Task 1: Audit approach
(a)
Here are the positive aspects of the audit approach based on the scenario:
1. Use of a Structured Audit Process – The audit followed the organisation’s written audit procedure, ensuring a systematic and organised approach.
2. Independence of Auditors – The internal auditing system ensured auditors were from different departments, maintaining objectivity and reducing bias.
3. Training Opportunity for Worker A – Including Worker A in the audit process helped develop internal auditing skills and supported knowledge transfer.
4. Proper Audit Planning – The audit was scheduled in advance, and the PM was informed via email and a follow-up conversation, showing a planned approach.
5. Comprehensive Scope – The audit covered all critical stages of production, including raw material delivery and storage, mixing, quality control, and transportation of finished goods.
6. Persistence in Conducting the Audit – Despite the PM not informing supervisors, the audit proceeded, showing commitment to maintaining safety standards.
7. Document Review – The auditors examined paperwork such as risk assessments and the health and safety policy, identifying outdated documents.
8. Visual Inspection – Direct observation of work practices, including PPE use, spillages, equipment conditions, and emergency exit access, provided valuable insights.
9. Engagement with Workers – Speaking to workers, like Worker C, allowed auditors to gather firsthand accounts of safety concerns, such as dermatitis and fatigue.
10. Identification of Health and Safety Issues – The audit successfully identified non-compliances, such as improper chemical storage and handling.
11. Use of a Classification System – Findings were categorised into Good Practice (GP), Opportunities for Improvement (OFI), and Non-Compliance (NC), ensuring clarity in reporting.
12. Action Plan and Accountability – The audit report assigned responsibility for corrective actions (chemical storage improvements) to the PM with a set deadline, ensuring accountability.
(b)
Reviewing findings from audits is important for several reasons, based on the scenario:
1. Identifying Areas for Improvement – Reviewing findings highlights issues such as outdated documents, poor chemical storage, and unsafe handling practices, allowing corrective actions to be taken.
2. Ensuring Compliance – Audits help verify compliance with health and safety policies, regulations, and industry standards, ensuring the organisation meets legal obligations.
3. Enhancing Workplace Safety – Addressing audit findings reduces risks, prevents accidents, and improves overall working conditions, as seen in the scenario where changes reduced injuries and improved housekeeping.
4. Accountability and Follow-up – Assigning responsibility for corrective actions (e.g., the PM being responsible for chemical storage improvements) ensures that issues are addressed within a set timeframe.
5. Supporting Continuous Improvement – Regularly reviewing audit findings helps identify recurring issues, track progress, and refine safety measures for long-term improvement.
6. Demonstrating Management Commitment – Acting on audit findings shows that senior management prioritises health and safety, fostering a positive safety culture within the organisation.
7. Reducing Financial and Operational Costs – Addressing audit findings proactively can prevent costly incidents, lost productivity, and regulatory penalties, as seen in the scenario where improvements led to increased efficiency and fewer accidents.
Task 2: Change management controls
Here are the key changes during the project that may require management of change (MoC) controls….
1. Introduction of Bulk Storage Tanks – The organisation replaced 25-litre drums with bulk storage tanks for three raw materials. This required controls to ensure the safe design, installation, and maintenance of tanks to prevent leaks, contamination, or overfilling.
2. New Pipework Installation – The system introduced pipework to transfer raw materials from storage tanks to mixers. Proper risk assessment was needed to check for potential leaks, pressure issues, or blockages that could affect safety and efficiency.
3. Modification of Raw Material Delivery – Previously, forklifts transported 25-litre drums from the warehouse to the production area. With the new system, raw materials were delivered by tanker, requiring changes in unloading procedures, spill containment, and emergency response planning.
4. Elimination of Manual Handling Risks – Workers previously carried heavy drums up stairs, leading to injuries. The new system removed manual handling, requiring training on how to safely operate the new bulk transfer system.
5. Changes in Housekeeping and Spill Control – The scenario mentions that spillages and poor chemical storage were an issue. The new system reduced spills and improved housekeeping, but MoC controls were necessary to ensure ongoing maintenance and proper cleaning procedures.
6. Impact on Worker Roles and Training – Workers no longer handled individual drums but had to operate and maintain a bulk transfer system. Training and competency assessments were required to ensure safe operation and emergency handling.
7. New Maintenance Requirements – The old system had corroded equipment and worn seals due to spills. The new bulk system required a preventive maintenance schedule to avoid similar issues in the future.
8. Potential New Hazards (Process Safety Risks) – The shift from manual handling to bulk storage and pumping introduced risks such as chemical leaks, pressure hazards, and equipment malfunctions. A risk assessment was needed to manage these new risks.
9. Regulatory and Compliance Considerations – The changes could require updated risk assessments, permits, and regulatory approvals, ensuring compliance with health and safety regulations for bulk chemical storage and handling.
10. Review of Emergency Procedures – The emergency response plan had to be updated to account for bulk chemical storage and transfer, including spill containment, fire hazards, and leak detection measures.
Task 3: Training to develop competence
Following the implementation of the bulk storage and transfer system, workers need training to ensure safe and efficient operations. The recommended training includes:
1. Safe Handling of Bulk Chemicals – Workers previously handled 25-litre drums manually; now, they must learn how to safely operate bulk storage and transfer systems to prevent spills, leaks, and exposure risks.
2. Operation of the Bulk Transfer System – Training on how to safely use the new pipework and pumping system, including startup, shutdown, and troubleshooting to ensure correct operation.
3. Emergency Spill Response Training – Since raw materials are now stored in bulk, workers must be trained on spill containment procedures, including the use of spill kits and emergency shut-off valves.
4. Personal Protective Equipment (PPE) Use and Care – While workers were already using gloves, goggles, and dust masks, they should receive refresher training on proper PPE selection, use, and storage, particularly for chemical exposure risks.
5. Safe Maintenance Procedures – The scenario highlighted corrosion and worn seals on old equipment due to spills. Workers should be trained in preventive maintenance practices to keep the new system in good working condition.
6. Manual Handling and Ergonomics – Although bulk storage has eliminated the need to carry heavy drums, workers still need refresher training on safe lifting techniques for handling smaller items and maintaining good posture.
7. Permit-to-Work (PTW) and Lockout/Tagout (LOTO) Training – With the introduction of new equipment and pipework, workers must understand isolation procedures and permits required for maintenance, reducing risks of accidental exposure to chemicals.
8. General Housekeeping and Workplace Hygiene – The scenario showed improvements in housekeeping after the project. Workers should be trained on maintaining a clean, organised workspace to sustain these improvements.
9. Incident Reporting and Investigation – Previously, an accident was recorded but not investigated or reported to the Regulator. Training on proper reporting of incidents and near misses ensures compliance and prevents recurrence.
10. Regulatory Compliance and Safety Standards – Workers must understand any new legal requirements or company policies related to bulk chemical storage and handling, ensuring compliance with health and safety laws.
11. Fire Safety and Hazardous Material Handling – With the introduction of bulk chemicals, workers should be trained in fire hazards, chemical reactivity, and proper storage precautions, especially in case of leaks or ignition risks.
Task 4: Procedural controls
To improve chemical handling safety, the organisation should implement the following procedural controls, based on the scenario:
1. Chemical Storage Procedures – Establish clear guidelines for safe storage, ensuring bulk chemicals are kept in designated storage tanks and smaller quantities are properly stored to prevent leaks and spills.
2. Safe Handling and Transfer Procedures – Workers should follow standard operating procedures (SOPs) for transferring chemicals from bulk storage to mixers, ensuring proper use of pumps, valves, and containment measures to prevent spills.
3. Housekeeping and Spill Control Procedures – Implement a clean-as-you-go policy to keep the production area free from chemical spills and clutter. The scenario highlighted spilled chemicals and poor housekeeping, which should now be addressed with strict cleaning protocols.
4. Personal Protective Equipment (PPE) Requirements – Ensure that gloves, goggles, and appropriate respiratory protection are consistently worn and properly maintained when handling chemicals, reducing the risk of exposure (as seen with Worker C’s dermatitis).
5. Forklift Truck (FLT) Usage and Traffic Management – Implement safe procedures for FLT operation, ensuring chemicals are not left blocking emergency exits (as observed in the scenario). This includes designated routes and unloading areas.
6. Maintenance and Inspection Procedures – Ensure regular inspections of mixers, storage tanks, and pipework to detect corrosion, leaks, or worn seals (issues found in the scenario). A preventive maintenance schedule should be in place to ensure equipment is in good condition.
7. Emergency Response and Incident Reporting Procedures – Update procedures for reporting and responding to chemical spills, leaks, and worker injuries. The scenario noted an incident where a worker slipped on chemicals and fell, but no investigation was conducted. Ensuring proper reporting and investigation will prevent future occurrences.
8. Training and Competency Procedures – Regular training and refresher courses should be provided on chemical handling, spill response, emergency procedures, and proper use of new bulk storage systems. Workers should also be trained on reporting unsafe conditions to management.
Task 5: Financial arguments to improve health and safety
To convince senior management to invest in health and safety improvements, the proposal likely included the following financial arguments based on the scenario:
1. Reduced Costs from Workplace Accidents and Absenteeism
The scenario reports a high number of accidents and near misses.
A worker injured their back lifting 25-litre drums and another slipped on spilt chemicals, leading to three weeks off work.
These incidents increase costs through sick pay, lost productivity, and possible compensation claims.
Investing in bulk storage and automated transfer eliminates manual handling risks, reducing injuries and absenteeism.
2. Increased Productivity and Efficiency
The old system required workers to carry and pour 25-litre drums manually, slowing down production.
The new bulk storage and transfer system reduced batch production time from two hours to one hour.
This allows the company to produce more paint within the same timeframe, increasing output and revenue.
3. Lower Material Wastage and Cost Savings
Supervisor B highlighted that spilt chemicals lead to significant waste, increasing costs.
The new system eliminates spills, ensuring more efficient use of expensive raw materials.
Less waste translates to direct cost savings and better profit margins.
4. Reduction in Temporary Worker Costs
Due to high demand, the company hired temporary workers to meet production targets.
With the new system improving efficiency, there is no longer a need for temporary workers, leading to significant cost savings on wages and training.
5. Avoiding Regulatory Fines and Legal Costs
The scenario mentions that a serious accident was not reported to the Regulator, a potential legal violation.
Non-compliance with health and safety regulations can lead to fines, lawsuits, and reputational damage.
Investing in safer equipment and better procedures ensures compliance, avoiding costly legal consequences.
6. Improved Worker Morale and Retention
Worker C complained about the tiring and dirty working conditions and dermatitis from chemical exposure.
Poor conditions lead to low morale, high turnover, and recruitment costs.
The new system makes work less physically demanding, reducing fatigue and improving job satisfaction, leading to higher retention and lower hiring costs.
7. Lower Equipment Maintenance and Replacement Costs
The old system caused corrosion and wear on machinery due to chemical spills.
The new bulk transfer system prevents exposure to chemicals, reducing damage to mixers, motors, and seals.
This extends equipment lifespan and lowers repair and replacement costs.
8. Potential for Business Growth and Competitive Advantage
With increased production capacity, the company can fulfill larger orders faster, making it more competitive.
Faster production could lead to new business opportunities and increased revenue.
Task 6: Obligations of employers to workers
Employer Obligations Under ILO R164 and Non-Compliance Observed in the Audit
The International Labour Organisation’s (ILO) R164 – Occupational Safety and Health Recommendation, 1981 (No. 164) outlines key employer obligations to ensure workplace health and safety. Below is an analysis of how these obligations were not fully followed in the production department at the time of the audit.
1. Recommendation 10(a): Ensuring Workplaces, Machinery, Equipment, and Operations Are Safe
Non-Compliance Observed:
Chemical spills were present in the production area, creating slip hazards.
Corrosion and worn seals on the mixers indicated poor maintenance.
The maintenance log showed no recorded checks for six months, increasing the risk of machinery failure.
Implication:
Workers were exposed to safety hazards, increasing accident risks.
2. Recommendation 10(b): Ensuring That Chemical, Physical, and Biological Substances Are Without Risk
Non-Compliance Observed:
Chemicals were stored improperly, with full, partly full, and empty drums piled around mixers.
Chemical spillages were not properly cleaned, increasing exposure and slip hazards.
Worker C developed dermatitis from chemical exposure, showing inadequate protection measures.
Implication:
Poor chemical handling and inadequate controls put workers' health at risk.
3. Recommendation 10(c): Providing Appropriate PPE and Ensuring Its Proper Use
Compliance Observed:
Workers were wearing gloves, goggles, and disposable dust masks as per the risk assessment.
Non-Compliance Observed:
Worker C complained that the gloves were too hot, leading to discomfort and possible improper PPE use.
PPE alone is not a sufficient control; better engineering controls (such as improved chemical handling systems) were needed.
Implication:
PPE should be suitable, comfortable, and effective to ensure compliance and protection.
4. Recommendation 10(d): Implementing Safe Systems of Work
Non-Compliance Observed:
The risk assessments were outdated (three years old) and not reviewed despite multiple incidents.
A worker injured their back from carrying a 25-litre drum, indicating a lack of safe manual handling procedures.
A worker slipped and fell down the mixer stairs, showing inadequate control of spillages.
The accident was recorded but not investigated or reported to the Regulator.
Implication:
Failure to review and update risk assessments led to preventable workplace injuries.
5. Recommendation 10(e): Providing Information, Training, and Supervision
Non-Compliance Observed:
Supervisor B struggled to find important paperwork, suggesting poor documentation management.
Workers were not properly trained on chemical handling, as improper storage and spillages were common.
The emergency exit was partially blocked by chemical drums, indicating a lack of awareness of emergency procedures.
Implication:
Lack of proper training and supervision increased risks in the workplace.
6. Recommendation 10(g): Consulting Workers on Health and Safety Measures
Non-Compliance Observed:
Worker C reported concerns about the work environment, but no action was taken by the Production Manager (PM).
High accident and near-miss rates suggested a lack of worker involvement in safety improvements.
Implication:
Workers' safety concerns were ignored, leading to low morale and ongoing risks.
Task 7: Indicators of health and safety culture
A negative health and safety culture is reflected in poor attitudes, behaviors, and management commitment toward workplace safety. Based on the audit findings, several indicators of a weak health and safety culture were evident in the organization.
1. Poor Management Commitment to Health and Safety
Indicators from the Scenario:
The Production Manager (PM) did not inform Supervisor B about the audit, showing a lack of priority for health and safety matters.
The health and safety policy was outdated (signed by a previous managing director, three years old), suggesting that management did not review or reinforce safety commitments.
Worker C reported concerns about chemical exposure and working conditions, but nothing was done to address them.
Implication:
If management does not prioritize safety, workers may also neglect safety procedures.
2. Lack of Proactive Hazard Identification and Risk Management
Indicators from the Scenario:
Risk assessments were three years old and had not been updated despite workplace incidents and near misses.
The maintenance log had not been updated for six months, leading to corroded machinery and worn seals.
No investigation was conducted for a worker who slipped and fell down the mixer stairs, and the incident was not reported to the Regulator.
Implication:
Ignoring risks and failing to investigate incidents can lead to repeated accidents and workplace injuries.
3. Unsafe Chemical Storage and Handling Practices
Indicators from the Scenario:
Chemicals were stored improperly, with full, partly full, and empty drums piled around mixers, creating trip and spill hazards.
Chemical spillages were not cleaned up, increasing slip risks and exposure to hazardous substances.
A worker suffered dermatitis due to direct skin contact with chemicals, indicating poor handling procedures.
Implication:
Poor chemical management puts workers at risk of injuries, health issues, and potential regulatory violations.
4. High Accident and Near-Miss Rates
Indicators from the Scenario:
The accident book showed a high number of accidents and near misses, suggesting frequent workplace safety failures.
One worker suffered a back injury from carrying 25-litre drums, showing a lack of proper manual handling training.
The blocked emergency exit increased risks during an emergency.
Implication:
A high accident rate without corrective actions shows a reactive rather than proactive safety culture.
5. Poor Communication and Worker Engagement in Safety
Indicators from the Scenario:
Worker C voiced concerns about poor working conditions, but the Production Manager did not act on them.
Supervisor B was unaware of the audit, indicating a lack of communication between management and production staff.
The safety notice board had outdated documents, suggesting workers were not actively engaged in health and safety updates.
Implication:
If workers feel their safety concerns are ignored, they may stop reporting hazards, worsening the safety culture.
Conclusion
At the time of the audit, the organization demonstrated a negative health and safety culture through:
Poor management commitment (outdated policies, lack of follow-up on safety concerns).
Failure to update risk assessments and investigate incidents.
Unsafe chemical handling and maintenance neglect.
High accident rates without proactive solutions.
Poor communication and lack of worker involvement in safety decisions.
These issues increased workplace risks, reduced worker morale, and could have led to legal consequences if left unaddressed.
Task 8: Good practice within a health and safety
management system
While there were several areas in the organization that required improvement, there are key examples of good practice that reflect a positive approach to health and safety management in the scenario. These practices align with standards expected in an effective health and safety management system. Below are the examples of good practice demonstrated by the organization:
1. Internal Auditing and Independence
Good Practice:
The implementation of an internal auditing system is a strong example of good practice in health and safety management.
The organization established a team of auditors from different departments, which ensures that audits are independent and not influenced by the department being audited.
Worker A's involvement in the auditing process, although as part of their training, also promotes engagement with the health and safety system and encourages a culture of safety responsibility across the organization.
Implication:
Internal audits allow the organization to identify safety issues early and make improvements based on objective findings, which is a key element of continuous improvement in health and safety practices.
2. Correct Use of Personal Protective Equipment (PPE)
Good Practice:
Workers were observed wearing appropriate PPE, such as gloves, goggles, and disposable dust masks during the production process.
The use of PPE was in line with the risk assessment and demonstrated that the organization is following established safety protocols to minimize exposure to hazardous materials.
Implication:
Proper PPE use reduces the risk of injury and complies with legal safety requirements, ensuring a safer working environment for employees.
3. Documented Health and Safety Procedures
Good Practice:
The organization has developed and documented its health and safety procedures, including risk assessments, which help to identify and mitigate potential hazards.
The audit procedure is written and followed to ensure consistency in conducting safety assessments and audits.
Implication:
Having documented procedures ensures that health and safety practices are consistent, repeatable, and compliant with regulations, which strengthens the overall safety culture.
4. Health and Safety Policy in Place
Good Practice:
The organization has a health and safety policy displayed in the production area. Although it is outdated, the fact that the policy is visible shows a commitment to promoting safety awareness among workers.
The policy being signed by the previous managing director indicates that senior leadership is involved in and supports health and safety initiatives.
Implication:
A visible policy helps employees understand their rights and responsibilities, fostering a sense of ownership and accountability in maintaining a safe work environment.
5. Proactive Identification of Safety Concerns and Reporting
Good Practice:
The organization encourages reporting of safety concerns. Worker C raised the issue of dermatitis from chemical exposure, which is a proactive step in identifying a health risk.
Although there were shortcomings in addressing the issue, the fact that health concerns were reported shows that the communication channels are open for workers to voice their safety concerns.
Implication:
A system that encourages reporting creates an environment where safety issues can be addressed early, preventing more serious health risks or accidents.
6. Engagement with External Solutions for Health and Safety Improvement
Good Practice:
The PM attended a trade fair to explore systems that could improve the bulk movement and storage of raw materials. This initiative demonstrates the organization's willingness to invest in safer, more efficient systems.
The decision to move to bulk chemical storage through tankers and pipelines is a forward-thinking solution that reduces manual handling, increases efficiency, and minimizes exposure to hazardous substances.
Implication:
The organization is open to external ideas and technologies to improve health and safety standards and production efficiency, reflecting a proactive approach to continuous improvement in safety management.
7. Monitoring and Evaluation of Health and Safety Improvements
Good Practice:
After implementing the changes, the organization reviewed the impact of the changes on health and safety performance.
The reduction in accidents, improved housekeeping, and worker satisfaction indicate that the organization is effectively monitoring the outcomes of its health and safety initiatives.
Implication:
Evaluating health and safety performance helps ensure that changes lead to tangible improvements and maintains momentum in the pursuit of safety excellence.
Conclusion
While there were some areas needing improvement, the organization demonstrated several good practices within its health and safety management system, including:
Internal auditing and independence to maintain objectivity.
Correct use of PPE by workers.
Documented procedures and policies promoting safety.
Encouraging reporting of safety concerns and actively seeking external solutions for improvement.
Monitoring the outcomes of changes to ensure health and safety improvements are effective.
These practices contribute to creating a culture of safety, compliance with regulations, and a continuous improvement mindset in the organization’s health and safety management system.
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