be alert for hazards that can be revealed by the combination of
knowledge from specialists in different work groups.
Features of a HAZID process
The following aims to demonstrate the main features of a HAZID.
Although the HAZID process chosen by employers must suit the
circumstances of the MHF, the features noted below are generally
applicable to all processes.
Preparation: Prior to commencement of the HAZID, the following steps
should be completed:
a) Agreement on the purpose and scope of the HAZID;
b) Appropriate personnel and HAZID tools identified;
c) Sufficient resources and time allocated;
d) Clearly defined reporting processes and study boundaries according
to the purpose and scope;
e) Appropriate background information and studies collated, such as
historical incident data;
f) An agreed interpretation of ‘major accident’ that is consistent with
the Regulations and relevant to the facility.

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System description: At the commencement of the HAZID, the complete
system of assets, materials, human activities and process operations
within the boundaries of the study should be clearly defined and
understood, taking account of the original design, subsequent changes
and current conditions. Typically, the system should be divided into
distinct separate components or sections to enable manageable quantities
of information to be handled at each stage.
Systematic evaluation and recording: The HAZID should move
progressively through the system, applying the HAZID tools to each
component or section in turn. All identified hazards and incidents should
be recorded in some way. (See Figure 16 in this booklet for some
examples of how hazard registers may be configured.) A checklist of
guidewords, questions or issues should be considered at each stage.
Some key questions and issues could be:
a) What is the design intent, what are the broad ranges of activities to
be conducted, what is the condition of equipment, and what
limitations apply to activities and operations?
b) What are the critical operating parameters? What process operations
occur, and how could they deviate from the design intent or critical
operating parameters? This should consider routine and abnormal
operations, start-up, shutdown and process upsets.
c) What materials are present? Are they a potential source of major
accidents in their own right? Could they cause an accident involving
another material? Could two or more materials interact with each
other to create additional hazards?
d) What operations, construction or maintenance activities occur that
could cause or contribute towards hazards or accidents? How could
these activities go wrong? Could other hazardous activities be
introduced into this section by error or by work in neighbouring
sections of the facility?
e) Could other materials, not normally or not intended to be present, be
introduced into the process?

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f) What equipment within the section could fail or be impacted by
internal or external hazardous events? What are the possible events?
g) What could happen in this section to create additional hazards, e.g.
temporary storage or road tankers?
h) Could a particular section of the facility interact with other sections
(e.g. adjacent equipment, an upstream or downstream process, or
something sharing a service) in such a way as to cause an accident?
Past, present and future hazards
To identify all hazards, the HAZID will need to consider past, present
and future conditions, hazards and potential incidents. Past incidents, at
the MHF or similar facilities, provide an indication of what has gone
wrong in the past and what could go wrong in the future.
A wide range of hazards and potential incidents will be present in the
facility. New hazards and incidents could be created in the future as a
result of planned or unplanned changes. The management of change
process described in the SMS should identify new conditions during the
planning of modifications or new activities. This should then trigger
further HAZID studies and risk assessments, with the identification of
control measures as appropriate. Figure 2 below illustrates the range of
tools that can be used to identify past, present and future hazards.
Figure 2: Past, present and future hazards

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4.3 Hazard identification processes and techniques
HAZID techniques

The flowchart below summarises all the steps needed in a HAZID
process and how those steps relate to one another.
Figure 3: HAZID process

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Examples of HAZID Techniques
HAZOP
Hazard and Operability Study (HAZOP) is a highly structured and
detailed technique, developed primarily for application to chemical
process systems. A HAZOP can generate a comprehensive understanding
of the possible ‘deviations from design intent’ that may occur. However,
HAZOP is less suitable for identification of hazards not related to
process operations, such as mechanical integrity failures, procedural
errors, or external events. HAZOP also tends to identify hazards specific
to the section being assessed, while hazards related to the interactions
between different sections may not be identified. Therefore, HAZOP may
need to be combined with other hazard identification methods, or a
modified form of HAZOP used, to overcome these limitations.
Equipment failure case definition
This method is a systematic approach to defining loss of containment
events for all equipment within the study boundary. Process flow and
equipment diagrams are studied systematically, and all equipment is
assigned appropriate loss of containment scenarios, such as pinhole leaks,
according to design, construction and operation. This form of hazard
identification may be necessary for many major hazard facilities, to avoid
missing potential scenarios, but is not sufficient on its own because it
does not consider specific causes or circumstances. Therefore, this
technique should only be used in combination with other techniques for
MHF purposes.
Checklists
There are many established hazard checklists which can be used to guide
the identification of hazards. Checklists offer straightforward and
effective ways of ensuring that basic types of events are considered.
Checklists may not be sufficient on their own, as they may not cover all
types of hazards, particularly facility-specific hazards, and could also
suppress lateral thinking. Again, this technique should only be used in
combination with other techniques for MHF purposes.

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What-If Techniques
This is typically a combination of the above techniques, often using a
prepared set of ‘what-if’ questions on potential deviations and upsets in
the facility. This approach is broader but less detailed than HAZOP.
Brainstorming
Brainstorming is typically an unstructured or partially structured group
process, which can be effective at identifying obscure hazards that may
be overlooked by the more systematic methods.
Task Analysis
This is a technique developed to address human factors, procedural errors
and ‘man-machine interface’ issues. This type of hazard identification is
useful for identifying potential problems relating to procedural failures,
human resources, human errors, fault recognition, alarm response, etc.
Task Analysis can be applied to specific jobs such as lifting operations,
moving equipment off-line or to specific working environments such as
control rooms. Task Analysis is particularly useful for looking at areas of
a facility where there is a low fault-tolerance, or where human error can
easily take a plant out of its safe operating envelope.
Failure Modes Effects Analysis (FMEA)
FMEA is a process for hazard identification where all conceivable failure
modes of components or features of a system are considered in turn and
undesired outcomes are analysed. This technique is quite specialised and
may require expert assistance.
Failure Modes Effects and Criticality Analysis (FMECA)
FMECA is a highly structured technique that is usually applied to a
complex item of mechanical or electrical equipment. The overall system
is described as a set of sub-systems and each of these as a set of smaller
sub-systems down to component level. Individual system, sub-system
and component failures are systematically analysed to identify their
causes (which are failures at the next lower-level system), and to
determine their possible outcomes, which are potential causes of failure
in the next higher-
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level system. This technique is quite specialised and usually requires
expert assistance.
Fault Tree and Event Tree Analysis
Fault Trees describe loss of containment events in terms of the
combinations of underlying failures that can cause them, such as a
control system upset combined with failure of alarm or shutdown and
relief systems. Event trees describe the possible outcomes of a hazardous
event, in terms of the failure or success of control measures such as
isolation and fire-fighting systems. Fault tree and event tree analysis is
time-consuming, and it may not be practicable to use these methods for
more than a small number of incidents.
Historical records of incidents
Databases of incidents and near misses that have occurred are a useful
reference because they give a very clear indication of how incidents can
occur. Employers should consider site history, company history, and
industry history and possibly even wider sources of historical
information for this purpose.
Examples of major accidents and the role of multiple factors in
those accidents
Texas City, USA, 2005. An explosion at a large refinery killed 15
workers and injured over 170 others. Equipment upgrades and SMS
elements including process safety information, communications and
training were targeted for improvements following the incident. Total
cost of plant upgrade reported to be 1 billion dollars over 5 years.
Longford, Victoria, 1998. Two workers were killed and eight others
injured in an explosion at a gas processing plant. As a result, many
elements of the SMS were targeted for improvements including process
safety information and communication of critical safety information.
Pasadena, USA, 1989. A fire and a series of explosions at a refinery
complex resulted in 23 fatalities. Inadequate and unofficial isolation
procedures, together with human error induced by poor ergonomics
played
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a role in causing the accident. The loss of life and scale of damage were
increased due to poor plant layout and subsequent damage to fire-fighting
systems.
Piper Alpha, UK, 1988. The accident was triggered by a small leak in a
condensate pump system, which by itself would most likely have had
only minor consequences. However, in combination with failures in
management systems, design and equipment, the event resulted in the
loss of 167 lives and destruction of the entire platform.
Bhopal, India, 1984. Half a million people were exposed and over
20,000 have died to date as a result of a release of methyl-isocyanate via
a vent stack. A range of systems and equipment had been malfunctioning
or were taken out of service over a period leading up to the disaster,
including a safety system for scrubbing tank vent releases, but this was
disabled because the plant was shut down and not considered to be a risk.
After the plant’s construction, a large ‘shanty town’ had grown up around
it, but this had not led to any recognition of changes in risk.
Flixborough, UK, 1974. A modification was made to a bypass for one
of a series of reactor vessels. Due to the urgency of the work, and the
fact that there had been significant organisational change, the
modification was designed and constructed inadequately. The bypass
failed, releasing a large cloud of cyclohexane, which exploded and killed
28 persons. Not only was the new hazard not considered during the
modification, it was not recognised during subsequent operations even
though the bypass was seen to move as process pressure rose and fell.

Human factors and the nature of hazards – an overview


Human factors are defined as the interactions between people and the
organisation, systems and equipment they interface with. Consideration
of the effect of human factors on risk is sometimes defined as ‘fitting the
work to the employees’ or ‘the science and practice of designing systems
to fit people’. The subject of human factors is concerned with
understanding the capacities and limitations of people in their jobs, and
using this understanding to eliminate or control the effects of human
weaknesses and exploit human strengths. In this context, human
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weaknesses may include limitations on information processing
capabilities, while human strengths may include adaptability.
Some facilities may find that human factors are a major contributor to the
nature of hazards at the facility. It is expected that in this case there will
be thorough evaluation of the causes of this. Analysis of human errors
may require procedural reviews or human factors analysis.

From the major hazard control perspective, the role of people is critical to
the safe operation of major hazard facilities and should be addressed in
the safety report. Accordingly, employers should incorporate human
factors into relevant aspects of the operation of major hazard facilities,
including the SMS, hazard identification, risk assessment, control
measures, the safety role of employees and contractors, emergency
planning and training.
Human factor HAZID techniques
When identifying human factor hazards, the employer should examine
the foreseeable major accidents and consider how human factors may
contribute to or cause those accidents. It is important employees with
experience in the specific area being studied participate to identify the
hazards that may be present.
This should involve identifying the ways in which ‘just being human’ can
influence the performance of individual tasks and roles. For example, a
person may operate a wrong valve by mistake, or may inadvertently use
the incorrect procedure. Examples of ‘being human’ include: memory
limitations, visual acuity limitations, information processing problems,
distraction, fatigue, decision-making biased by experience and
knowledge, rigid problem solving, susceptibility to following group
behaviour. These can all adversely influence human actions and
decisions leading to the possible creation of hazards.
It is important to acknowledge that human factors can introduce hazards
at all levels, from performing individual operations and maintenance
tasks, through to designing the facilities, writing the procedures and even
setting standards and policy for the organisation. Human factor hazards
can also be latent hazards, in that they will not be revealed until

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particular

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circumstances combine to make them obvious. For example, the transfer
of a key operational supervisor into a non-operational project role may
lead to a deficiency of knowledge within the operations team; this
deficiency may not become apparent until an emergency occurs.
Accordingly, while it is necessary to involve first-line operations and
maintenance personnel in the hazard identification, it is also necessary to
consider wider issues than the day-to-day roles and activities of these
persons.
When considering the type and level of human factors input that is
needed in hazard identification, employers should consider their specific
circumstances, and in particular, the amount of reliance they place on
human actions and decisions in the prevention and control of major
accidents. Cases where detailed consideration of human factors might be
appropriate include a process plant that requires employee action to
prevent or control emergency situations or a dangerous goods warehouse
that relies heavily on procedural controls to ensure correct segregation of
goods.
In addition to calling upon the necessary range of operations personnel to
take part in the hazard identification, it may also be appropriate to use
persons having specialist human factors knowledge. This specialist
knowledge may be essential if human factors hazards can influence
critical safety controls.
Human factor HAZID techniques are evolving and are based on methods
developed from engineering HAZID methods. They follow the same
principles and can be conducted in conjunction with an engineering
HAZID.
Task analysis
An important set of human factors techniques, which can be used in all
areas of human factors consideration, is a set of methods collectively
called ‘task analyses. Task analysis is not only used in HAZID but is
also a tool for risk assessment and development of control measures to
accommodate human factors.
Task analysis is used to study what a person, or team, is required to do, in
terms of actions and/or mental processes to achieve a system goal. The
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information used in and derived from a task analysis will depend on the
technique used and the objective of the analysis.
Examples of task analysis techniques include:
 Questionnaires and structured  Task simulation
interviews
 Link analysis  Work safety analysis

 Hierarchical Task Analysis (HTA)  Event/fault tree analysis

 Timeline analysis  Human Factors HAZOP

HTA is one of the most commonly used task analysis techniques. It is


used to systematically analyse a task or series of tasks. The outcomes of
the HTA will depend on the reasons for its use. For example, if a new
control room is being designed for a process facility, the design layout
and equipment available in the control room should be tested to ensure
that it is appropriate for handling all foreseeable operations (start-up,
normal, abnormal). If HTA is used to assess workload, the information,
processing and time requirements of the task, or tasks, should be tested.

4.4 Review, revision and typical problems


Review and revision of hazard identification
The Regulations require that the safety report must be reviewed in
particular circumstances and reviewing the HAZID is part of this
requirement. Consequently, the overall HAZID process should include
regular and pro-active reviews to identify any new hazards and to refresh
knowledge of existing hazards. The HAZID process should include a
range of triggers for individual HAZID studies. These triggers may be a
scheduled program of reviews or could arise from information gathered
during regular safety meetings.

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Use of the HAZID results
The value of a high-quality HAZID, and the major commitment of
resources required, demand effective use of the HAZID. However, the
cost of a major accident will be far more significant than that for the
process that could prevent it.
The hazard register should facilitate the process of revisiting and
updating the knowledge of hazards and incidents within the facility. The
register should communicate clear linkages between the employer’s
processes for hazard identification, risk assessment and the selection or
rejection of control measures.
Lateral thinking and realism in HAZID
History clearly shows that major accidents often arise from a set of
complex conditions or coincidental events, which may include multiple
failures in both equipment and procedures. The initial conditions that
lead to these major accidents might have been relatively minor problems,
but they developed into major accidents because other problems arose
concurrently.
Companies and individuals can exhibit ‘corporate blindness’ when
identifying or reporting hazards by assuming that the systems and
procedures in place only ever function as intended. It is possible that
other safeguards or pure luck will prevent a major accident from
occurring, but the employer should consider the possibility that several
events may at some time combine to cause a serious incident. These
situations arise in reality, and should be allowed for in HAZID.
Use of worst-case scenario in HAZID
Employers should include all foreseeable hazards in the HAZID and
transparently analyse each event within the risk assessment. The
employer should consider all possibilities, on a case-by-case basis, and
document any assumptions regarding the definition of worst case. The
employer should then be in a position to define the worst-case scenario
for the facility. By using risk assessment techniques employers should be
in a position to identify worst-case scenarios.

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Definitions of what constitutes the worst-case scenario can be difficult to
assess. The worst-case scenario is sometimes incorrectly deemed to be
the largest event within the capacity of the on-site protection systems,
simply on the basis that any event worse than this cannot be planned for.
However, such events are merely the worst that has been allowed for
during design and are not necessarily the worst that can occur. Most
examples of major accidents given above clearly exceeded the design
basis, which is why they resulted in such serious outcomes. Both the
‘design’ events and the true ‘worst case’ events are required to be
considered.
It should also be recognised that the ‘worst case’ in terms of the distance
of impact might not be the ‘worst case’ in terms of potential
consequences. It may be necessary to consider both these consequences.
The worst-case scenario for one area of a facility may not be the same as
that for another area of the same facility. This will depend on a large
number of factors such as materials normally or not normally present,
extreme process conditions, isolation systems that may fail, the proximity
and the layout of vessels and the presence of personnel. Employers
should consider all available information, including historical incident
records, in deriving the worst-case scenario.
Common mistakes in HAZID
A common mistake in hazard identification is to screen out or discard
some incidents because they are perceived to be extremely unlikely or of
low consequence. Incidents may be unlikely or of low consequence only
as a result of the control measures in place. However, a key purpose of
the HAZID and risk assessment process is to identify critical control
measures and to determine their effectiveness. Therefore, it would be
self-defeating to disregard incidents because control measures are in
place. All potential major accidents should be recorded during the
HAZID. Any screening, analysis and assessment of the hazards, their
consequences or the effectiveness of the controls, should occur during the
risk assessment. In practice, the HAZID and risk assessment processes
are often combined into one workshop (or similar) which makes this
distinction difficult. This

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ensures transparency and the ability to audit the entire process. This is
necessary for the justification of the adequacy of control measures.
Other potential pitfalls that should be avoided include:
a) being too generic in identification of hazards and potential major
accidents;
b) limiting the hazard identification to the immediate cause of potential
major accidents, without determining the fundamental underlying
cause;
c) attempting to conduct the risk assessment and assessment of control
measures during the hazard identification. Except for very simple
facilities, it is almost certainly better to separate hazard identification
from the subsequent stages; this helps ensure a systematic HAZID
process. However, in practice, the HAZID and risk assessment are
often combined so that the risk assessors are aware of the hazards
identified and any other information discussed during the HAZID;
d) widening the scope to include too great a range of incident types,
such as all occupational health and safety issues. If these issues must
be considered they should only be the issues relevant to controlling
the risk of a major accident;
e) carrying out the HAZID with incomplete or inaccurate facility
descriptive information;
f) proceeding with the study without first having developed, agreed and
planned the approach and the method of recording. A pilot study on
a selected area of the facility, may be beneficial in deciding on an
effective HAZID approach;
g) failing to be comprehensive and systematic with respect to the
activities, operations and possible different states of each part of the
facility;
h) failing to record important information discussed during the HAZID,
e.g. assumptions, uncertainties or debated issues and gaps in
knowledge;

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i) allowing the hazard identification workshops to be dominated by
individual persons or groups within the organisation; and
j) where HAZIDs are conducted across several sessions - failing to
review previous session findings or remind participants of the scope
and objectives.

5 Risk assessment
5.1 Risk assessment aims
The aims of risk assessment are to:
a) provide a basis for identifying, evaluating, defining and justifying
the selection of control measures for eliminating or reducing risk,
and to therefore lay the foundations for demonstrating the adequacy
of the standards of safety proposed for the facility;
b) provide the employer and employees with sufficient objective
knowledge, awareness and understanding of the risks of major
accidents at the facility;
c) capture knowledge of risk of a major accident at the facility so it can
be managed, disseminated and maintained. The management of
knowledge generated in the risk assessment will also greatly assist
the efficient development of a safety report for the facility, for
example by handling assumptions and actions arising; and
d) provide practical effect to the employer's safety report philosophy.
For example, if the employer intends to base the safety report largely
on the facility’s compliance with specific codes or standards, the risk
assessment should address corresponding issues such as the basis of
the codes and standards and their applicability to the facility.
Creating and transferring knowledge using risk
assessment
Understanding the risks of major accidents may be accompanied by
uncertainty, but the risk assessment will be successful if it reduces this
uncertainty to an acceptable or tolerable level. The results of risk

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assessment must be captured and disseminated to those who require the
knowledge, to enable the uncertainty of the entire organisation to be
reduced to an acceptable level.
An effective risk assessment should involve the processes of debating,
analysing, sharing views and generating information and knowledge on
the risk of major accidents and their means of control. It should include
the active participation of employees or contractors who influence safe
operations. This is the definitive criterion for participation of employees
and contractors. Formal roles or assumptions about someone’s role are
irrelevant to producing a high quality risk assessment.
There are no limits to the activity or sources that can be used to
understand the facility and its risks. For example, it could incorporate
information from incident investigations, discussions during safety
meetings about hazards and ways of controlling them, condition
monitoring programs, analysis of process behaviour, and evaluation of
process trends or deviations from critical operating parameters, procedure
reviews or flood or weather records.
Risk assessment results are a useful input to training needs analyses. For
example, if a procedure or task carried out by employees is an important
control measure that can fail if there is inadequate employee knowledge,
then the risk assessment should identify that risk and the need for that
knowledge. It can then be a tool to assist in imparting that knowledge to
employees, either by direct involvement in their defined roles or as a
source of information to develop instruction or training sessions.
The above example illustrates the importance of knowledge management
in the process of complying with the Regulations: the HAZID and risk
assessment generate knowledge, and this knowledge should be captured
and implemented via the safety management system and the processes of
consulting, informing, instructing and training. It must be recognised
however, that assessing safety is not the same as managing safety, and
risk assessment is only worthwhile if it informs and improves the
decision- making and implementation processes. Reducing uncertainty
should balance the improvement in the effectiveness of decisions against
the cost of additional assessment.

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The SMS should instigate risk assessments to maintain a comprehensive
and up-to-date understanding of risk as the facility changes. Risk
assessment may be triggered via the management of change process at
the facility. The results of risk assessments would be expected to feed
into the development of the SMS.
Identifying and evaluating control measures using risk
assessment
The risk assessment should consider a range of control measures and
provide a basis for the selection of control measures. Risk assessment
can be a useful tool, which can save or optimise the use of resources, by
determining the effectiveness and costs of different control options,
improving the decision-making process and providing a basis for
allocating resources in the most effective manner. The risk assessment
process should provide the following in relation to control measures:
a) identification or clarification of existing and potential control
measure options;
b) evaluation of effects of control measures on risk levels;
c) basis for selection or rejection of control measures and the associated
justification of adequacy; and
d) basis for defining performance indicators for selected control
measures.
The range of control measures that should be considered in the risk
assessment is addressed later in this guidance material. The risk
assessment should evaluate the range of control measures in terms of
viability and effectiveness to provide a basis for selection or rejection of
each control measure:
a) Viability relates to the practicability of implementing the control
measure within the facility; and
b) Effectiveness relates to the effect of the control measure on the level
of risk. For example, the reliability and availability of control
measures influence the likelihood of an incident occurring, while the

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functionality and survivability of the control measures during the
incident influence the consequences.
Specific studies may be carried out as part of the risk assessment to
evaluate these issues for individual or groups of control measures.
By evaluating options for control measures within the risk assessment the
employer should be able to determine what additional benefit is gained
from introducing additional or alternative control measures. If these do
not result in any reduction in risk, the basis for rejection is apparent. The
employer should look for gaps in the existing control regime, where the
introduction of further control measures may be necessary.
Using the risk assessment to set performance indicators
The risk assessment should generate information useful to the setting of
performance indicators for the adopted control measures. For example:
a) matching performance indicators with the control measures – control
measures with more rigorous performance standards are more likely
to be associated with the high consequence hazards than the lower
consequence hazards;
b) control measure functionality, including reliability, reflecting the
scale of incidents being controlled;
c) reliability, or number of control measures, reflecting the likelihood
of the corresponding incidents.
Overall framework and principles for risk assessment
There are fundamental questions most forms of risk assessment attempt
to address to ensure the risk assessment is comprehensive and systematic
(see Figure 4).
Figure 4: Basic questions within risk assessment

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The risk assessment should use assessment methods (quantitative or
qualitative or both) that suit the hazards being considered. This means
that the tools employed must be selected according to the nature of the
risk. A tool that does not address any variability or uncertainty in the
nature of the hazards and incidents identified can fail to generate the
necessary understanding and provide no basis for differentiating between
control measures.
There is no single tool able to meet all the requirements for risk
assessment, and all tools have limitations and weaknesses. For example:
If the dominant contributor to a major accident relates to aging of
equipment and associated mechanical integrity problems, then an
analysis of mechanical integrity, corrosion rates, breakdown data,
reliability and inspection/testing/maintenance issues may be necessary to
develop the required understanding. In such a case, a quantitative risk
assessment (QRA), which is usually based on generic data, may not
provide the necessary information or lead to effective solutions.

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Similarly, if a facility employer has identified human error as a key risk
driver, then a Task Analysis, Human Reliability Analysis, or detailed
analysis of the operating procedures may be appropriate. Analysis of
equipment condition and reliability in this case would probably not be
effective.
For many facilities, there may be several types of assessment required. In
the interests of efficiency, it is desirable to clearly identify the types of
detailed study required, before following any particular route. Two basic
tools can assist this process, they are preliminary/qualitative risk
assessments and hazard or risk ranking. There are plenty of examples of
both types of tool, but they all have a common purpose - to determine the
nature of the risk in terms of the basic causes, likelihood, consequences
and controls.
Where it is clear that the employer has insufficient knowledge of causes
or likelihood, detailed studies may be needed. A preliminary evaluation
should point towards the types of detailed study required. An appropriate
ranking methodology allows the key areas to be identified and prioritised.
It enables the employer to determine if the gaps in knowledge correspond
to what may be major risk contributors.
Priority should be given to those areas where it is obvious there is likely
to be a high risk and there are also gaps in knowledge about the things
giving rise to the risk. Some iteration may be required where the ranking
of key areas is revisited following detailed assessment, to see if any
hazards have increased in rank and now require more detailed study.
Figure 5 aims to illustrate the relationship of preliminary evaluation,
ranking and detailed studies.

Figure 5: Relationship between preliminary evaluations, ranking and


detailed studies

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The above discussion introduces the concept of a "tiered approach" that
is frequently used in risk assessment. If a simple technique generates the
information required by the Regulations and also generates sufficient
understanding of the risk and the options for its control, further risk
assessment may not be necessary. However, if substantial uncertainty
remains, or the employer wishes to look at a range of options in greater
detail, then further effort is justified and more detailed tools may be
desirable. In general, greater assessment effort should result in a more
quantitative, accurate and robust understanding, thereby allowing a more
transparent and rational basis for decision-making.
The key to the tiered approach is that, at each stage, the employer should
compare the potential cost of increasing the detail of the assessment
against the benefit that further assessment may give. In this context, the
“benefit” may be a higher level of knowledge of the hazards and the risk,
or may be a better understanding of the optimum means of controlling
the risk (described in Figure 6).
Figure 6: Tiered Approach to Risk Assessment

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Some facilities may use a semi-quantitative risk assessment where
qualitative brainstorming sessions of staff are combined with quantitative
studies and information. If data and knowledge have been collected
previously about the MHF and remain relevant to risk assessments under
the MHF Regulations, it is acceptable to make use of that data and
knowledge.
Cumulative assessment of hazards in the risk
assessment
The risk assessment must consider hazards cumulatively and
individually. The effects of several hazards occurring in combination
must be considered. Many major accidents have been caused by the
realisation of
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a number of hazards concurrently. For any accident there may be several
independent hazards or combinations of hazards, each of which could
lead to that accident, and several control measures which may be
particularly critical because they may influence one or more of those
hazards. The risk assessment should give an understanding of the total
likelihood of each accident and the relative importance of each separate
hazard and control measure.
The potential for escalation of major accidents, and the consequences of
this which may be greater than an event in isolation, need to be
considered along with the consequences and their effects (e.g. number of
injuries, extent of property damage).
A facility may have a range of major hazards that could lead to potential
major accidents. Both the highest risk incidents and the overall profile of
risks from all incidents must be determined, so that the risk can be shown
to be adequately controlled. In cases where a large number of different
hazards and potential accidents exist, the cumulative risk may be
significant even if the risk arising from each event is low.
The "bow tie" diagram (Figure 7) is similar to a combined fault and event
tree that shows how a range of causes, controls and consequences can be
linked together and associated with each major accident scenario.
Cumulative consideration of the hazards can be seen as the overall
evaluation of interactions between different parts of a single bow tie or
consideration of a range of bow ties together.
Cumulative consideration of hazards enables the employer to assess the
overall risk picture for the facility and to understand how different causes
and events can combine to lead to an accident. It also enables the key
causes and controls for the risks to be identified and evaluated in more
detail if required.
Figure 7: Examples of bow tie diagram

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Uncertainty and assumptions in risk assessment
Handling uncertainties and assumptions in risk assessment is a difficult
issue, but necessary. A complete and accurate understanding of the risk
of major accidents is unlikely. Uncertainty cannot be eliminated and it
will be necessary to make assumptions in some areas. The key is to
record and test assumptions wherever possible and to explicitly recognise
where the main gaps or uncertainties exist.
Where important assumptions are made (e.g. assuming a control measure
has a high level of effectiveness), the employer should ensure these
assumptions are consistent throughout the safety report, and are
implemented, tested and confirmed in practice.
Employers should consider using sensitivity analysis to test the
robustness of the risk assessment results against variations within the key
areas of uncertainty. This may involve changing key assumptions and
determining if the changes in results would affect any decisions that have
been made based on those results. Where sensitivity analysis or
consideration of the gaps in knowledge indicates a significant level of
uncertainty or poor
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confidence in the resulting decisions, further detailed assessment may be
required.
Is quantitative risk assessment required?
QRA is only one tool within the risk assessment toolkit. It involves
calculation of the frequency and consequence of a range of hazardous
events and numeric combination of these to estimate the risk in a
numerical format to allow direct comparison of results, including a
measurement of risk to nearby neighbours and society as a whole.
However, it is not a requirement of the Regulations that a QRA is
performed. The methods used must be appropriate to the hazards, the
nature of the options available, the facility safety philosophy and the
decisions that are required from the risk assessment. A decision not to
perform QRA does not preclude the employer from carrying out specific
quantitative calculations regarding frequencies, consequences or other
aspects of the risk.
If QRA assists understanding of the risks and the appropriateness of
control measure options, then it should be considered as a tool to support
the risk assessment. However, QRA may not provide all the answers and
is typically best suited to differentiating design, layout, location and
engineering options. QRA is generally considered to be most useful for
quantifying off-site risk; however, it can be useful in assessing on-site
risk if sufficient detail and an understanding of the reality of people’s
response to accidents are included.

5.2 Examples of risk assessment methods


To recap, risk assessment must involve an investigation and analysis of
the identified hazards and major accidents, so as to provide an
understanding (and documentation) of the:
a) nature of each hazard and major accident
b) likelihood of each hazard causing a major accident
c) magnitude of each major accident
d) severity of consequences of each major accident to persons on-site
and off-site
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e) range of control measures available to control each major accident
f) effectiveness and viability of control measures for each major accident
g) individual and cumulative effects of hazards
Each of these aspects is discussed below, with examples to illustrate the
concepts, together with discussion of simplified, overall, preliminary
qualitative methods of risk assessment, that may be used to focus the
detail of the assessment onto the high-risk cases.
This section is not intended to be a detailed or comprehensive description
of risk assessment methods. The methods and figures shown below are
purely selective examples to illustrate the approaches and are not a
recommendation for any specific application.
Preliminary or qualitative risk assessment
The most common form of preliminary or qualitative risk assessment is a
“risk matrix”, which assesses individual incidents in terms of categories,
e.g. low, medium and high, according to their expected consequence and
likelihood. An example of the risk matrix approach is provided in
Australian Standard AS4360 (Risk Management). Risk matrices may
need to be tailored to the requirements of the MHF Regulations as they
are not typically designed for very low frequency events. Risk
nomograms provide an alternative approach; although it is little used in
practice (see Figures 8 & 9).
These methods can provide a relatively rapid understanding of the risk
profile of the facility and can be based on judgment or be refined using
more detailed information. However, the understanding gained will be
relatively coarse, and the methods have limitations. For example, it is not
easy to incorporate the effects of risk reduction measures within the risk
matrix, and neither method is easy to use to assess cumulative hazards, in
particular at facilities where a large number of hazards exist. To assess
such issues, methods that are more detailed are likely to be required.
When using risk matrices or nomograms it is important to define
individual incidents or scenarios on a consistent basis so that comparable
events are assessed. For example, a risk matrix could be used to evaluate
specific outcomes of incidents or individual incidents or a specific
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cause of an

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incident. The likelihoods and consequences would be defined very
differently depending on which definition of incident is used. Hence, the
employer should decide how incidents will be defined and use the same
approach for all incidents. A balance must be struck between defining
events in sufficient detail and defining too many events to manage in the
assessment.

Figure 8: Example of a risk matrix

Figure 9: Example of a risk nomogram

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Ranking methods
Most forms of preliminary risk assessment can be used as a basis for
ranking different incidents to establish their approximate order of
importance. In the risk matrix example, a simple scoring system can be
introduced to represent the combined effect of likelihood and
consequence. For example, the highest-ranking incident is m.a.7 (i.e.
major accident number 7) with a score or risk index of 16, closely
followed by m.a.12 with a risk index of 15. The sum of the risk indices
for all incidents is 76; therefore, the contribution of incident m.a.7 is
16/76 or about 21% of the cumulative risk. Note that the risk index on
the matrix is a multiplication of the numbers assigned to the rows and
columns NOT an addition.
An extension of the above scoring approach is to define a range of
specific factors that affect the likelihood or consequences of each
incident. For each factor, each incident may be given a score such as
from 1 to 5 or a simple rating such as low, medium or high based on
specific, established

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criteria. The scores for each incident are then added to give an overall
likelihood, consequence or risk score for each incident.
Investigating and analysing the nature of hazards and
major accidents
A range of different techniques is available for investigating and
analysing the nature of hazards and major accidents. The MHF
Regulations do not prescribe a specific method; therefore, it is the
employer’s responsibility to determine the most appropriate for the
circumstances of the particular MHF.
To assess the nature of hazards and potential major accidents requires
knowledge of what may go wrong within the facility if measures to
eliminate or prevent accidents are not present. Depending on the
different types of hazards and potential outcomes, the employer may
need to employ a combination of techniques to develop a complete
understanding.
Techniques, which may have been used for identifying hazards and
accidents, can sometimes also be used in the risk assessment to assist in
understanding the nature, consequences and likelihood of the hazards and
their control. For example, while HAZOP is primarily a tool for hazard
identification, the HAZOP process can also include assessment of the
causes of accidents, their likelihood and the consequences that may arise,
so as to decide if the risk is acceptable, unacceptable or requires further
study. However, within the scope of a combined HAZID and risk
assessment workshop, this assessment would necessarily be coarse,
qualitative and subjective and would in many cases need to be
supplemented by more detailed assessment outside the workshop.
A HAZOP would not necessarily be the appropriate technique for
detailed analysis of the causes of some other types of accidents (e.g.
failures within complex electrical or mechanical equipment). In such
cases, a failure mode effects and criticality analysis (FMECA) may be
more useful and

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supplemented by whatever mechanical integrity information already
exists for the systems within the facility’s maintenance and breakdown
records.1
Alternatively, a Fault Tree Analysis may provide the necessary
understanding of the nature and causes of different types of hazard. 2 In
many cases, an FMEA may be used to identify what can go wrong, and
how low-level failures may affect higher-level systems.3 A Fault Tree
may then be used to show how low-level failures, combined with
external aspects such as loss of power supply or human error may
combine to cause overall system failure. The Fault Tree can also be used,
in principle, to estimate the likelihood or frequency of the failure
occurring.
Figure 10: Example of a Fault Tree

1
See under the heading “Examples of HAZID techniques” in section 6.6 of this booklet for a
brief explanation of an FMECA.

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2
Also see the reference above for a brief explanation of a fault tree and event tree analysis.
3
Also see the reference above for a brief explanation of an FMEA.

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Investigating and analysing the likelihood of hazards
causing major accidents
Likelihood analysis is a complex and potentially difficult process. The
range of values in this process varies from “may occur within a plant
lifetime”, through to “extremely rare” or “never known within industry”.
Likelihood is highly dependent on a range of site-specific factors such as
the number of equipment items, its condition, activity frequencies, the
quality of the management system and human error levels.
Likelihood analysis should consist of a mixture of qualitative and
quantitative information that, overall, gives an indication of likelihood of
each incident. This may be based on calculations of basic task
frequencies, analysis of how often errors are made, the reliability of
safety devices, previous incident history or near miss data for the facility
or industry sector.
If historical data is used, it should be critically assessed and the sources
of such information documented. If simple judgment or other techniques
are used, the employer must record the assumptions and logic used to
determine likelihoods.
Likelihood analysis flows directly from the preceding process of
assessing the nature of hazards and accidents. Further evaluation of
information generated in these processes may be carried out to derive an
understanding of likelihood. For example, Fault Trees can be used to
produce a qualitative or quantitative understanding of the likelihood of
different hazards and how they may combine to lead to a specific
accident.
Event Trees may be used to determine what alternative outcomes may
arise from an initial event, and the relative likelihood of each outcome.
Again, it is possible to develop qualitative or quantitative event trees.
Event trees also assist in defining the significant consequence scenarios,
which need to be evaluated in detail.
Both Event Trees and Fault Trees can be used to evaluate quantitatively
or qualitatively what effect existing or potential control measures have on
risk levels. The effects of control measures assumed in these assessments
should be reflected in the performance indicators defined for the control
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measures.

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Figure 11: Example of an Event Tree

Human factors and likelihood


Human factors can have a major effect on the likelihood of breakdowns,
hazards or overall incidents. It is very difficult to fully quantify the
effects of human factors on likelihood; however there is some robust
general information on human error rates that may be utilised in risk
assessment.
Investigating and analysing the magnitude and severity
of accidents
The magnitude and severity of accidents can be determined using
consequence and impact analysis. Consequence analysis involves
calculation of the size and duration of the physical and or chemical
effects of accidents, while impact analysis involves determination of the
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harm done to people and property.

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There are complex computer packages available for consequence
analysis, but also simple equations and nomogram techniques for some
cases such as the radiation from pool fires or the toxic gas cloud
formation from releases of chlorine. Typical consequences which need to
be considered within a risk assessment are toxic exposure from gas
clouds or smoke inside or outside buildings. The selective use of “worst-
case” consequence modelling can improve the efficiency of a process
when it is necessary to identify which areas of the facility can cause
offsite effects.
It is necessary to also consider less than worst-case conditions to develop
a comprehensive understanding of the risk. The Regulations apply
equally to onsite and offsite populations, and the worst-case scenarios for
onsite and offsite populations may be very different.
The worst-case approach involves defining the credible combination of
conditions giving rise to the maximum consequence zone for the
identified accident, in relation to the target population. This can include
defining release quantity, duration, pressure, composition, location, wind
speed and other atmospheric conditions, time of ignition and functioning
of control measures.
It is common to assume the worst-case release quantity is the maximum
vessel contents, released over a defined period of time. However it
should be noted that this cannot be assumed to be the correct assumption
for all types of plant or storage area. Where there is a clear mechanism
for releasing more than the maximum vessel inventory, this should be
considered in the consequence analysis.
Active control systems such as isolation valves and blowdown systems
need to be assessed for worst-case scenario. Passive control measures
that are assured of functioning in the event of the worst-case accident
may be included in the assessment.
The impact distance in all directions from the release point should be
determined allowing for the fact that the wind can blow from any
direction. The impact distance is usually determined to a predefined
“consequence criterion” which can be material and/or effect specific.
For example, LPG flash fires will occur to a defined lower flammable
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limit while LPG can also produce fireballs or jet fires that can cause
injury or

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damage from thermal radiation effects. Thermal radiation criteria are the
same for all flammable materials. Employers should carefully define all
relevant consequence criteria based on their definition of a major
accident.
Below is an example of one method for illustrating the consequences and
effects of a major accident. The example is a major accident involving a
pool fire. This method may prove helpful during the risk assessment
process and, if used, should be included in risk assessment
documentation.

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12: Pool fire consequences & effects

The employer should consider consequences under a range of


meteorological conditions. Usually the worst-case meteorological
condition for toxic or non-dense gas releases is high atmospheric stability
and a low wind speed, typically experienced at night-time or in the very
early morning. For dense gases, the worst-case condition is typically a
high wind speed, which tends to occur at neutral atmospheric stability
and during the day. Definitions of stability and other environmental
conditions can be found in safety or meteorology literature.
Ambient temperature and humidity may also affect the consequences of
releases. In particular, high temperature can increase the flammable
effect range of low volatility materials. Surface type and topography can
also affect the consequence, such as a spill into water or onto sloping
areas.
For flammable materials the consequences should be analysed both when
ignition occurs immediately following the release, and if ignition occurs
after sufficient delay for a flammable cloud to fully develop. Further
factors to consider include day versus night conditions, extreme weather
conditions such as flooding, storms and including cyclones for facilities
located in cyclone-prone areas of Australia.
To evaluate the impacts of major accidents on people, it is necessary to
consider the number and distribution of potentially exposed people, and
their characteristics. Variations in these factors should also be considered
such as temporary populations, maintenance crews and on-site
populations for specific operational modes. A further factor that should
be considered is that people such as emergency services or investigators
may be present specifically because there is a developing incident.
Presentation of risk assessment results
Risk assessment results can be presented in many different ways (see the
example below). Again it is important to provide the results showing
explicitly which control measures are reflected in each result.

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Figure 13: Example risk assessment results

Key achievements for a quality risk assessment


 The risk assessment is conducted for all hazards and potential
major accidents at a facility, ensuring that:
a) it is comprehensive, systematic, rigorous and transparent;
b) it generates all information required by the Regulations, and
provides employers with sufficient knowledge to operate safely;
c) the knowledge is kept up to date, through review and revision;
d) the information is provided to persons who require it to work safely;
e) an appropriate group of employees is actively involved;
f) uncertainties are explicitly identified and reduced to an acceptable
level;
g) all methods, results, assumptions and data reflect the nature of the
hazards considered and are documented;
h) a range of control measures are considered and their effects on risk
are explicitly addressed;
i) it supports the development of the safety management system;
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j) it is used as a basis for adoption of control measures, including
emergency planning; and
k) it is used as a basis for the demonstrations in the safety report.

6 Control measures
6.1 Introduction
The previous sections discussed key elements for the range of control
measures that should be in place at an MHF. This section provides more
detailed guidance on how to select and judge the effectiveness of specific
control measures. Choosing the best control measures and being able to
demonstrate their effectiveness is a critical feature of compliance with
the Regulations.

6.2 What is a control measure?


A control measure is the part of a facility, including any system,
procedure, process or device that is intended to eliminate hazards,
prevent hazardous incidents from occurring or reduce the severity of
consequences of any incident that does occur.
It is the principal tool that delivers safe operation. Control measures are
not only physical equipment; they may include high-level procedures or
detailed operating instructions and information systems. Control
measures may be proactive, in that they eliminate, prevent or reduce the
likelihood of incidents, or they may be reactive, in that they reduce the
consequences of incidents. They must be implemented under and fully
supported by the managerial elements of the SMS.
The employer should identify control measures carefully for the MHF, to
avoid unnecessary effort or confusion via assessing measures that are not
relevant to major accidents. Understanding what part is a control
measure, and how it actually controls or affects hazards and risks, is
critical to safe operation. This understanding is also essential to the
safety report and the associated justification of adequacy of the adopted
control measures.
Control measures can be regarded as the “barriers” between the hazards
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of an MHF, the occurrence of a major accident as a result of these
hazards,

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and ultimately the harm that may be caused to people, property and the
environment in the event of a major accident. This concept is illustrated
in Figure 14.

Figure 14: Control measures as “barriers” to major accidents

Consequences
Control measures can be identified while identifying hazards and during
the risk assessment. Employers should be able to identify a range of
control measures immediately, both the existing measures and possible
alternatives. Checklists of "typical" control measures may be able to
assist in the process, but these should not be used in isolation. The
specific nature of each hazard and the associated part of the facility
should be considered when identifying control measures. The table below
is an example of the consequences and key control measures that might
apply for a warehouse.
An example: Identification of scenarios and control measures,
dangerous goods warehouse

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Scenarios Key Controls
 Flash or pool fires from  Drum inspection and handlin
puncturing drums containing procedures
flammable liquids.  Ignition source control
 Fire fighting equipment
 Fires in packaged goods  Housekeeping
areas, in pallet storage stacks,  Ignition source control
or amongst general rubbish.  Smoke detection and automatic vent
 Fire escalation.  Separation and segregation rules
 Stacking restrictions
 Fire fighting equipment an
emergency response

6.3 Understanding control measures


Each identified control measure should be clearly linked to the causes,
hazards, major accidents or outcomes they are designed to control.
Employers should understand the nature, scale and range of hazards and
outcomes each control measure must deal with and the effects each
control measure has on these factors. This understanding is required to
cover the whole range of conditions that might exist at the facility.
This knowledge provides a clear basis for defining which control
measures are critical to safe operation. It also provides a basis for
defining performance indicators and standards for control measures.
Using a risk control hierarchy to determine control
measures
In an occupational health and safety context, risk control is often
categorised according to an effectiveness hierarchy; often simply called
the “risk control hierarchy”. The hierarchy lists the type of control

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measures in a priority order, based on the extent each measure has an
impact on risk.
In the context of MHFs, a useful effectiveness hierarchy of control
measures is as follows:
a) eliminate hazards;
b) prevent incidents;
c) reduce consequences; and
d) mitigate the harm.
The different categories are defined below.

The control "hierarchy" in an MHF context:


Control measures that eliminate a hazard are clearly the most effective.
If practicable they should be selected in preference to any other type, as
their existence removes the need for other controls.
Control measures for prevention are those intended to remove certain
causes of incidents or reduce their likelihood. The corresponding hazard
remains, but the frequency of incidents involving the hazard is lowered.
Control measures for reduction are those intended to reduce the severity
(consequences) of incidents. They include reduction of inventory.
Control measures for mitigation are those that take effect in response to
an incident to limit the consequences. They may include fire-fighting
systems and, in particular, the emergency response plan. While they may
be the "last line of defence", they remain necessary if risk cannot be
reduced to a negligible level by other means.
Control measures can also be categorised as hardware (i.e. engineered systems)
or software (e.g. management systems or operating /maintenance procedures).
Controls may also be grouped into categories that define the nature and spread
of the control such as engineering, organisational, procedural and
administrative controls. Whatever method of categorisation is employed, safe
operation will depend on an appropriate balance of different types of control
measures.

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These categorisations can help in determining the most effective control
measures for a facility and in ensuring a range of measures is chosen so
that one failure does not remove many controls.
A single category of control measure will rarely be enough for a risk to
be controlled as far as is reasonably practicable unless the elimination of
the hazard has occurred. Most commonly, layers of protection will be
required to reduce a risk so far as is reasonably practicable.
For most facilities or items of equipment, there are numerous layers
acting as barriers to eliminate, prevent, reduce or mitigate incidents. This
is illustrated in Figure 15. Equipment integrity, operating and
maintenance procedures are the "inner layers", and are the barriers
normally relied on to ensure incidents do not occur. Systems that reduce
or mitigate incidents are the "outer layers" which are relied on in
abnormal or emergency conditions. A robust risk control regime will
feature a range of risk control layers; the number and integrity of which
should reflect the inherent level of hazard and risk within the protected
part of the facility.
Figure 15: Layers of Protection

COMMUNITYEMERGENCYRESPONSE

PLANTEMERGENCYRESPONSE

PHYSICALPROTECTION&
MITIGATIONSYSTEMS
AUTOMATIC SAFETY
INSTRUMENTSYSTEM
CRITICALALARMSAND
OPERATINGPROCEDURE
S
BASIC
PROCESS
CONTROLSYSTE
M
PROCESS

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Examples of control measures are shown below, using the above
categorisation. The table is illustrative only, and is not intended to be a
complete list of possible controls for any facility. The categorisation
shown is not intended to be rigid, and many controls may apply in more
than one category.

Some examples of control measures


Type Engineering Controls Administrative Controls
Eliminatio  Mounding of LPG  Inherently safe process
n storage tanks. concept.
 Substitution with non-  Feedstock quality
hazardous materials. specifications.
 Inherent design features,  Plant design procedures.
layout.
Prevention  Impact and dropped  Operating procedures and
object barriers. instructions.
 Isolation valves to enable  Maintenance and isolation
safe maintenance work. procedures.
 Mechanical ventilation  Management of change.
systems.
 Process Control systems.
 Corrosion and erosion
probes.
 Materials specifications,
corrosion allowance.

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Reduction  Physical barriers between  Spill containment and
incompatible materials. clean-up procedures.
 Secondary containment  Ignition suppression
of hazardous substances. equipment.
 Process emergency  Procedures.
controls and alarms.
 Shutdown, isolation and
de-pressurisation
systems.
 Bursting disks.
 Safety and relief valves.
 Bunds, other containment
and drainage systems.
Mitigation  Fire detection systems.  Emergency alarms.
 Fire suppression and  Emergency planning and
cooling systems. procedures.
 Passive fire protection  Employer-owned buffer
systems. zones.

Control measures may vary for different stages of the facility's life cycle.
For example, design and construction standards are important for new
facilities, but as the facility ages more emphasis may be required on asset
integrity management. Similarly, control measures may themselves have
life cycles that may need to be considered.
The balance and type of control measures are expected to be consistent
with the employer’s overall safety philosophy. If the safety philosophy is
based primarily on engineering controls there is less need for other
controls such as administrative ones. On the other hand, if the safety
philosophy is based on personnel knowledge and skills, then procedural
and competency controls might be dominant, although there would need
to be additional hardware controls.
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The assessment required to understand control measures, their function
and their effects on hazards and associated risks, is driven by three
factors:
a) a highly complex reaction process, new technology, or complex
process equipment may require detailed assessment to understand
the control measures, whereas a simple system can be understood
more rapidly and without using sophisticated methods of assessment;
b) where there are numerous options available to control the associated
risk, more effort is likely to be required to reach an understanding of
the available controls, to differentiate the options in terms of their
effects on risk and to provide a basis for selecting or rejecting
options appropriately; and
c) a high level of uncertainty regarding the nature of the hazard or risk
or the behaviour of the control measures is likely to require greater
effort to reach an overall understanding; e.g. Class 6.1 liquids are
more straightforward to analyse than Class 2.3 toxic gases.
The above concepts illustrate the issues that need to be considered in
defining and understanding control measures. There may be many other
issues that need to be considered in developing an understanding of
control measures for a facility. For many facilities this may result in a
significant amount of information. Therefore a simple method of linking
and communicating the information together should be considered, for
example "bow tie" diagrams or registers of hazards and controls.
Figure 16 provides examples of how to use bow tie diagrams or registers
to link and communicate control measure information. Alternatively,
simple hazard management tables or diagrams can be developed.

Figure 16: Examples of presentation formats for hazard and


control information
a) "Bow Tie" diagram

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b) Register of hazards and controls

6.4 Selecting and rejecting control measures


There are several factors to consider when selecting or rejecting control
measures. These factors have a bearing on the fundamentally important
requirement to:

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a) justify the adequacy of control measures (where “adequacy” means
“adequate to eliminate risk or reduce it so far as practicable”);
b) identify potential common mode failures; and
c) define performance indicators for the control measures.
The text below sets out a series of core questions that the employer may
consider using when selecting or rejecting control measures:

Core questions to ask when selecting or rejecting control measures


Are there controls clearly linked to each hazard, or are there some
hazards having no (or insufficient) control measures? Does the number of
controls reflect the level of severity of the hazards? The extent of
demonstration should be proportional to the level of risk.
What is the functionality of a control measure against the relevant
hazards? Is it sufficient to control the hazard in the intended manner, i.e.
is it fit for purpose, will it suppress the hazard completely, prevent
escalation or simply mitigate effects?
What is the survivability of the control measure in an accident? Is the
control measure able to function as intended during the types of accidents
it is intended to reduce or mitigate?
Is the reliability of individual control measures, and of all control
measures in combination, appropriate to the level of risk presented by the
associated hazards? Is function testing sufficiently frequent to detect
failures, and will failures once detected be rectified sufficiently
promptly?
Has the hierarchy of control measures been considered, with
measures to eliminate the hazard adopted first if practicable, followed by
measures to prevent, reduce and mitigate?
Is there a balance of different types of control measure for each hazard,
i.e. is there a diversity of control measures? Are the control measures
associated with individual hazards independent of each other, or can they
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all be disabled by the same mechanism?

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Are the control measures maintainable? For example, are they accessible,
can they be maintained (i.e. safety valve with no means for
removal/maintenance as it is the only one and must remain in service)?
Are new control measures compatible with the facility, and any other
control measures already in use?
Can the control measures be implemented at the facility considering
their availability and cost?

6.5 Additional or alternative control measures.


Employers should objectively challenge how safety is achieved and
consider ways to improve safety. This means that alternative control
measures not currently in place must be considered alongside existing
control measures, and either adopted or rejected according to the results
of the risk assessment. In particular, additional controls should be
considered if the risk is not reduced as far as practicable or hazards have
been identified with no control measures in place. Alternative controls
should be identified where the risk is not reduced as far as practicable.
The importance of being prepared to challenge the "norms" of facility
operation has been highlighted in past disaster inquiries such as the
Longford Royal Commission and the Cullen Inquiry into Piper Alpha.
Therefore the employer should typically consider the following
circumstances:
a) existing control measures which are believed to be fully functional
and appropriate;
b) existing control measures which may have become disabled,
degraded or deficient;
c) existing control measures which function as intended but could be
improved;
d) control measures which were considered or used in the past and
rejected for some reason;
e) existing control measures which are to be replaced due to
obsolescence or old age;

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f) new control measures which could replace or add to the existing
range of control measures; and
g) new control measures for modifications to the facility.
For many existing facilities, there may be control measures that were
adopted or rejected in the past without records to support those decisions.
Employers should identify past decisions and control measures that need
to be recorded and reviewed, to understand what was done in the past and
why it was done, and to maintain the integrity of existing control
measures in the future.
This relates to the need for a knowledge base of the control measures on
the facility and is an important part of justifying the adequacy of an
existing facility in the safety report. Given the potentially large number
of decisions and control measures for a typical MHF, which may have
decades of operating experience, the employer will need to identify the
critical areas that require review, and determine which areas need to be
reviewed in brief or in detail.
Circumstances where control measures would require review include:
a) new operating conditions have arisen;
b) knowledge of the basis for safe operation has been lost;
c) there may have been a degradation in effectiveness of existing
controls;
d) the knowledge or technology employed is now outdated; and
e) an incident occurred.
The employer should identify both proven technology and newly
developed options, as appropriate and not dismiss any option on the
grounds that it is "unproven". The process of risk assessment should
include the evaluation of new technologies and practices to determine if
they are appropriate to the facility.
A reasonable number of existing and alternative control measures should
therefore be considered, depending on:
a) the scale and complexity of the facility;
b) the nature of the risk profile; and
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c) the rate of development of new technologies and practices.

6.6 Defining performance indicators for control


measures
Performance indicators for control measures will generally relate to some
standards or target levels of performance (performance standards) to
ensure safe operation. Performance indicators and the corresponding
standards play a vital role in the justification of the adequacy of control
measures.
A performance indicator is defined as information that is used to measure
the effectiveness of a control, e.g. a test of effectiveness, an indicator of
failure, an action taken to report a failure or a corrective action taken in
the event of a failure. An indicator is an objective measure, which shows
current and/or past performance.
A performance standard is defined as the target set for a performance
indicator. The standard represents the required performance for the
control/SMS (whatever) to be considered effective in managing the risk
to ALARP.
Once the employer has decided which control measures are to be
adopted, performance indicators must be defined for the control
measures, which enable the employer to:
a) measure, monitor or test the effectiveness or failure of each control
measure; and
b) determine the best reporting and corrective actions to be taken in the
event of failure.
Performance indicators should measure not only how well the control
measures can perform, but also how well the management system is
monitoring and maintaining them. This shows how performance
indicators for control measures overlap with the performance standards
required for the SMS.
Some performance indicators and their corresponding performance
standards for engineered control measures may be adopted from

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manufacturer's recommendations; however, the employer should
determine if these are appropriate to the specific conditions of the facility.
Performance indicators take many forms, and can be quantitatively or
qualitatively expressed. One type of target is a desirable long-term goal
or a limit, the breaching of which can be tolerated to a certain extent or
under certain conditions in the short-term. Another type of target is one
that needs to be achieved within a prescribed timeframe, or where there is
zero tolerance for any breaches.

An example of performance indicators for control measures:


A hardware control measure has performance standards relating to its
capacity and reliability, plus management system standards for
inspection, testing and maintenance, which aim to assure that the
capacity and reliability of the control measure are maintained.
Performance indicators need to be set that measure performance against
these standards.
For example, for a pressure relief valve the performance indicators and
standards may relate to:
Min number on-line: x
Min relief rate: y kg/s
Max probability of failure: y%
Max interval between tests : z yrs
One example of a performance indicator that provides a range of
acceptable performance is a pre-alarm limit that can be exceeded for a
period of abnormal operations provided this is monitored. A
performance indicator that does not allow a range of acceptable
performance is set at the level of the critical operating parameter (see the
section on critical operating parameters).

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Performance indicators for control measures should include the following
considerations:
a) failure of any control measures - what are the performance
requirements for functionality, availability, reliability and
survivability of control measures that indicate how or how often the
control measures may fail to perform, and what performance
standards are required for any activities necessary to achieve these
standards?
b) reporting of control measure failures - what activities are
necessary to confirm or assure performance, what degree of
reporting of failures is required, how quickly will the reporting
system identify a failure, and what level of independent verification
is needed in addition to routine assurance?
c) Corrective action in the event of such failures - what steps are to
be taken and how quickly following detection, and what
performance standards are required of the corrective process?
Performance indicators can be defined at various levels, e.g. there may be
high-level performance indicators as well as lower level and detailed
performance indicators. High-level indicators tend to address overall
performance issues, for example:
a) employee perceptions, incident rates, improvement programs,
availability of control measures which may be taken as indicators of
overall safety performance;
b) maintenance of operating conditions within a critical operating
envelope, which may indicate overall integrity of the process control
regime; and
c) total number of resources dedicated to testing, inspection and
maintenance of critical control measures.
Detailed performance indicators tend to relate to individual measures that
when combined; contribute to achieving overall high-level performance.
At a detailed level, there are many different types of performance
indicators that can be defined for each control measure.

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When specifying performance indicators or standards, it may be
necessary to provide detail on “who, what, where, and when” for
implementation of procedures and activities relating to these indicators
and standards. The responsibility for implementation of performance
indicators can be defined at a very specific level for each performance
standard. For example, responsibility for operational parameters may lie
with operations management teams.
Where performance standards relate to control measures, they should be
assessed as part of the justification of adequacy. It is also necessary to
show that the control measures achieve the standard that has been set. In
the simplest cases, performance standards may be industry standards,
codes or norms. However, these need to be shown to be appropriate to
the specific facility and this can be by a combination of techniques such
as:
a) risk assessment results;
b) qualitative argument or reference to the basis for the standard; and
c) cost-benefit or cost-effectiveness analysis of options.
In more complex cases, where there may be no appropriate existing
standards, the employer may need to demonstrate the suitability of the
performance standard based solely on the risk assessment.

Some examples of performance indicators for control measures:

 Management system compliance levels as shown by audit.


 Test frequency/interval for safety-critical equipment.
 Average skill level of the operations shift personnel.
 Compliance level with operating procedures as shown by monitoring.
 Number of failures in specific safety devices.
 Number of times staffing levels fall below target minimum numbers.
 Number of times pressure, temperature etc exceed particular levels.
 Measured mechanical integrity (e.g. extent of corrosion).
 Detection and response
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 Sensitivity levels and response times for process alarms.
 Compliance levels with manufacturer's or design standards.
 Vibration levels in rotating equipment (e.g. compressors).

6.7 Critical operating parameters


For the purposes of this booklet, a critical operating parameter (COP) is
“the upper or lower performance limit of any equipment, process or
procedure, compliance with which is necessary to avoid a major
accident”.
The sum total of COPs may define an overall safe operating envelope for
the facility. Control measures are required to prevent COPs being
exceeded; in general each COP will have at least one associated control
measure, and each control measure will relate to at least one COP. A
COP is a process or other variable that can be measured instantaneously,
and where a breach of the safe operating envelope may be detected by
exceeding the COP limit.
This contrasts with performance standards, which are generally
something against which performance may need to be tracked over a
period of time, to determine whether operations are acceptably safe.
Performance standards might include the number of times COPs are
exceeded each year. Examples of COPs are the quantity, pressure,
temperature or composition of a material in storage or process systems,
or the manning level at the facility, or the number of fire-water pumps
available on-line.
Each COP may have an associated performance standard, such as the
allowable number of times a soft target associated with the COP is
exceeded. This performance standard then also relates to the associated
control measure. There may be critical design or maintenance parameters
that can be used in setting performance standards. The concept of COPs
is illustrated in Figure 17.

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Figure 17: Illustration of critical operating parameters

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6.8 Involving employees in control measures
The Regulations require employers to consult with employees and
contractors (where practicable) in all decision-making processes
associated with controlling risks. The employer should consider defining
roles for employees in relation to adopting or reviewing control
measures. Through this involvement, employees are able to provide their
knowledge of how the facility is operated in practice and assist in
identifying the control measures actually in place. The employees’
knowledge may also assist in providing an understanding of how control
measures function in practice, and how they may fail or be defeated.
Employees will be aware of issues such as compatibility and
maintainability of alternative control measures and are vital to the
process of selecting or rejecting control measures. The objective is to
make use of employees’ knowledge and experiences in the working of
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the facility.

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In practice, only particular employees are involved in this way, however,
all employees must be provided with information, instruction and
training on the adopted control measures regardless of their involvement
in the review and assessment activities. This ensures that all individuals
understand the control measures to the extent necessary to perform their
work safely. Evidence of genuine participation by employees in all
aspects of selecting control measures will make an important contribution
to the quality of the safety report.

6.9 Control measures within the safety report and SMS


Control measures should be systematically managed within the SMS and
must be presented within the safety report. This information should
include statements on the viability and effectiveness of the range of
control measures considered, methods and results of the corresponding
risk assessments, and the reasons for selection or rejection of control
measures. It should also include the COPs and performance indicators for
the adopted control measures and a justification of the adequacy of
control measures, including the means by which performance is assured.
The SMS must relate to each activity used in the selection and ongoing
maintenance of control measures. Each element of the SMS should have
performance standards to provide regular monitoring of the effectiveness
of each element. Consultative methods used to involve the people
working at the facility to identify and develop control measures should be
described.
The employer’s processes for adopting and managing control measures
and their related information are illustrated in Figure 18. Examples of
methods for recording information, such as a register of hazards and
control measures, were discussed above. However, these can be
expanded if necessary to include additional data on the control measures,
for example consequence and likelihood information from the risk
assessment, performance indicators, the responsibility for "who, what,
when and how", and information to support the justification of adequacy.

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Figure 18: Adopting and Managing Control Measures

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6.10 Reviewing and revising control measures
Control measures must remain valid or effective for the conditions at the
MHF. Ordinarily, it is improbable that all control measures will always
remain valid or effective, given changes at the facility and new
knowledge about hazards, risks and control measure options.
Reviews of control measures should be triggered whenever a situation
arises that would indicate that control measures are no longer valid or
effective, for example if there is a proposal to modify the facility, if there
has been a major accident or if a control measure fails to meet the set
performance standard.
In addition, reviews of the safety report HAZID and risk assessment are
required if requested by Compare and at least every 5 years. It follows
that

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an ongoing process of reviewing and revising control measures simplifies
the 5-year requirement to review the safety report.
Investigating and analysing control measures
Throughout the above steps, the employer will be reflecting upon
existing or potential new control measures in the determination of causes,
likelihood, consequence and risk. It is essential to be explicit about what
control measures are being included and how they are considered to
affect risk levels. The investigation, adoption and rejection of control
measures are discussed later in this guidance material.

6.11 SMS - A suggested combination of key elements


This section discusses the key SMS elements for the range of control
measures at an MHF.4 This booklet provides guidance on the nature of
control measures, selecting facility-specific measures and ensuring the
effectiveness of the control measures. Refer to Booklet 3 for further
information on the SMS.
The actual configuration of control measures used must suit the facility.
This suggested combination of key SMS elements for control measures is
not intended as a template, but as an indication of the type of elements
and features that should be in place at the facility (refer to Figure 19).

4
This combination of key elements is mainly derived from the US Department of Labour’s
Occupational Safety and Health Administration’s (usually contracted to OSHA) guidelines for
process safety management (see reference in Appendix A under the topic heading “Role and
development of an SMS”.)
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Figure 19: Suggested combination of key control measure
SMS elements

Keywords: Workplace safety, safety inspectors, enforcement, legislations,

accidents.

Introduction/ Background

In the pursuit of a livelihood, wage earners are subjected to varying risks and

hazards, some of which are peculiar to their own occupation, while others arise

as a result of their own or the carelessness of others. Industrial accidents do not

constitute a new risk to social security and wellbeing of workers in industrial

organizations. In fact these accidents have been covered by many legal

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provisions throughout the world for several decades. In the contemporary

techno-bureaucratizing world, industrial accidents pose a special challenge to

the safety of workers in industry. Also, the multi-causality of industrial

accidents, new and emerging types and causes of industrial accidents due to

sophisticated equipment and machinery, the growing impact of informal work

and migrant workers in a globalized economy all demand special attention be

paid to the problems and challenges associated with industrial accidents in the

beginning of the 21st century. Against this background, it appears very

important to devise some safety regulation and legislation to protect the life of

individuals employed in industries or factories.

History suggests that labour legislation follows closely on the heels of

industrialization (Singleton, 1983). The advent of the industrial revolution in

the nineteenth century created a need for legislation designed to reduce the

increasing risk of injury and ill-health resulting from the introduction of new

machines and processes. The achievements of modern industry were

unfortunately marred by a startling casualty rate. One of the immediate effects

of the industrial revolution with its mechanization of production was a

tremendous increase in the number of health and accident hazards faced by the

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worker and the subsequent evolution of industry has facilitated a cumulative

increase in such hazards (Muntz, 1980). The industrial safety philosophy

developed because the hazardous work environment of early factories and

other production and distribution sites produced a high rate of worker injuries

and deaths. If these conditions had not been corrected to stop the waste of

personnel and resources, the growing number of accidents and injuries would

have staggered the imagination (Singleton, 1983). The fact that the startling

total of persons incapacitated by industry is in large parts needless has been

emphasized over and over again.

The cost of industrial accidents and workplace injuries cannot be

underestimated. Throughout the history of industry, hardly does any day passes

without a reported case of accident or workplace injuries. The financial cost of

workplace accidents and injuries includes compensation payment, reduced

production due to damaged equipments, man-day loss, loss of wages, medical

care and loss of property among others. The non-financial/ social cost of

workplace accident are made up of loss of limb/life, loss of breadwinner,

human suffering and widowed spouses and children and loss of skilled workers

whilst off injured.

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Occupational Safety and Health Administration activities represent a major

public intervention to reduce the incidence of occupational injuries and

fatalities at the workplace. Although Occupational Safety and Health

Administration have other tools, its chief instrument is a program of

inspections geared to achieve compliance with its set of safety and health

standards. Industrial safety has become the prime responsibility of the

management in the modern industrial set up. Industrial and labour legislations

have made it obligatory on the part of captains of industry to take necessary

steps to ensure industrial safety. Safety measures do not only reduce the

frequency of industrial accidents but also increase the productivity.

According to Bittel (2005), accident reduction and prevention depends on the

three E’s –Engineering, Education and Enforcement: job should be

engineered for safety, employees should be educated in safe procedures and

safety rules should be enforced.

Devising effective safety and health legislation is a very difficult process, but

the problem cannot be avoided. There is no doubt that some legislation is

essential for every country, since the state must act to protect the individual

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from

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the complex hazards involved in his/her work and provide ways of

compensating him when an unpredictable or unlikely event occurs (Singleton,

1983). In all countries, both developed and developing, there are some forms of

safety and health legislations or regulations. In many countries, all employees

are supposed to be covered by employee safety services, legislations and

regulations as stipulated by the International Labour Convention 161(1985).

Employee safety is a crucial issue in the functioning of any industry or

company. This is because without the safety of workers, the whole production

could come to a halt and this could affect the income of employees, the profit

of employers/management, the dividend of shareholders, the taxes of the state

and could raise the scarcity of product demanded by the consumers. In this way

devising effective, efficient and achievable safety, regulations and legislations

should be the concern of all in industry, since this is the only way in which safe

and healthy working environment can be guaranteed. It is also important to

state that, the successful implementation of well developed safety regulations

depend on the education and awareness of workers on such regulations, the

effective compliance of workers with such regulations and the regular

enforcement and inspection by the management and statutory enforcement

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agencies. Such

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industrial safety legislations are necessitated by the fact that, the individual

workers are members of society and hence they need protection from

workplace related hazards and accidents. This is based on the assumptions of

the Human Relations School, which focuses on the behaviour of employees in

group situations and how these workers should be treated as human beings to

be protected against any hazard or accident in the factory which is a social

system.

Against this background in Ghana for instance, Workmen’s’ Compensation

Law, 1987 (PNDC L 187,) and the Labour Act of 2003(Act 651) are examples

of safety legislations and regulations in industry. Part xv of the Labour Act of

2003 has a section on occupational health, safety and environment. Also

Section 118 of the Labour act provides measures on general health and safety

conditions. There is the Factories Act of 1970{Act 328} which has provisions

for the safety of any person employed to work in an organization. All these

legislations are enacted to enable all stake holders and social partners in

industry to apply the standard set in order to control the hazards that may exist

in the workplace. In so doing, the work environment becomes safe for all

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involved in industry, resulting in reduced accident cases. The issue of

awareness, compliance and enforcement

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of safety legislation is very important. This is because, it is paramount and

significant in determining the efficiency and effectiveness or otherwise of

safety legislations and can also influence the rate of workplace related injuries

and accidents. In Ghana, the Department of Factories Inspectorate is the

statutory agency responsible for enforcing industrial safety regulations. In spite

of the regulatory roles played by the DFI the rates of workplace accidents in

Ghana are still quite alarming. The existence of safety legislations and

regulatory agencies is not enough as in the case of Ghana, these legislations

and regulations abound, but in most cases the problem is with enforcement of

safety legislations and the inspectorate role to be played by the regulatory

agencies. No wonder in Ghana, the rates of workplace accidents and injuries

keep on increasing despite the existence of legislations on workplace safety.

Statistics available on number of workplace deaths and injuries speaks volumes

about the weakness in the enforcement and regulatory regimes and systems.

The table below indicates statistics on workplace accidents and fatalities in

Ghanaian factories between 1997 and 2011.

Table 1: Accidents and fatalities rates in Ghanaian Factories (1997-2011)

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YEAR NUMBER OF NUMBER OF
INJURIES FATALITIES
1997 734 55
1998 898 54
1999 1,190 57
2000 2,150 45
2001 2,485 50
2002 3,456 52
2003 3,565 60
2004 4,560 65
2005 5,670 70
2006 7,790 68
2007 8,903 75
2008 9,804 80
2009 10,045 86
2010 12,096 92
2011 15,323 97

Sources: 1. Department of Factories Inspectorates Report. (2006-2011)

2. Association of Ghana Industries Report. (2006-2011)

The figures so presented above cannot be said to be very accurate considering

the problem of underreporting and the lack of enforcing provisions in the

existing legislation. The problem is compounded also because there is no

central point where statistics are collated for analysis and periodic comparison

and policy direction. The above statistics on workplace injuries and

fatalities in

Prepared by Isaac Mintah – Professor page 90 of


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Ghanaian factories raise serious question of about how work is engineered for

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safety, the extent to which workers are educated on the safety procedures to

follow and how often the safety procedures are enforced. Even thought the

above statistics may not be accurate, the fact still remains that injuries and

accidents occurs in these factories daily and in many cases they are never

recorded. The quest to know the extent to which safety legislations and

regulations are enforced and how effectively safety inspections are carried out

prompted the need to examine the role and activities of the Department of

Factories Inspectorate (DFI) in the Tema Industrial Are.

The efficiency and effectiveness of any safety regimes in industry depends to a

large extent on how effective the statutory agencies responsible for inspection

and enforcement perform their function in promoting workplace safety and

health. The critical issue for this paper therefore is to examine the role of the

Department of Factories Inspectorate, which is mandated by law (the Factories

Act) to inspect and enforce safety legislations and regulations in Ghanaian

workplaces. What is the role of the DFI in promoting workplace safety and

health in Ghanaian factories? What goes into the inspection and enforcement

functions of the DFI? What are some of the challenges faced by the DFI in its

operations? How effective is the DFI in its activities and how does it affect

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workplace safety and accidents? Answers to these questions constitute the

thrust of this paper.

METHODOLOGY

The field work on which this paper is based was conducted at the Department

of Factories Inspectorate in the Tema Industrial Area. To enhance and enrich

the quality of data, both the qualitative and the quantitative methods were used.

The instruments of data collection included semi-structured questionnaires that

were administered to the employees of the Pioneer Food cannery, key

informant interviews with supervisors of the company and officials of

Department of Factories Inspectorate in Tema and a two-day non-participant

observation in the factory. Key informant interview was conducted with

officials of the Factories Inspectorate Division in Tema to examine their

regulatory and inspection role in workplace safety. In all five (5) officials were

interviewed, including the Municipal Chief Inspector in charge of Tema and

four other inspectors responsible for regular inspection of factories in the Tema

Industrial Area. The interviews were conducted with the Municipal Chief

inspector and the other four inspectors to find out the kinds of inspections

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they carry out, how frequent do

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they carry out factory inspections and the challenges they face in their work.

The key informant interviews were conducted because it afforded the

researcher to ask more questions and got more explanations which otherwise

would not have been captured in a questionnaire as an instrument. To ensure an

objective and balanced picture of the role of the Department of Factories

Inspectorate, there was also a focus group discussion and key informant

interview with the supervisors of all production departments in Pioneer Food

Cannery, in Tema. This was discovered from these supervisors who are

responsible for supervising the workers the frequency and efficiency of the

factory inspectors. In all five safety supervisors in the Employee Health and

Safety (EHS) department together with one supervisor from the other

production sections constituting the Plant Safety Team and the Safety

Committee were interviewed and involved in the focus group discussions.

Furthermore, 150 employees of the company were selected using a multiple

method of sampling including purposive, simple random and quota and

stratified sampling methods to find out from them how frequent the factory

inspectors came for inspection and their effectiveness in accident reduction in

the workplace. A purposive sample of both line and staff workers involving

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130

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workers from the production departments and 20 workers from the non-

production departments was used. The company was then stratified into the

various departments with the simple random sampling method used to select

the respondents.

In order to get adequate information on the compliance levels of workers with

safety regulations, a study tour was undertaken in the factory to get first-hand

information on the operation of the company and to observe the workers whiles

they were at work. In spite of the initial difficulties, permission was granted

and a two-day study tour of the factory the workers from beginning to the end

of production was undertaken to observe how workers comply with safety

mechanisms.

Results and Discussions of Findings

The Role of the Department of Factories Inspectorate (DFI) in Safety

Enforcement and Regulation

This section sought to outline the activities of the DFI in enforcing industrial

safety legislations. The analysis is based on the responses of the Municipal

Chief

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Inspector and four other factory inspectors of the DFI during interviews and

also relevant literature on the activities of the DFI.

In order to make the enforcement of safety legislations more effective and

efficient, regulatory agencies are given the task to carry out enforcement. In all

countries, there is an agency responsible for regulating safety legislations

through inspection. One of the main pillars for the Global Strategy on

Occupational Safety and Health (OSH) adopted by the International Labour

conference in 2003 is the application of a management systems approach to

OSH at the national level (Muchiri, 2005).

The responsibility of the state in ensuring the safety of the citizens in industry

is two-fold. Firstly, the state is expected to enact acts that could protect the

lives of workers in industry/factory. Such acts include the Factory and the

Labour acts. Secondly, the state is to ensure the enforcement of the provisions

of the laws. In Ghana, the Department of Factories Inspectorate was established

to enforce the provisions of the factories act to ensure the safety of workers in

factory.

The Factory Inspectorate Directorate, a division of the Ministry of

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Employment and Labour Relations, is responsible for the enforcement of

the Factories,

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Offices and Shops Act (Act 328, 1970). The Department of Factories

Inspectorate was established in accordance with carrying out the provisions of

the Factories Act of 1970, Act 328. According to the section 74(i) of the

factories Act, “the Minister may appoint a chief inspector and such other

inspectors and officers as he thinks necessary to carry out the provision of this

act.” (3) Every Inspector shall be given a certificate of his appointment issued

by the minister and when visiting any premises to which this Act applies shall,

if so required, produce the certificate to the occupier or other persons holding a

responsible of management at the premises.

In this light, the main role of the Department of factories Inspectorate (DFI) is

to keep a register of all factories and to enter any factory to inspect facilities

put in place to ensure the health, welfare and safety of people employed in the

factory. The DFI has the backing of the Act to prosecute any employer who

contravenes any section of the factor Act.

Frequency of Enforcement and Inspection Activities

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It is important to state that the mere existence of regulatory agencies in

industry does not make industrial safety regulations effective and highly

complied with by employees and employers.

When asked about the frequency of inspection and enforcement by statutory

agencies especially the DFI their supervisors, the majority of the respondents

(76 percent) noted that, inspections were infrequent.

The inspectors from the Department of Factories Inspectorate are tasked to

inspect, check and examine safety, health and welfare facilities in place for

safety of the workers. According to the workers, the officials from the

Factories Inspectorate normally inspect whether their safety facilities worn

while working and also the safety situation at work. The majority of the

workers confirmed the presence of the inspectors from the Department of

Factories Inspectorate. When the workers were asked about the frequency of

the inspection from the inspectors, the majority of them stated that the

inspections were done once a year. They further explained that the inspectors at

times do not come at all for the whole year. A confirmation from the safety

officer showed that the officials of the Factories Inspectorate were supposed to

conduct routine inspections once

Prepared by Isaac Mintah – Professor page 101 of


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every six months, followed by check inspection three months after the routine

inspection. However, they did come for inspection once in a year.

To confirm the claims of the workers and the safety supervisor an interview

was conducted with the Municipal Chief Inspector of the Department of

Factories Inspectorate and four other inspectors in Tema. According to the

Municipal Chief Inspector, the inspectors are supposed to conduct routine

inspection at least once every six months followed by a check inspection three

months after. He, however, stated that, because of their poor staff strength and

the larger number factories in Tema, the inspectors were unable to inspect the

factories frequently. He, therefore, confirmed the assertion of the workers that

the inspectors inspect the factories once a year. He further revealed that at

times, even for a whole year, they were unable to visit a factory, since the

attention of inspection seems to focus on the new emerging companies. From

the views of the workers, supervisors and the MCI, it is clear to state that the

Factories Inspectorate is unable to frequently conduct regular inspections at

Pioneer Food Cannery, Tema.

The MCI gave detailed information and description of the activities of the DFI

in Tema and enumerated some o the challenges confronting the department.

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According to the Municipal chief Inspector, there were about four main types

of inspections carried out by the departments of Inspectors. These care Routine

Inspection, Request Inspection, Hygiene Survey Inspection and Statutory

Examination.

He explained that the routine inspections normally examine the kind of safety

or welfare facilities that are supposed to be put in place in accordance with the

Factory Act (Act 328). He stated that routine inspections are supposed to take

place every six months. However, after the routine inspections there is a check

inspection to find out whether recommendations based on the routine

inspections are complied with. This check inspection is supposed to be carried

out or follow normally 3 months after the routine inspection.

Inspections are requested for by the factories to inspect some machines or

equipment they have installed and to examine how those machines can be

safely operated.

Hygiene surveys are normally conducted to inspect the mechanisms and

legislations put in place by management to ensure that proper hygienic

conditions exist for the health of workers. For instance, the inspectors inspects

the noise levels, heat levels, fumes levels, content of explosive liquids, slippery

Prepared by Isaac Mintah – Professor page 103 of


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nature of the production floor, the drinking water, canteen or where food is

served, ventilation, lighting, first aid and fire alarms, among others. The

inspectors are supposed to periodically (at a least once every three months)

inspect and examine the hygiene facilities to find out whether they meet the

requirement of the Factories Act.

Accident Investigation is another way of inspection. This is carried out after a

factories or a company reports an accident to the Directorate. The Inspectors go

into the factories to investigate the causes of such accidents and recommend

the necessary compensation to be paid by the Labour department to the victim.

However, in the case of Pioneer food cannery, due to the existence of a

department responsible for employee safety, accident investigation is easy.

This is because the Safety Department of Pioneer Food Cannery keeps all the

records of accidents and reports to the Directorate.

Statutory examination is the last type of Inspection done by the Department of

Factories Inspectorate. According to the Municipal Chief Inspector, the

examination is supposed to be done on heavy and sophisticated production

equipments such as boilers, vacuum flakes and other heavy equipments.

However, the DFI have contracted private agencies to conduct such inspections

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and examinations on behalf of the Directorate and the report made to the

companies of factories. In the case of Pioneer Food cannery, the main statutory

examination is done on their boilers, cold or freezing equipment and vacuum

cookers to ensure that they meet the standards. According to him, such

statutory examinations are supposed to done once every three months.

Challenges faced by the Department of Factories Inspectorate and Safety

Inspection Systems in Africa and Ghana

The Factories and Other Places of Work Act make the employer responsible

for ensuring that the work environment is safe and without risks to employees’

health. In Africa today inspectors are faced with challenges from new

technologies in workplace in addition to the traditional workplace hazards both

in the formal and the vast informal economy that is generally unregulated and

sparsely covered by inspection services. This has further been compounded by

the scarcity of support and operational resources, facilities and the reduction of

skilled and experienced inspectors (Muchiri, 2005).

In the traditional inspection approach, which has been practiced for a long

time, the occupier of the factory primarily waits for the government

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inspectors to

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inspect and point out the contravention against the law, sometimes requiring

that the occupier is taken to court before any tangible improvements are made.

If no inspectors show up, the workplace safety improvements implemented by

the employer are usually very basic, if any (Makhonge, 2005).

In Ghana, the name factory inspectors’ seem to limit their activities and

functions to only factories, offices and shops. There appears to be a serious

conflict between the other agencies such as the Ghana Standards Board without

any clear lines of approach to OHS issues and eventually facilitate the

development of industrial standards, codes and practices to guide employers in

the management of safety and health at all times.

According to the Municipal chief Inspector in charge of Tema, the Department

of Factories Inspectorate has only four inspectors in addition to the Municipal

chief Inspector. Considering the number manufacturing companies in Tema

that falls within the jurisdiction of the Department of factories Inspectorate the

number of inspectors is woe fully inadequate. This has accounted for the

infrequent inspection by the department.

The Municipal chief inspector the safety situation in Tema factories was good in

the case of some companies while for others the safety situation is bad. Some

Prepared by Isaac Mintah – Professor page 107 of


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companies have put in place effective employee safety mechanisms for the

protection of their employees. In most cases, the companies with effective and

well designed or established safety mechanisms in most cases complies with

the Department of factories inspectorate when it comes to inspection. However,

those without well-developed employee safety mechanisms do not want to

comply with the department when it came to inspection. They are reluctant to

give the accurate information about safety. He indicated that, they have

prosecuted some companies who have persistently failed to put in place certain

basic mechanisms for the protection of their employees.

He further stated that comparing most companies in Tema with those in the

North industrial area of Accra, the Tema companies have better employee

safety policies and mechanisms in place as compared to those in the North

Industrial area of Accra. The reason is that, the companies in Tema are owned

by British, American and other European countries who are concerned with

employee safety. In North Industrial area companies are owned by Arabs

mostly Lebanese, who are not so much concerned with safety of employee. The

Municipal chief Inspector had worked in the North Industrial area as a Factory

Inspector for almost twenty years, hence this assertion.

Prepared by Isaac Mintah – Professor page 108 of


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Since the focus of this study was on the Pioneer Food cannery as a company,

the researcher decided to find out from the Municipal chief Inspector about the

safety situation in the company. According to Municipal chief Inspector,

Pioneer Food Cannery have put in place several mechanisms and legislations

for the protection of its employees. He noted that in terms of safety, the

company’s safety policies, facilities and legislations are encouraging. On

visitations, he stated that his directorate is supposed to inspect the factory every

three months, but due to the heavy work load they are unable to conduct

regular inspections. According to him, the last time they inspected PFC was

almost a year ago.

He further went on to state that, in spite of the success of Pioneer Food

Cannery in employee safety there are some safety problems the company has to

deal with. He mentions for instance the high level of heat on the production

floor, the noise level and the slippery nature of the production floors. He also

mentioned that because most of the women in the racking section have stand on

their legs for long hours working, this may result in health problems. He also

complains about the non-compliance with safety mechanisms on the part of

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workers.

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According to the Municipal chief inspector one of the major challenges faced

by the Department in its activities was the inadequate number Inspectors for

inspection duties. With only 5 inspectors to about over 200 companies, the

department was unable to do regular inspection of all the companies. Thus, the

concentration of inspection is on the new emerging companies.

The factories inspectors also indicated that some of the challenges they faced

in their work is the lack of appropriate equipments for their inspection.

According to them, though department have some equipment to do its

inspection, they did not have all the appropriate equipment for inspecting for

instance noise and fume levels of certain companies. This makes the work of

the department inefficient.

They also stated that, the Factories Act of 1970, (Act 328), which empowers

the Department to inspect factories, was outmoded and this point was also

collaborated by the Municipal chief inspector. According to him, though the

Act mandates the Department to prosecute offending companies, it did not give

the department the necessary legal backings to do so.

Prepared by Isaac Mintah – Professor page 111 of


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He also said that, the Factories Act also do not have enough information on

new sophisticated machinery that are been brought into industry. There is

therefore need to amend the act. The department is also facing what the chief

Inspector called ‘professional challenges’. He explained that, most industries

are bringing in more sophisticated equipments and machinery but the

inspectors do not have the requisite skills and knowledge to inspect such

equipment about their safety. The effectiveness and efficiency of any safety

legislations depends on how often or frequent such legislations were enforced

by the agencies who are supposed to enforce them. This is because, when

employees and employers feel that the agencies responsible for enforcement of

such legislations carry out the enforcement frequently, they (workers) become

more committed to the compliance with such legislations and mechanisms.

Also supervisors are more committed to the enforcement of the regulations.

However, when the enforcement in terms of inspection is not done frequently,

the workers and management are less inclined to comply with such legislations

and mechanisms making them ineffective and inefficient.

Conclusion and Recommendations

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The study examined the effectiveness of the role of the Department of

Factories Inspectorate in the enforcement and inspection of the safety

legislations and regulations in factories. The findings from the study revealed

that the Department of Factories Inspectorate did not frequently inspect the

company’s safety policies and facilities. This has been due to the small number

of inspectors in the department as well as other problems such as the

professional challenges faced by the department where most of the inspectors

did not have the required skills and knowledge to meet the challenge of

inspecting of new technologies and sophisticated equipments brought into

industry by most manufacturers.

Furthermore, the study also identified that, the existing Factories Act of 1970

that gives authority to the department was outmoded in terms of its provisions

and powers given to the department and need to be amended to give more

power to the department to educate the factories on their safety programme. On

the whole the study revealed that, the rates of enforcements and inspection by

the state agencies responsible for employee safety regulations was very low in

terms of the frequency of their inspection and enforcement.

The paper made the following recommendations, that;

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 The Department of Factories inspectors should be provided more

logistics in terms of equipment, vehicles to enhance the activities of the

department. Also more inspectors should be appointed to meet the

increasing number of emerging companies or factories in Tema. Also

the activities of the Department of Factories Inspectorate should be

decentralized to give some of their activities to Tema Municipal

assembly’s Environment department to help in the inspection and

enforcement.

 The Factories Act of 1970(Act 328) must be amended to give way to a

more active and effective occupational health and safety Act or

legislation. A new occupational health and safety act should give more

power to the Department of the Factories Inspectorate to examine

occupational diseases and also educate companies on their

responsibilities in ensuring the safety of their employees. The

Directorate should also be empowered legally to prosecute companies

who violate the factories act.

Prepared by Isaac Mintah – Professor page 114 of


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REFERENCES

Appiah, S.O. (2014). Enforcement of Industrial Safety Laws in Ghana: A Study

of the Pioneer Food Cannery, Tema. Lambert Academic Publishing.

Andioni, D. (2006). The cost of occupational Accidents and Diseases.


Occupational Safety and Health Series 54, Geneva,
International Labour Office.

Association of Ghana Industries Report (2006), Accra: Government Printer.

Beach, DS. (2005). Personnel: The Management of People at Work. New York:
Macmillan Publishing Company.

Bittle, L. S., (2003). What Every supervisor should know. New York: Mc-Graw-
Hill Book Company.

Prepared by Isaac Mintah – Professor page 115 of


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Department of Factories Inspectorate Report, (2006). Accra: Government
Printer.

Dessler, G (2001). Personnel/Human Resource Management. New York:


Prentice Hall.

Ghosh, D (2000). Human Resources Development and Management. New Delhi:


Vikas Publishing Housing Ltd.

Government of Ghana (1970). Factories Offices and Shops Act (Act 328).
Accra: Government Printer.

Government of Ghana (1981). P. N. D. C. Law187, Accra: Government Printer.

Government of Ghana (2003). Industrial Relations Act (Act 651), Accra:


Government Printer.

International Labour Organisation (2006), Occupational safety and Health:


Country Profile, Geneva, 15, 43:109-225.

James C. K. (2007), “Occupational Health and safety” Daily Graphic July 9.


P.23.

Markhonge, P.W. (2005), Challenges in Development of Labour Inspection


Systems. African Newsletter on Occupational Health and Safety, 15:32-35.

Miller, T. A. Hoskin, A. F. and Yalung-Mathews, D. (2000).A procedure for


annually estimating wage losses due to accidents in the
U.S.A. Journal of Safety Research, 5, (18):101-119.
Muchiri, F. K. (2005). Occupational Health and safety programmes. African
Newsletter on Occupational Health and Safety, 5,
(15):27-28.

Prepared by Isaac Mintah – Professor page 116 of


122
Muntz E. E. (1990). ‘Industrial Accidents and Safety Work’ Journal of
Educational Sociology, 10, 14: 397-412.

Obeng-Fosu, P. (1991). Industrial Relations in Ghana: Law and Practise


Accra: Ghana Universities Press.

Simmonds, R. H. and Grimaldi J. V. (1956). Safety Management – Accident Cost


Control Illinois: Richard D. Irwin, Inc.

Singleton, W.T. (1983). ‘Occupational Safety and Health System: A three


country. Comparism’: Int. Labour Review, 1221, 1:155-
182.

United State Government Publications.

1945 America Labour Year Book


1950 National Safety Council
1970 Occupation Safety and Health Act.
1974 Accident Prevention Manual
1991 Accident Facts
1974 National Safety Council

World health Organisation (2006). The Global Burden of Diseases Harvard:


Harvard University Press.

Internet Sources
http:// www.axissupprt.Ltd html (Accessed: January 15, 2010)
http://www.anglogold.com html (Accessed: June 20, 2010)

Health and Safety Abbreviations

ACOP Approved Code of Practice

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ADR European Agreement Concerning the International Carriage of
Dangerous Goods by Road (see RID)
ALARP As Low as Reasonably Practicable (see SFAIRP)
BMA British Medical Association
BOHS British Occupational Hygiene Society
BSI British Standards Institute
BTS British Toxicology Society
C(WP) Construction (Work Place) Regulations
CBI Confederation of British Industry
CDG The Carriage of Dangerous Goods by Road Regulations
CDM Construction (Design & Management) Regulations
CE The letters "CE" do not represent any specific words but the
mark is a declaration by the manufacturer, indicating that the
product satisfies all relevant European Directives. Note,
however, that the mark only applies to products that fall
within the scope of
European Directives.
CFC Chlorofluorocarbons
CFM Cubic Feet per Minute
Amount of air flowing through a given space in one minute
One CFM approximately equals Two litres per second (l/s)
CHIP Chemical Hazards Information and Packaging
CO Carbon Monoxide
CO2 Carbon Dioxide
COMAH Control of Major Accident Hazards Regulations
CONIAC Construction Industry Advisory Committee
COSHH Control of Substances Hazardous to Health Regulations
CNS Central Nervous System
CRT Cathode Ray Tube
CTS Carpal Tunnel Syndrome
CVD Cardiovascular Disease
DB Decibel
DDA Disability Discrimination Act
DSE Display Screen Equipment
DSEAR Dangerous Substances & Explosive Atmosphere Regulations
EA Environmental Agency
EAW Electricity at Work Regulations

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EHO Environmental Health Officer

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EMAS Eco-Management and Audit Scheme
EMAS Employment Medical Advisory Service
FA Factories Act
FH(G) Food Hygiene (General) Regulations
FLT Fork Lift Truck
FPA Fire Precautions Act
FPWR Fire Precautions (Workplace) Regulations
GMC General Medical Council
GP General Practitioner
H&S Health & Safety
HAZCHEM Hazardous Chemical Warning Signs
HR Human Resources
NHIS National Health Insurance Scheme
HSC Health & Safety Commission
HSDSER Health & Safety (Display Screen Equipment) Regulations
HSE Health & Safety Executive
HASWA Health & Safety at Work Act
ICOH International Commission on Occupational Health
IOD Institute of Directors
IOSH Institution of Occupational Safety & Health
LOLER Lifting Operations and Lifting Equipment Regulations

LPG Liquid Petroleum Gas


MAPP Major Accident Prevention Policy
MEL Maximum Exposure Limit
MHOR Manual Handling Operation Regulations
MHSWR Management of Health & Safety at Work Regulations
MSD Musculoskeletal Disorder
MSDS Material Data Safety Sheet
NAWR Noise at Work Regulations
NEBOSH National Examination Board of Occupational Safety and Health
NHS National Health Service
NIHL Noise Induced Hearing Loss

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OHAC Occupational Health Advisory Committee of The Health & Safety
Commission
OHSAS 18001 BSI Standard for Occupational Health & Safety
OSRPA Offices Shops & Railway Premises Act
PAT Portable Appliance Test
PPE Personal Protective Equipment
PPEWR Personal Protective Equipment at Work Regulations
Ppb Parts Per Billion
Ppm Parts Per Million
PUWER Provision & Use of Work Equipment Regulations
QA/QC Quality Assurance/Quality Control
RCD Residual Current Device
RID European Agreement Concerning the International Carriage of
Dangerous Goods by Rail (see ADR)
RIDDOR Reporting of Injuries, Disease & Dangerous Occurrences
Regulations
RITA Record of In-Training Assessment
ROSPA Royal Society for the Prevention of Accidents
RPE Respiratory Protective Equipment
RSA Regional Specialty Adviser
RSI Repetitive Strain Injury
SBS Sick Building Syndrome
SFAIRP So Far As Is Reasonably Practicable (see ALARP)
TUC Trades Union Congress

VDU Visual Display Unit


WHO World Health Organisation
WHSWR Workplace (Health Safety & Welfare) Regulations
WRULD Work Related Upper Limb Disorder

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Thank you for reading this book.

I HOPE YOU ARE SAFE NOW

Isaac Mintah – Professor


Health & Safety Practitioner
Tel: +233543052955/2332705295
E-mail: isaacmintahantwi@gmail.com
Skype: Isaac-Mintah or tarkwagh@oulook.com
Facebook.com: Isaac Mintah – Professor
YouTube: Isaac Mintah Antwi

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