If your belt buckle is feeling a little tight it is most likely the result of too many Christmas delights. The New Year presents an opportunity for us all to make changes.
In addition to cutting back on calories, boardrooms and site managers can continue to cut back on bad safety practices.
The story of 2015 is yet to be written and, by instilling good process safety standards atop of your organisation, we can make the following 12 months our safest yet.
Here’s a few suggestions for your New Year’s Resolution list:
1# Process safety: lead by example
Leadership is essential in developing a positive process safety culture. The apple never falls far from the tree, so it is imperative that boardrooms sound positive safety tones which echo across the whole of the organisation from directors, to site managers, to operators.
The operation must then work as a collective body to ensure safety remains atop of the agenda, rolling out effectively implemented and robustly maintained systems.
2# Work hard to make the regulator happy
The Health and Safety Executive placed a renewed focus on process safety during the past 24 months with a tightening of regulations. So, whilst industry should be applauded for its efforts thus far, we still have much to do.
3# Roll out a dedicated programme of training
There is, of course, no such thing as a perfect health and safety procedure. Companies must therefore regularly evaluate their safety culture and performance, continually improving resources to enhance key skills and knowledge around process safety.
Making profit is important, but safety is crucial. After all, a process will be further delayed by an avoidable accident.
4# Start each day by asking: are we doing enough?
The high hazard sector is, for the most part, a safe one and we are to be proud that the majority of companies work hard to ensure the safety of their site, staff and surrounding communities.
Whilst incidents such as Buncefield are rare, rare doesn’t mean extinct. Catastrophic events can be prevented if we shift our focus to prevention rather than reaction. Learning from incidents such as the Buncefield blast means we can create and implement process safety strategies designed to avoid recurrences.
5# Become more sociable
Organisations must break down corporate barriers and engage in process safety knowledge sharing with each other.
Some sites already do. Others, however, are less receptive. Those who sit on this side of the fence are often motivated by competitive protectionism – a fear of trade secrets being leaked, clouding otherwise better judgment.
We therefore need a culture change at the boardroom level to accelerate an industry-wide drive to prevent and mitigate major incidents. The idea is simple: in addition to learning from past incidents or ‘near misses’ at a company’s own site, industry leaders should talk to each other about their own experiences.
Resolving to make 2015 the year of health and safety
With 2015 upon us, we can now truly turn this talk into action, rolling out programmes of continual improvement from the top of our organisations.
Your New Year’s Resolution list should be personal to you, tailored to the needs of your site. Start by asking what you’ve already done. What’s working? What needs improvement? Are there any gaps and what more can we do during the year ahead?
Studies show that 90% of resolutions are broken within two weeks of the New Year. So let’s show the world that we mean business and lead by example.
After all, decisions made at a boardroom level are felt across the whole of an organisation and must therefore shore up safety on the ground.
The Health and Safety Executive has published updated guidance which aligns the rules governing the unloading of petrol from road tankers with recent regulatory changes.
The guidance, which is intended for those engaged in the delivery and unloading of petrol at filling stations, has been simplified in line with the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR).
Key messages include:
- The importance of the risk assessment
- Roles and responsibilities of the various parties involved in petrol delivery
Changes since the last edition include:
- New ACOP text to ensure employers have in place, and maintain, systems to contact the emergency services
- Removal of specific guidance on working at height as this is not a requirement of DSEAR
More information is available at the Health and Safety Executive’s website.
The chairperson of the US Chemical Safety Board has underscored “the need to do more” to improve health and safety standards across industrial workplaces in America.
Rafael Moure-Eraso’s comments came as part of a written testimony to the Joint Committee: Senate Committee on Environment and Public Works and the Senate Committee on Health, Education, Labor, and Pensions.
Dr Moure-Eraso, in the hearing entitled ‘Oversight of the Implementation of the President’s Executive Order on Improving Chemical Facility Safety and Security’, said the CSB had long advocated process safety reform.
“In January 2014,” writes Dr Moure-Eraso, “I authored a New York Times opinion article entitled ‘The Next Accident Awaits’ where I noted that the current process safety regulatory system is in need of reform.
“Tragically there was not too much time spent waiting for the ‘next accident’ – in November 2014 four workers were killed outside Houston in a large-scale toxic gas release from a DuPont pesticide plant. The CSB is now investigating this accident.
“After the West explosion, President Obama issued an executive order requiring federal agencies to review safety rules at chemical facilities.”
Processing safety improvements
Dr Moure-Eraso was “encouraged” at the “leadership” shown by the White House, OSHA, and EPA in taking the “first steps” towards reforming US process safety management regulations.
“To date, both OSHA and the EPA have issued Requests For Information (RFI’s), and may soon initiate rulemaking to revise the PSM standard and the RMP regulation. I support these efforts. The CSB submitted a comprehensive response to each RFI detailing needed improvements to the existing federal process safety management regulations.”
Even so, he added, process safety management regulations had undergone “no substantive improvements since their inception in the 1990s”.
“Moreover, other existing OSHA standards governing explosives like ammonium nitrate, flammable and combustible liquids, and hot work are even older, dating from the early 1970s, and are based on fire code guidance from the 1960s.
“These regulations have not been updated since, even as the voluntary fire codes have undergone many cycles of revision and improvement.”
Preventive safety systems
Dr Moure-Eraso said the current system was designed to respond to workplace safety incidents rather than stopping them before they happen.
“The CSB has noted in its recent investigations of major incidents that both the OSHA Process Safety Management (PSM) standard and the EPA Risk Management Plan (RMP) Program regulations appear to function primarily as reactive and activity-based regulatory schemes that require extensive rulemaking to modify, resulting in stagnation despite important lessons from accident investigations, advancing best practices, and changing technology.”
As such, Dr Moure-Eraso said “more must be done” to ensure the introduction of process safety management systems which protect worker safety, public health and the environment.
“There must be greater emphasis from regulators and companies on preventing the occurrence of major chemical accidents through safer design and elimination of hazards.”
Chevron Refinery fire and explosion
Dr Moure-Eraso went on to discuss the 2012 fire and explosion at the Chevron Refinery in Richmond California, saying it had triggered a series of regulatory reforms across the state.
These, he believed, could serve as a model for the modernisation of process safety management at a federal level.
Dr Moure-Eraso explained: “Chevron’s own employees had repeatedly notified company officials of the corrosion hazard (which ultimately caused the failure of a major pipe carrying hot hydrocarbons), but unfortunately this did not result in replacing the corroded piping with inherently safer, corrosion-resistant materials that were known to industry and recommended in voluntary practices.”
“California is taking important steps towards modernising process safety management by funding additional PSM inspectors and by issuing draft process safety management regulations that address many of the attributes of a stronger regulatory system identified by the CSB’s investigative reports.”
“In October,” he continued, “California’s legislature passed, and Gov. Jerry Brown signed, a sweeping law requiring the state’s petroleum refineries to provide regulators with detailed information concerning extensive maintenance overhauls and repair operations – known in the industry as turnarounds. This important reform will help prevent accidents by ensuring that needed repairs will be more promptly conducted rather than deferred as we found in our Chevron investigation.”
Dr Moure-Eraso “commended” California for taking action in the wake of the Chevron fire.
“In my view, had these new laws and regulations been in effect before August 2012, California’s Division of Occupational Safety and Health, or Cal/OSHA, could have urged or required the safety improvements needed to prevent the accident.”
“To continue to advocate for further reforms, the CSB recently added the issue of federal process safety management reform and modernization to its Most Wanted Chemical Safety Improvements Program. The goal of adding this important issue to the CSB Most Wanted Program is the continuous improvement of process safety management in the US through the implementation of key federal and state CSB process safety-related recommendations and lessons learned.”
The CSB, commented Dr Moure-Eraso, found that current federal and state regulations “do not focus enough on continuously reducing process risks”.
“CSB investigations into serious accidents including the Tesoro explosion and fire in Anacortes, Washington, and the Chevron Refinery fire found that there was no requirement to reduce risks to a specific risk target such as ‘As Low As Reasonably Practicable’ (ALARP), which is the standard applied in Europe and elsewhere, where major accident rates are much lower.”
“Similarly, there is no mechanism to ensure continuous safety improvement; no requirement to address the effectiveness of controls or to rank the effectiveness of preventive measures (also referred to as the hierarchy of controls); and no requirement to implement and document an inherently safer systems analysis in establishing safeguards for process hazards.”
Dr Moure-Eraso also refuted the notion that major incidents “are the result of mistakes by what some have called ‘outlier’ companies”.
“There should be no mistake – process safety disasters are not limited to any so-called outliers. These disasters – which no one wants to occur – are the result of many factors affecting large and small companies alike. These include: weak or obsolete regulatory standards, inadequate regulatory resources and staffing, overly permissive industry standards, and a lack of safe design requirements and risk reduction targets.”
Concluding his testimony, he acknowledged an “increase in efforts” by industry and government to prevent major chemical accidents.
Dr Moure-Eraso cautioned, however, that “CSB investigations show that much more needs to be done to assure that future tragedies will be avoided.”
“The opportunity for meaningful reform is now.”
RE: Open health and safety letter to Santa Claus
Dear Santa,
Let us prefix this health and safety letter by taking a moment to thank you for your tireless efforts year in, year out. Thank you Santa, thank you indeed – particularly for the fabulous trainset you left under the tree last year.
Be that as it may, we have a health and safety claus we’d like to pick with you. With eyes that twinkle and dimples so merry, it’s easy to look past the safety failures you make – each year – when working at height.
As a bringer of safety, however, it is our duty to take you task.
Santa’s been a naughty boy
When flying in your sleigh and prancing upon snowy roof tops, Santa, you are in clear violation of The Work at Height Regulations 2005.
As sure as your belly wobbles like a bowlful of jelly, these regulations apply to you as an employer and the individual in control of work at height.
In controlling any work activities at height, you must:
- Make sure the work is properly planned, supervised and carried out by competent people
- Use the right type of equipment for working at height. Likewise, low-risk, relatively straightforward tasks will require less effort when it comes to planning
Safety’s not just for Christmas
Santa, let us summarise. You are a role model to children and workers around the world. Let us therefore implore you to lead by example.
Please remember Santa: safety is not just for Christmas, it’s for life. So these rules apply not only on the eve of the 24th but all year round.
Merry Christmas to all and to all a safe night.
Kind regards,
Reynolds Training Services
Supporters of Tottenham Hotspur Football club were left empty handed – and we’re not talking about silverware – when they had banners taken off them by club stewards at a recent game against Stoke City.
Many of the banners, according to a Telegraph report, were populated with messages calling for the club’s chairman, Daniel Levy, to be ousted in light of a poor run of form.
“There were claims on social media that fans had ‘Levy Out’ banners taken off them by club stewards at the game,” the newspaper article read.
The reason? Health and safety. “Anybody wishing to take a banner inside White Hart Lane,” the Telegraph report continues, “must get the prior approval of the club for health and safety reasons.”
So, was the club on or offside in its health and safety protestations?
Health and Safety Executive Mythbusters Panel
Like a world-class referee, the Health and Safety Executive’s Mythbusters Panel made a quick and decisive decision.
The panel found: “The club does have a rule in place that requires all banners (not just those about an unpopular ‘chairman’!) to be notified in advance and this is for fire safety reasons.
“Given the challenges of crowd management at football matches this is an entirely reasonable rule to have in place.”
Back of the net.
Safety failures were to blame for injuries to three workers in separate falls from height, a court ruled upon sentencing a Hampshire-based aircraft maintenance company.
The incidents, which occurred at ATC (Lasham) Ltd, took place during 2011. A subsequent Health and Safety investigation exposed a raft of safety breaches.
After the hearing at Salisbury Crown Court, HSE inspector Kelly Nichols said: “Three workers have suffered painful injuries owing to inadequate safe systems of work employed by ATC (Lasham) – which is particularly disappointing given it is a major company working in a particularly safety-critical sector.”
Health and safety failures
The Health and Safety Executive’s investigation established the circumstances surrounding each workplace injury.
- The first safety incident: An employee, who was repairing a faulty door on 9th July 2011, fell five metres from an aircraft door to the runway tarmac. At first, the worker’s injuries were thought to be life-threatening.
- The second safety incident: A contractor, three weeks later on 27th July 2011, suffered a broken knee after a weld gave way on a scissor lift.
- The third safety incident: Another employee incurred three fractures to their thumb when they fell from an aircraft stand that had no guardrail between the aircraft and the stand steps.
Unsafe systems of work
In the case of all the incidents, the HSE found ATC had failed to provide a safe plant and a safe system of work for the three men. The court heard:
- There was an absence of safe procedures for working at height
- The company provide unsuitable and unmaintained equipment
- General poor management was found onsite
The HSE had served a number of prohibition notices following each incident ordering the cessation of certain areas of work and improvement notices requiring better working practices.
HSE inspector Ms Nichols commented: “The company’s management of health and safety was extremely poor in many areas but particularly in their approach to working at height. Three falls occurred in a relatively short period and these could have resulted in even more serious injuries.
“Working at height needs careful planning and organisation, and part of that is selecting and using the right type of equipment, which is properly maintained and safe.”
ATC (Lasham) Ltd, of Lasham Airfield, Lasham, Hampshire, admitted three breaches of the Health and Safety at Work etc Act 1974. The company was fined a total of £35,000 and ordered to pay £32,430 in costs.
Press release: 17th December 2014
Stallingborough-based Reynolds Training Services Ltd has gained accreditation from industry skills sector council Cogent in the delivery of health and safety training material.
Reynolds Training Services managing director, John Reynolds, believed the move would further enhance safety standards across high hazard sites in the industrial sector.
“As a training provider, we’ve always sought to provide the highest quality of training,” said Mr Reynolds. “Quality material is customised around a site’s specific needs then delivered by safety trainers who have direct experience within that sector.”
“Blending quality material with experienced trainers is how we cultivate safer environments.”
Creating the link with Cogent, he added, further strengthened Reynolds Training Services’ delivery mechanisms.
Mr Reynolds explained: “It stands to reason that we should link ourselves directly to our industry skills sector body, Cogent. Doing so provides clients with reassurance that safety training is delivered in line with Cogent’s standards.
“Cogent enables us to demonstrate that Reynolds Training Services not only attains the relevant standards to gain accreditation, but consistently maintains these.”
Cogent’s provider manager, Claire Green, expressed “delight” at the addition of Reynolds Training Services into the Skills Council’s provider network.
“We have a long standing relationship, and look forward to building on the positive work done so far,” stated Ms Green.
Notes to editors
More about Cogent
Cogent SSC is the employer-led, strategic skills body for the science industries. Cogent’s work is closely aligned with science employers’ skills needs. It both responds to the demands of business and connects with government policies.
[cta_button]More about Cogent[/cta_button]
More about Reynolds Training Services
Reynolds Training Services brings training and consultancy solutions to industrial sites and workplaces. The company, which works with brands such as Simon Storage and BP, does this to manage risks which are central to businesses’ prosperity.
Training packages and custom courses are accredited by NEBOSH, PAAVQ-SET, IOSH and CIEH.
[cta_button]More about RTS[/cta_button]
This online health and safety course gives you The Big Picture about implementing safety management systems in line with the Hazardous Inspectorate Directorate regulatory model.
Turn on the computer, log into iLearn and gain key insights into the central role leadership plays in the creation of robust prevention and mitigation systems.
From here, we learn that the most effective barriers are those forged around plant, process and people, with ongoing systems of checks, measures and reviews sustaining a safer future.
Online health and safety training video
Watch the online health and safety training video:
[cta_button]Tell me more about this online health and safety training course[/cta_button]
A developer, scaffolding company, its director and a roofer have been prosecuted after a 36 year old worker fell around seven metres to his death in Staffordshire.
Phillip Lonergan, an experienced roofer, was installing a roof on a new warehouse on 29th December, 2010. The property was being built by E2 Developments Ltd.
Mr Lonegran, of Burton-on-Trent, was standing on the edge of the roof when he slipped. He fell through a gap measuring in excess of 50 centimetres between two scaffolding rails put in place to form temporary edge protection.
Mr Lonergan died in hospital on the same day from head injuries.
Speaking after the hearing at Stafford Crown Court, Health and Safety Executive inspector Lindsay Hope said: “Each defendant failed to ensure Mr Lonergan and other roofers could work safely. In each case their failure was a significant cause of Mr Lonergan’s death.”
Health and Safety Executive investigation
The court heard how a subsequent HSE investigation discovered that the edge protection had been provided by Nottinghamshire-based Albion Tower and Scaffold Ltd.
The company’s director, Lee Cotterill, had no formal qualifications as a scaffolder. Even so, Mr Cotterill had overall control of the design, planning and construction of the edge protection. He personally signed the structure off as being safe.
The edge protection took the form of two scaffolding guardrails running around the roof edge. These were attached to horizontal scaffolding tubes. The court was told that British Standards allows only a minimum of two guardrails to be in place when the angle of the roof is ten degrees or less.
In Mr Lonergan’s case, he was working on a roof with a pitch of 20 degrees.
Roofer Peter Allum was approached by E2 to install the roof panels. Mr Lonergan was among a number of workers whom he offered the work to. Mr Allum was supplied with roof plans detailing the 20-degree angle in October 2010 but failed to address the risks with adequate edge protection.
The investigation also found E2 Developments was unaware of the Construction (Design and Management) Regulations 2007. These rules required the company, as the client, to inform the HSE of the work and, in doing so, appoint a competent scheme co-ordinator and principal contractor.
HSE inspector, Lindsay Hope, said the temporary edge protection “should have had a third guardrail to reduce the space for a person to slide through”.
“It should also have had netting around the edge, or toe boards,” she added. “No such safety measures were in place. The edge protection was therefore inadequate to reduce the risk of serious harm – something that should have been obvious to both Albion and its director Lee Cotterill.
“E2 was provided with architects’ plans showing the roof was at a 20-degree pitch but failed to plan, manage or monitor the work in order to eliminate the risk of a fall. One of the directors had never heard of the regulations the company should have been working to. It was therefore very difficult for the company to discharge its duties under those Regulations if directors were ignorant of them.
“Peter Allum was aware of the obvious risk of harm posed by the inadequate rails, but did nothing about it. As an experienced roofer he could, and should, have tackled the issue.”
Four sentenced over safety failings
On Tuesday 2nd December, 2014, at Stafford Crown Court:
- E2 Developments Ltd admitted breaching Regulations 14(1), 14(2) and 22 of the Construction, Design and Management Regulations 2007. The company was fined a total of £66,000 with costs of £13,200.
- Peter Allum pleaded guilty to breaches of Section 3(2) of the Health and Safety at Work etc Act 1974. Mr Allum was fined £1,500 with £1,500 costs.
- Lee Cotterill pleaded guilty to breaching Section 3(1) of the Health and Safety at Work etc Act 1974. Mr Cotterill received three months in prison, suspended for 12 months and ordered to pay costs of £4,000
- Albion Tower and Scaffold pleaded guilty to the same offence. The company was fined £53,000 and ordered to pay £15,500 in costs.
HSE figures show that more than a fifth of all construction deaths are caused by falls from or through roofs. Comprehensive guidance on working at height is available at HSE’s website.
Debate is healthy when it is based on facts as opposed to antidotes designed to support the arguments of health and safety critics, according to Judith Hackitt.
Writing in her blog, the chair of the Health and Safety Executive was quick to caveat her thirst for discussion by underscoring the need for it to be grounded in “real evidence”.
“Even before I became chair of HSE, I was aware that there are very few people who don’t have an opinion about health and safety,” she writes.
“I don’t expect all of those views to coincide with mine and I welcome proper debate among people with different perspectives. What I really find frustrating are people who seize opportunities to express their opinions but use some interesting tactics to mislead their audience into thinking they are being presented with facts.”
Health and safety by numbers
Honing in on data massaging, Ms Hackitt comments: “The HSE’s own statistics have been used to question whether we can be regarded as a world leader in health and safety regulation.
“I will admit to being proud of our system here in GB, but it is the system which we have all created and are part of which matters.”
Whilst the statistics are testament to “working together in preventing death injury and ill health”, they also serve as a sharp reminder “that we still have work to do”.
“But the fact is,” adds Ms Hackitt, “what we do achieve is one of the best performances in the world and other regulators around the world come to us for advice on how to improve their systems.”
“I’ve seen one report which ranked the UK as having one of the highest levels of health and safety risk in the world. It’s easy (but misleading) to arrive at that answer if you base it on absolute numbers of incidences and include countries which grossly under-report and those which have very small populations – as this report did.
“It should be obvious to anyone that 50 fatalities in a country of five million people is a significantly worse performance than 100 fatalities in a country of 50 million people. Not so in the methodology of this study, the country of 50 million people would be ranked as being worse than the one with five million!
“One can only question the point of such a study and its bizarre conclusion.”
Ms Hackitt concludes by inviting those who “think differently” to an open debate provided it is thrashed out in the arena of “real evidence” rather than “arguments which are chosen to support a particular prejudice or hidden agenda”.
