Seminar 5Safety Management System 6 June 2006 Mike Connell Dannae Campbell Sarah Sinclair Wayne Williams
What is a Safety Management System? • “An orderly arrangement of interdependent activities and related procedures that drives an organisation’s performance.” 1996 • “A Safety Management System is an integrated set of work practices, beliefs and procedures for monitoring and improving the safety and health of all aspects of your operation.” CASA, July 2002
What is a Safety Management System? • “That part of the overall management systems which includes organisational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the OHS policy, and so managing the risks associated with the business of the organisation.” AS/NZS 4801, 2001
What is a Safety Management System? What do we make of this? • A mixed bag • Software not hardware (paper warfare) • Can be repetitive or mundane • But VITALLY important!!
Security Policy Safety Policy Road Safety Plan Alcohol & Drugs Policy Audit Plans Safety Drills What is a Safety Management System? Continuous Improvement Policy Mgt. policy Process Safety (HSE Cases) Task Structure No Structure 5
Our Challenge today • Explain what is needed under the Regulations • Show what makes a good SMS • Reconfirm the importance of the SMS at a MHF • Show what to look for in Round 2 review and revision of the SMS • AND make it interesting!!
Program for today • Regulations • What do they ask for? • What does WorkSafe look for? Break • SMS approaches in use at MHF’s • SMS elements required for risk control • Questions Break
Program for today • Case Study of SMS element failure (Piper Alpha) • Experience from Round 1 and Annual Inspections Break • Auditing and Performance Monitoring • Operator presentation – Round 2 review & revise SMS Melbourne Water Ms Charmaine Quick • Guidance for Round 2 submission • Questions
Safety Case Assessment and the MHF Regs
What is Safety Case Assessment? A process which uses desktop assessment and onsite verification to see if you comply with the regulations. i.e. meet the performance standard Our performance standard for assessing your SMS: The MHF regulations and known SMS Standards which you may subscribe to. (eg. Australian Standards, your own corporate policies) Our assessment tools: Focus Rule 7 – Safety Management Systems, Focus Rule 8 – Safety Case Demonstrations and your own SMS KPI’s
Why do WorkSafe verify the SMS? Verification obtains evidence to show that your SMS is implemented and functional as you describe it. We also verify that your employees • have access to the SMS • understand their duties in following procedures • have been provided information, instruction and training • where practicable have been consulted in SMS development/ changes • have been involved in review/revise process
Examples of information needed to assess & verify your SMS • Your SMS summary and selected procedures • Samples of auditing and proof of corrected non conformances • Proof of monitoring of SMS KPI’s • Work Safe’s observations from oversight and annual inspection • Review of changes as a result of the review and revise • Training records • Interviews with your employees, contractors and HSR’s • Position descriptions • Contractual details if the management of control measures is outsourced
Why do WorkSafe perform these processes ? Because ofyour needto demonstrate compliance before you can get a licence What are the drivers for demonstration?
Drivers for demonstration - The CEO signed statement Reg 402(3)(a) and (d) A Safety Case must contain a signed statement by which the operator certifies that - The summary of the SMS is an accurate summary The persons who participate in the implementation of the SMS have the knowledge and skills necessary to enable them to perform their allocated tasks and discharge their allocated responsibilities in relation to the SMS
Drivers for demonstration - Granting of a licence 803(1)(a) The Safety case has been prepared in accordance with regulation 402 Reg 402 The content of the safety case must be sufficient for the purposes of (a) Demonstrating that the safety management system provides a comprehensive and integrated management system for all aspects of control measuresadopted in relation to hazards and major incidents Have you given your assessor enough information for them to confidently state that demonstration is adequate?
Because WorkSafe can suspend or cancel licences Regulation 808(2) The Authority may suspend or cancel a licence if the Authority is satisfied that - (a) The SMS for the licensed MHF no longer provides a comprehensive and integrated management system for all aspects of control measures adopted in relation to hazards and major incidents
Granting of licence The Authority may grant a licence if, 803(1)(b) The applicant has complied with provisions of part 3 of the Regs; Part 3 of the MHF regs: SAFETY DUTIES OF THE OPERATOR
Safety duties of operators Regulation 301(1) The operator of a major hazard facility MUST ESTABLISH and IMPLEMENT a SMS for the major hazard facility When is your SMS established? When is your SMS implemented?
Safety duties of operators Regulation 301(2) The operator MUST USE the Safety Management System as the PRIMARY MEANS of ensuring SAFE OPERATION of the Major Hazard Facility Does not say ‘preventing Major Incidents’ What does “primary means” mean to your site?
Safety duties of operators Regulation 301(3) The Safety Management System so established MUST • provide a COMPREHENSIVE and INTEGRATED management system for all aspects of CONTROL MEASURES adopted under Part 3 (b)be DOCUMENTED (c)Be so set out and expressed that its contents are readily ACCESSIBLE and COMPREHENSIBLE to persons who use it Are you confident that your SMS supports your CM’s for all aspects? Is your SMS providing comprehensive (effective) management of your control measures?
Safety duties of operators Reg 301(4) The SMS MUST STATE the operator’s safety POLICY, including the operator’s broad AIMS in relation to the SAFE OPERATION of the major hazard facility; State the operator’s SPECIFIC safety OBJECTIVES; DESCRIBE the SYSTEMS and PROCEDURES by which these OBJECTIVES are to be ACHIEVED; Describe how COMPLIANCE with PART 3 & PART 5 is to be achieved; (part 3: Safety duties of operator), part 5 (consulting, informing instructing and training) INCLUDE all matters specified in SCHEDULE 2
Safety duties of operators Schedule 2 – Additional matters to be included in the SMS Safety policies and objectives Organisation and personnel Operational controls Compliance with part 3 & part 5 of the regulations Management of change Principles and standards Performance monitoring Audit Performance monitoring and Audit will be covered later in this presentation
Safety duties of operators Reg 301(5) The operator must REVIEW and as necessary REVISE the Safety Management System if • a MODIFICATION is made to the major hazard facility; • a MAJOR INCIDENT occurs at the major hazard facility; • whether or not the circumstances mentioned in paragraph (b) or (c) occurs, AT LEAST ONCE EACH 5 YEARS. To what extent are you going to review/revise your SMS? Document this in your review/revise plan
Safety duties of operators Reg 307(1)(d) Safety roles for employees The operator of a MHF must develop a role for the operator’s employees including the specific procedures they would be required to follow to assist the operator in relation to Establishing and implementing a SMS under regulation 301. Who writes and/or updates your SMS? Who implements your SMS? Who is responsible for making sure your SMS is adhered to?
Interpretation of terms Comprehensive? Describes the way that all safety issues including control measures are managed Clear link between CM management and the SMS Integrated? The structure is logical, systematic Logical tie-ins to other management systems Corporate systems do not contradict onsite systems Comprehensible? Abbreviations and terms used mean something to employees Consideration of language issues
Interpretation of terms Implemented? Procedures are approved and in circulation Evidence is available – completed forms and/or checklists Employees are trained and knowledgeable Accessible? Employees are aware how to obtain the most up to date or relevant procedures Employees can obtain the SMS information needed to support control measures
Consulting, informing, instructing and training Reg 501 Consultation with health and safety representatives 501(1)(d) The operator of a MHF who is establishing and implementing a SMS under regulation 301 must if practicable consult with the HSR of each designated work group to which the operator’s employees belong What has happened now with the new Act?
OH&S Act 2004 – Duty of employers to consult Part 4, section 35(1) Duty to consult is now wider than MHF regulations originally intended for SMS Where practicable employers need to consult with employees* on: • Proposed changes about conduct of work • Provision of information/ training • Identifying/assessing hazards • Making decisions about controls * Employee includes, independent contractors and any employees of independent contractor
Consulting, informing, instruction and training 502(1) (d) The operator of a MHF must provide their employees with such information, instruction and training in relation to • the content and operation of the SMS generally as are necessary to enable the employees to perform their work in a manner that is safe and without risk to health
Consulting, informing, instruction and training 503 (b) Further information and access to documents The operator of a MHF must ensure that the SMS, the SC and the Emergency Plan or copies of these documents are readily accessible to the operator’s employees Are you confident that your employees always have easy access to the most up to date information?
Duties of employees Reg 601 (1) (a) An employee at a MHF must follow the operators procedures relating to the prevention and control of major incidents within the MHF Your SMS should tell your employees what they have to do to remain safe!
The Safety Case Reg 402(1)(a) Content of the SC A safety case prepared or revised under this Part must – Contain a summary of the content of the SMS established under regulation 301 Are you satisfied that your summary adequately describes how your SMS works?
The Safety Case Reg 402(1)(c) Include the information specified in schedule 4 A statement as to how existing control measures and the SMS are capable of maintaining safe operation of the MHF At all points in the SC where the matter addressed is covered by the SMS a clear reference to the relevant part of the documented SMS A description of those parts of the documented SMS which address the maintenance of the SMS (that is, its ongoing effective implementation and its ongoing improvement) The SC describes your SMS and justifies decisions based on assessment of risk
Safety Management Systems Theory & Practice Sarah Sinclair Business Improvement Unit, WorkSafe Victoria
Definition of a Management System • Orderly arrangement of interdependent activities and related procedures that drives an organisation’s performance • SMS - controlling risk through a management process
AS 4801 OH&S Environmental Policy Policy Planning Planning Implementation Implementation & Operation & Operation Checking & Checking & Corrective Actions Corrective Actions Measurement & Evaluation Management Management Review Review Common Elements of Management Systems ISO 14001 Environmental Management Systems BS OHSAS 18001 Safety Management Systems
Continual Improvement OHS Policy Planning OHS Management System Model - AS 4801 Management Manageme Review Revie nt g g Implementation Implementation Measurement Checking & Operation Correctiv & Evaluation & Actio
Orderly Arrangement - Key Elements of a SMS HSE Model (HSG65)
Orderly Arrangement - Key Elements of a SMS Policy Effective health and safety policies set a clear direction for the organisation to follow.
Orderly Arrangement - Key Elements of a SMS Organising An effective management structure and arrangements are in place for delivering the policy.
Orderly Arrangement - Key Elements of a SMS Planning There is a planned and systematic approach to implementing the health and safety policy through an effective health and safety management system.
Orderly Arrangement - Key Elements of a SMS Measuring Performance Performance is measured against agreed standards to reveal when and where improvement is needed.
Orderly Arrangement - Key Elements of a SMS Auditing and Reviewing of Performance The organisation learns from all relevant experience and applies the lessons.
PLAN DO ACT CHECK More simply…. Health & Safety
OH&S Policy Planning Implementation & Operation Checking & Corrective Actions Management Review Activity • Allocate all Schedule 2 SMS requirements into the key elements of your SMS (regardless of what you call the key elements)
Answers…. Frequently Asked Questions • How big should the SMS be? • What should the SMS be called? • Should the SMS be integrated with other systems eg quality? • How many topics/groupings should there be in the SMS? • Should the SMS be on paper or electronic? Be appropriate for your site
Which SMS is best? History of your SMS? • Corporate (appears from on high) • Built from ground up • Tacked onto quality system (ISO 9000 or Lloyd’s accredited) • Bought off-the-shelf model from consultant • SafetyMAP • AS 4801 • From supplier or customer Suit your site (eg number of people, type of hazards, experience with systems etc) Meet MHF Regulations
SAFETY ROLE FOR EMPLOYEES (Reg 307) Consulting, Informing, Instructing Training (Part 5) MHF Regulations & SMS SAFETY MANAGEMENT SYSTEM (Reg 301) IDENTIFY MAJOR INCIDENTS & HAZARDS (Reg 302) ASSESS RISKS – LIKELIHOOD & CONSEQUENCE (Reg 303) DECIDE ON CONTROL MEASURES (Reg 303(4)) IMPLEMENT CONTROL MEASURES (Reg 304) MONITOR AND REVIEW (Reg 306)
SMS & Control Measures Regulation 301(3) The SMS must provide a comprehensive and integrated management system for all aspects of control measures adopted under Part 3. Control Measures SMS