Managing implementation of control measures

Chain reaction

7. Managing implementation of control measures

This Lesson is made up of 5 units. The objective of this unit is to

• Communicate and raise attention to the stakeholders on the hazards in accordance with organisational procedures.

• Present proposed control measures to relevant stakeholders for formulation of implementation plan.

• Communicate the control measures and implementation plan to the relevant stakeholders.

• Monitor the implementation and effectiveness of control measures.

• Report to management on status of implementation of control measurement Implementation

Residual risks are the remaining risks after implementation of risk controls. The risk assessment team should ensure that residual risks are acceptable and manageable and highlight the residual risks of each of the controls. For example, if the risk control involves the use of safety harnesses and lanyards (a type of PPE), one of the residual risks is that the workers may not anchor the lanyards to protect themselves. In this case, the risk assessment team may highlight training (administrative control) as a further measure to ensure that residual risks are further minimised.

Once all the risk controls are selected, the risk assessment team needs to identify the action officers and follow-up dates. The results of risk assessment must be approved and endorsed by the top management. The employer should as far as is practicable, implement the recommended risk control measures as soon as possible.

Arising from the risk assessment, SWPs for work which may pose safety and health risks should be established and implemented. The SWPs should include the safety precautions to be taken in the course of work and during an emergency, as well as the provision of PPE.

A written description of the risk assessment must be kept for reference for 3 years. The Risk Assessment Form can be used for record keeping, training and reviewing. All risk assessment records should be concise and kept in a register. The records should include the following information:

• Names and designations of risk assessment team members

• Inventory of work activities by process or location, associated with machinery, equipment and chemical;

• Hazards identification for each work activity, and possible types of accident or incident • Existing risk control measures

• Risk level for each hazard

• Recommendations on additional risk controls required

• Persons involved in implementing the measures on risk reduction

• Signatures, date and designations of the persons conducting risk assessment

• Signature, date and designation of management approving or endorsing the assessment

Communication

Throughout the risk management process, communication amongst stakeholders at every step is essential. Every employer, self-employed person and principal (including contractor and sub-contractor) must take all reasonably practicable steps to inform his employees or any other persons at the workplace who may be exposed to safety and health risk. They should be informed of the following:

• the nature of the risk involved,

• the measures implemented to control the risk, • applicable safe work procedures.

Copyright © 2012 NTUC LearningHub Pte Ltd. All rights reserved 152 Whenever the risk assessment is revised, or when there is a significant change in work practices or procedures, the employees or other persons who may be at risk must be informed accordingly.

The stakeholders have been covered in earlier topics. Communication of control measures to relevant stakeholders, which may include:

Organisation such as • Suppliers • Clients • Developers • Designer consultants • Contractors Individual such as • Workers • Supervisors • Foreman • Engineers • Architect • Managers

The mode of communication can be through the following: WSH committee meetings

One of the key functions of the WSH committee meetings is to promote safe conduct of work. The results of the risk assessment can be shared in these meetings,

Relevant parties feedback sessions

Feedback sessions help to gather feedback from the employees on the control measures implemented. Employees can provide suggestions about how to solve WSH problems. Employee participation enables the employee to contribute on how the work can be undertaken safely. Employees should be encouraged to:

• Ask questions. • Raise safety concerns. • Make safety recommendations.

• Be a part of the problem-solving process. Small group meetings

Meeting is an assembly of individuals to debate certain issues and take decisions. It allows for dialogue between the members. Examples of meetings include WSH committee meetings, coordination meetings, team meetings, etc. These meeting would be appropriate to tackle specific work groups or trades.

One-on-one discussions

This is a briefing conducted by the immediate supervisor to his subordinate. This would be appropriate when the supervisor wants to coach his subordinates on the safe method of work and on the job training.

Reports and email

Internal safety circulars and bulletins can be notified through intranet & email to reach the target audience in the shortest time. The disadvantage could be the literacy level of the employees and the availability of time and resources such as computers to access them.

The implementation of the control measures should be monitored through one of the following:

Schedule of implementation

An action plan should be prepared to implement the measures. The plan should include a time line of implementation and responsibilities of persons implementing the safety and health control measures.

Resources needed

Management should ensure that adequate resources are available for the implementation of the risk controls. The resources needed would be.

• Manpower - allocating necessary competent persons to assist in the implementation such as trainers, WSH professionals, etc

• Financial - setting aside a budget for safety to acquire the necessary manpower, space, equipment, etc.

• Equipment and tools allocation - e.g getting the necessary equipment such as training equipment, instruments, etc.

• Space allocation - e.g getting the necessary space for training, first aid, demonstration, evacuation, etc.

• Time - the availability of time in terms of implementation with respect to the production schedule considering the allocated resources.

Resources can be considered adequate if they are sufficient to carry out the risk control programmes and activities, including performance measurement and monitoring. For organizations with established WSH management systems, the adequacy of resources can be at least partially evaluated by comparing the planned achievement of WSH objectives with actual results.

Work in progress

The plan should be monitored regularly until all the measures are implemented. This can be done by maintaining an updated list of daily activities on site.

Evaluation

Regular auditing is required to ensure that risk control measures are functioning effectively. Regular review of the risk assessment plan is critical. While employers are required to review their plans every three years, a review should take place whenever:

• New information on safety and health risks surfaces; • There are changes to the area of work and / or • After any accident / incident.

The risk assessment team should undertake the same 3 steps (hazard identification, risk evaluation and risk control) when conducting a risk assessment review. The effectiveness of the control measures should be evaluated using the following criteria:

Reduced WSH risks

The implementation of the corrective and preventive action would translate to better risk controls bringing about a reduction in risk levels. The new risk levels should be evaluated and the risk assessments updated accordingly. For example from a medium risk to a low risk level.

Robustness

This indicates whether the corrective and preventive actions would be strong enough to withstand the shortcomings.

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This indicates whether the corrective and preventive actions would fail from the required norms due to certain factors such as environmental conditions, etc. e.g. Operator could be missing one step under the SOPs.

Reproducibility

This indicates whether the actions can be repeated at other areas with the same robustness and reliability.

Ease of use

This indicates whether the actions are user friendly and thereby resulting in better compliance levels.

Any side-effects

• Interference with productivity – This evaluates if the actions reduces the productivity level and cause a loss in business, which the organisation may not prefer.

• Creating hazards elsewhere – This evaluates whether the actions may bring down the risk level but may pose as a hazards somewhere else.

Reporting

The management should be updated on the status of implementation of control measurement, which may include:

Tracking the implementation of corrective / preventive actions

The implementation of corrective / preventive actions can be tracked using appropriate action items tracking methods which include computer programmes e.g Microsoft Access, Outlook, etc or manual e.g through records. The closure of actions items can be informed by person in charge through one-on-one basis or through the consultation and communication process. This can be further be verified through inspection and document reviews.

Persons affected by the non-conformances or audit findings

Persons responsible for taking corrective and/or preventive actions - Depending on the area of control such as process and physical areas, relevant personnel should be assigned to close the corrective / preventive actions. The time frame for the completion of the corrective / preventive actions should be agreed as well. This would reflect the outstanding action items and the corresponding action officer.

Risk assessment register – The non-conformances would require a review in the risk assessments and hence require to be updated. The risk assessment register would reflect the update.

Safe work procedures – Changes in risk assessment would require a review in the safe work procedures and hence require to be updated. The list of safe work procedures would reflect the update.

Training records – Employees have to be trained upon changes to risk assessments. The training records would indicate the number of persons trained, the duration of training, types of training attended, effectiveness of training, etc. This would reflect the company’s training status. The records would indicate the number of personnel trained in a particular training programme and how many more have to be trained.

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Learning Activity 7

Group Exercise - 30 minutes

Choose any 10 risk controls and identify how would you communicate the following to the various stakeholders?

S/No Risk Controls Communication Ways to monitor Evaluate effectiveness 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. Deleted: ¶ ¶ ¶ ¶ ¶ ¶ L Deleted: ¶ ¶ Deleted: _

Texts

• Reese, Charles D. (1999). Handbook of OSHA Construction Safety and Health. Lewis Publishers. ISBN 1566702976.

Websites

• Ministry of Manpower – http://www.mom.gov.sg/workplace-safety- health/Pages/default.aspx

• Workplace Safety and Health Council -

https://www.wshc.sg/wps/portal/resources?action=infoStopHome&openMenu=-1

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WSH (Workplace Safety and Health Officers) Regulations 2007

Factories

WSH (General Provisions) Regulations 2006

Factories and owners of pressure vessels

WSH (Construction) Regulations 2007 All worksites

WSH (First Aid) Regulations 2006

Factories, laboratories, ship in harbour, premises within airport

WSH (Incident Reporting) Regulations 2006 All workplaces WSH (Risk Management) Regulations 2006

Workplaces covered under the First Schedule of the Act WSH (Composition of Offences) Regulations 2006 All workplaces

WSH (Transitional Provision) Regulations 2006 - WSH (Offences and Penalties) (Subsidiary Legislation under Section 67(14)) Regulations 2006

WSH (Registration of Factories) Regulations 2008 Factories WSH (Workplace Safety and Health Committees)

Regulations 2008

Factories

WSH (Abrasive Blasting) Regulations 2008 Workplaces covered under the First Schedule of the Act WSH (Explosive Powered Tools) Regulations 2009 Workplaces covered under

the First Schedule of the Act WSH (Confined Spaces) Regulations 2009 Workplaces covered under

the First Schedule of the Act WSH (Safety and Health Management System and

Auditing) Regulations 2009

Factories

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Factories (Medical Examinations) Regulations Factories with exposure to certain chemicals, excessive noise, compressed air

Factories (Noise) Regulations Factories with excessive noise Factories (Operations of Cranes) Regulations Factories involving crane, mobile

crane and tower crane

Factories (Persons-In-Charge) Regulations Factories with steam boiler, steam engine or internal combustion engine

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Factories (Scaffolds) Regulations 2004 Factories with scaffolds

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Category of offender Maximum Fine Maximum

Imprisonment

Conditions

Workers

For failure to use personal protective equipment or misuse of any safety appliance 1 conviction - $1,000 2nd or subsequent conviction - $2,000

Individual $400,000 2 years Either or

both Repeat offenders For a 2nd or subsequent conviction for the same offence that causes the death of

another person Corporate

body $1 million

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R 63 - Revocation

The Factories (Scaffolds) Regulations 2004 (G.N. No. S 19/2004) are revoked.

In document Manage WSH Risks in Construction Industries - Courseware Learner's Guide V2 0 (Page 156-165)