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Basis of Presentation. The following notes are based on experience of audits in the Chemical Industry – both operational audits and acquisition due diligence.
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Basis of Presentation • The following notes are based on experience of audits in the Chemical Industry – both operational audits and acquisition due diligence. • Much of the experience in this field has been for a multi-site international manufacturer based in Australia, and has covered sites in the UK, France, Spain, Austria, The Netherlands, Egypt, the USA, and Canada. • The plants concerned involve medium scale organic synthesis, are not large, but are complex, and use a wide range of flammable, toxic, corrosive and environmentally sensitive materials. • Based on a multi-site organisation, it is nevertheless relevant to any large industrial enterprise with multiple operations. • It is not unusual to combine such audits with a simultaneous audit of environmental issues. John Freeman Associates 2005
Preamble The author has little knowledge of, and no experience of High Energy Physics facilities. It is hoped however that the audience can draw something useful from experience in a world where molecules are of more concern than are particles. A gentle disclaimer John Freeman Associates 2005
Typical factory layout John Freeman Associates 2005
A selection of typical plant details John Freeman Associates 2005
What is it? • Similarities • It provides an external overview • It aims to confirm due propriety of “internal” procedures • Differences • It is Management initiated – not a regulatory imposition • A principal aim is improvement, training and development • The downside is human suffering – not negative dollars! It’s a bit like a financial audit John Freeman Associates 2005
Why do we have them? • To justify fine words in policy statements • A duty of care to employees and neighbours • To reduce risks to the business of untoward events • Management being seen to be serious about safety • For consistent interpretation of management policy • To improve safety by training and development • Internal cross-fertilisation of experience and ideas John Freeman Associates 2005
Corporate Concerns Hatfield UK High Speed Derailment Oct. 2000 July 10 2003 Two rail companies and six of their executives and staff have been charged with manslaughter following a police investigation into the 115 mph Hatfield rail crash……. Four fatalities and 100 injured John Freeman Associates 2005
Where in the overall safety scheme of things? Tools for Ensuring Safety MAJOR HAZARDS OPERATIONAL INTEGRITY WORKPLACE SAFETY DESIGN Hazard Analysis Risk Analysis HAZOP Protection Systems SYSTEMS Procedures Reporting Statistics Support ACTIVITIES Housekeeping Vigilance Notification Compliance Design Team Inspection Tour Health and Safety Audit John Freeman Associates 2005
Who is involved? Typical Organisation Structure Group Management Group HSE Manager Third Party Independent (Occasional) Data and Statistics Site A Management Site B Management Audit Team Site B Group HSE Manager (Chair) Safety Manager Operations rep (varies) Management rep Site A rep (option) (Third Party Independent) Safety Officer Safety Officer Operations Operations John Freeman Associates 2005
How do we go about it? Typically annual,the main steps are: 1 – Collation of statisticsand comparative performance review 2 – Circulate self-audit questionnaire to each site 3 – On-site review of responses and Action Progress 4 – Site tour by Audit Team 5 – Round up discussion and Action Plan John Freeman Associates 2005
What is the Auditor looking for? • Throughout the process, the Audit Team should be asking itself: • Are Systems and Procedures appropriate and adequate? • Are Systems and Procedures correctly followed? • Are the correct Documentary Records available? • Are the H&S Facilities and Equipment appropriate and adequate? • Is there a general awareness of Safety as an issue? • Is there a programme for safety training? • Could the organisation respond to a serious emergency? John Freeman Associates 2005
Typical Audit Team • Leader – Senior Safety Manager • Responsible directly to Top Management (e.g. Group Board) • Not responsible for operations • Local personnel • Local safety officer and a management representative • Operating supervisor of a specific area under review • Visiting representative from another site/area • Others (if needed) • To give full experience cover of specialist technology and general operation/engineering (e.g. Chemist + Engineer) • Independent Neutral (Say every third audit or so) John Freeman Associates 2005
Actions and Feedback • Action Programme to correct deficiencies identified • Agreed actions (Where the team has authority to decide) • Recommended Actions (If 0ther authorisation is needed) • Include Target dates • Progress Reviews of previous action programme • Record Completions • Provide early prompts • Highlight missed dates • Record decisions not to proceed – with reasons John Freeman Associates 2005
Safety Statistics • Typical statistical analysis would include • Injury Frequency Rates – Lost time, Medical treatment • Injury Severity Index – extent of lost time • Injury analysis - by type, location, worker group To be meaningful, statistics must be consistent and accurate Central recording and analysis ensures consistency Care with definitions such as “Lost-time injury” – how many days? Figures are only useful if lessons are learned and improvement targets imposed Rigorous recording is essential John Freeman Associates 2005
Procedures – availability and adherence Defined procedures must be set down • Standard Operating Procedures • Default procedures for all main operations • Are they Available, Accessible and Clear • Use them or change them – don’t ignore them • Obtain user views • Maintenance Safety Procedures • Permit to Work System – hot work, confined spaces, heights • Isolation and Lock-off arrangements – a critical area • Authority to sign – training essential John Freeman Associates 2005
Training Procedures • Safety Training • Management, Factory workers, Office workers • Specialist functions (e.g. Fire, Rescue) • Induction programmes • New Employees • Temporary Employees • Contractor’s personnel • Visitors John Freeman Associates 2005
Safety Systems • Change Control System • Design vetting of any modification to plant, process or alarm and trip functions • Accident Reporting, Investigation and Remedial Actions • Abnormal Incident Reporting • Reporting, Investigation and Remedial Actions as for Accidents • Inspection and Testing programmes • Pressure Systems, Lifting Equipment, Access Equipment, etc. Some of the more important Systems to check John Freeman Associates 2005
Change Control Flixborough – UK 1974 Plant modification destroys original design integrity Failed flexible connector Aftermath John Freeman Associates 2005
Emergency Procedures • Response Plan for a major emergency • Does it exist and is it well known and understood • Liaison with local services – e.g. Fire Service? • Internal Emergency Actions • Fire fighters – trained? equipped? • First aiders – availability and training • Evacuation drill – clearly posted? practiced? • Notifications – to management, authorities, local services • Nominated person? Standard routine? Investigate preparedness for emergencies John Freeman Associates 2005
Health and Safety Facilities • First aid • Location and Equipment • Trained personnel and call-out arrangements • Fire fighting and Rescue • Extinguishers, breathing equipment, trained personnel • Security • Visitor control – record of people on the site • Intruder prevention John Freeman Associates 2005
Health monitoring policy • Occupational Health Issues • General medical checks and hearing tests • On first employment • At regular intervals • Specific Risk Areas • Exposure to chemicals – measurement of ambient levels • Known potential health hazards • Biological checks Requirements depend on local circumstances John Freeman Associates 2005
Some general comments • Avoid a “blame” culture • Encourage positive approach • Inter site participation helps • Numerical basis for performance assessment • Not generally successful unless based on objective measures • Subjective assessment is not usually satisfactory • Site visits help to reinforce comments • Photographs of areas of concern • Review meetings are as much about Training as Communication John Freeman Associates 2005
Especially Vulnerable Situations • Growth by Acquisition • High Staff Turnover • Regular use of Temporary Staff • Extensive use of Contractors • Language Differences John Freeman Associates 2005
In Conclusion A systematic and regular audit of Safety Systems and Performance can lead to significant improvements. Benefits include: Consistent and effective implementation of policy. Protection against corporate exposure. Reductions in accident rates. Improvements in Safety Training and Development. Cross fertilisation in Safety thinking. Increased awareness of the importance attaching to Safety issues. John Freeman Associates 2005
Don’t be like this guy! John Freeman Associates 2005