Risk / Safety Management Activity Areas

Topves

5.0.1 Content - Some sources for selection of activity areas

Below you will find some sources that provide a good indication as to what activity areas should be in a management system to control risk and losses. You will note that most of the sources mentioned are in one way or another related to the process industry. The reason why is simple: the process industry is leading where it concerns the control of risk - after all, risk is at the heart of what they do.

I have put the sources under three headings:

	Legislation - some major international legislation and some national applications
	Industry standards - some major industry standards and guidelines
	Company examples - some examples of companies, either corporate or site related.
	Commercial systems - mainly audit systems that are available commercially

You will have to select the activity areas that you feel are applicable to your organization. I like to think that what works for the process industry would probably also work for you but, when working out the selected areas in more detail, you may not need the detail that the process industry requires.

Talking about detail, I left most of it out when mentioning the sources below. Some of the information is too detailed to be reproduced here. Some sources seem to indicate more subjects than others but that is partly due to the fact that those have sub-headings which I did not list. You will be able to get additional information by visiting the websites of the organizations concerned and I will mention those, where appropriate. The detail for you own organization has to come from the process and by applying the structure to the selected areas that will then be part of your management system.

The sources mentioned below will of course change and new standards and legislation will be developed. It is not my intention to keep up with all these developments and I don't feel that is necessary either. Basically all risk control information sources follow the sequence of the risk management process. Once you have selected your system incorporating that process, you will just have to keep on working to make it better. And while doing the periodic reviews of your system you will, of course, not forget to look at changing legislation or other third party requirements.

I have made my own selection of activity areas and worked that out in some detail in the TopChem example.

LEGISLATION

OSHA - 29 CFR 1910 119 Process Safety Management of Highly Hazardous Chemicals

This is US legislation that, however, is also used by a number of international organizations.

	Employee Participation
	Process Safety Information
	Process Hazard Analysis
	Operating Procedures
	Training
	Contractors
	Pre-start-up Safety Review
	Mechanical Integrity
	Hot Work Permit
	Management of Change
	Incident Investigations
	Emergency Planning and Response
	Compliance Safety Audit
	Trade Secrets

The learn more about the OSHA 1910.119 requirements, visit http://www.osha.gov/ and search for 1910.119.

Seveso II- Guidelines on a major accident prevention policy and safety management system, as required by Council Directive 96/82/EC (Seveso II)

This is European legislation that is applicable is all EU member states. It basically services the same purpose as US OSHA 29 CFR 1910.119.

	Organization and personnel
	Hazard identification and evaluation
	Operational control
	Management of change
	Planning for emergencies
	Monitoring performance
	Audit and review

For additional information on Seveso II and related publications, look at Major Accident Hazards Bureau and to "Publication" where you will find various publications, including the one on

OSHA VPP - Voluntary Protection Programs To Provide Safe and Healthful Working Conditions

The VVP program addresses employee health and safety.

	Commitment
	Organization
	Responsibility
	Accountability
	Resources
	Planning
	Contract workers
	Employee involvement
	Annual evaluation of Safety and Health program
	Site plan
	Pre-use analysis
	Comprehensive surveys
	Self inspections
	Routine hazard analysis
	Employee reports of hazards
	Employee notification
	Accident investigation
	Pattern analysis
	Professional expertise
	Safety and health rules
	Personal protective equipment
	Emergency preparedness
	Preventive maintenance
	Medical program
	Safety and health training

For additional information go to http://www.osha.gov/oshprogs/vpp/

EPA 40 CFR 68 - Chemical accident prevention provisions

The USA EPA (Environmental protection Agency) addresses environmental issues related to chemical activities. It largely parallels OSHA 29 CFR 1910.119.

	Hazard assessment
	Process safety information
	Hazard review
	Operating procedures
	Training
	Maintenance
	Compliance audits
	Incident investigation
	Process hazard analysis
	Mechanical integrity
	Management of change
	Pre-startup review
	Safety audits
	Incident investigation
	Employee participation
	Hot work permit
	Contractors
	Emergency response program
	Accidental release prevention
	Risk management plan
	Record keeping requirements

Go to http://www.epa.gov/ for additional information and use the "search" function to go to the appropriate document(s).

MES - Metatechnical evaluation system

This is an evaluation instrument that is being used by the Belgian authorities, following the Seveso II Directive.

	Senior management responsibility
	Safety management system

Management of applicable safety standards

Procedures for control of design and design modification of installations

Control for start-up of new installations

Procedure for control of modifications of installations

Periodic process safety studies

Purchasing procedure

Control on receiving of hazardous goods

Working with third parties

Control of operational procedures and work instructions

Work permits

Control of periodic inspection programs

Control of general safety inspection programs

Control of maintenance programs

Procedure for control of emergency planning

Procedure for investigation of accidents and incidents

Control of training programs

Control of safety audits

	Implementation of the safety standards
	Design and modification of the installations
	Purchasing and working with third parties
	Process control
	Inspection and maintenance
	Emergency planning
	Corrective and preventive measures
	Safety audit
	Training

For additional information on MES - CLICK HERE

INTERNATIONAL STANDARDS

The international standards provided below are basically voluntary standards although some have (almost) the same standing as legislation.

ISO 14001 - Environmental management systems

ISO 14001 is the standard used for accredited certification.

	Environmental policy
	Environmental aspects
	Legal and other requirements
	Objectives and targets
	Environmental management programs
	Structure and responsibility
	Awareness and competency
	Communication
	Environmental management system
	Document control
	Operational control
	Emergency preparedness and response
	Monitoring and measurement
	Non-conformance and corrective and preventive actions
	Records
	Environmental management system audits
	Management review

Additional information about the ISO 14000 family of documents can be found on: http://www.iso.ch/ . You can of course also use one of the search engines to find additional information.

ILO-OSH 2001 Guidelines on OSH Management Systems

Policy

Occupational safety and health policy

Worker participation

Organizing

Responsibility and accountability

Competence and training

Occupational safety and health management system documentation

Communication

Planning and implementation

Initial review

System planning, development and implementation

Occupational safety and health objectives

Hazard prevention

Prevention and control measures

Management of change

Emergency prevention, preparedness and response

Procurement

Contracting

Evaluation

Performance monitoring and measurement

Investigation of work-related injuries, ill health, diseases and incidents, and their impact on safety and health performance

Audit

Management review

Action for improvement

Preventive and corrective action

Continual improvement

To obtain a copy of the ILO document CLICK HERE.

OHSAS 18001 Occupational health and safety management systems

OHSAS 18001 and the guidance document 18002 have been made by a working group consisting of the major Certification Institutes. It was made after ISO decided (in 1996/7) not to have an ISO standard for occupational health and safety. OHSAS 18001 does not lead to accredited certification but many Certification Bodies will provide a non-accredited certificate.

OHSAS 18001 parallels ISO 14001 which facilitates possible integration.

	OH&S Management system elements
	General requirements
	OH&S policy
	Planning

Planning for hazard identification, risk assessment and risk control

Legal and other requirements

Objectives

OH&S management programs

Implementation and operation

Structure and responsibility

Training awareness and competence

Consultation and communication

Documentation

Document and data control

Operational control

Emergency preparedness and response

Checking and corrective action

Performance measurement and monitoring

Accidents, incidents, non-conformance and corrective and preventive action

Records and records management

Audit

Management review

OHSAS publications can be obtained from BSI (British Standards Institute).

API 750 - Recommended Practice for the Management of Process Hazards

The American Petroleum Institute recommended practice has similar objectives as OSHA 29 CFR 1910.119 and EPA 40 CFR 68.

	Process Safety Information
	Process Hazard Analysis
	Management of Change
	Operating Procedures
	Safe work practices
	Training
	Assurance of the quality and mechanical
	Integrity of critical equipment
	Pre-start-up Safety review
	Emergency response and Control
	Investigation of process-related incidents
	Audit of process hazard management systems

The API 750 document can be obtained from Global Engineering Documents.

API 581 - Base Resource Document on Risk-Based Inspection

API 581 is the internationally accepted guide for inspection activities based on established risk.

	Leadership and administration
	Process safety information
	Process hazard analysis
	Management of change
	Operating procedures
	Safe work practices
	Training
	Mechanical integrity
	Pre-start up safety review
	Emergency response
	Incident investigations
	Contractors
	Assessment

The API 581 document can be obtained from Global Engineering Documents.

Responsible Care

Responsible Care is the copyrighted name under which efforts are described to upgrade the safety and environmental efforts of the international chemical industry. The initiative comes form within the industry itself and a logo is used to identify those companies that make use of the voluntary program. There are a number of different description which may vary per country. Below I am showing the contents of the program as promoted by the American Chemistry Council.

The program consists of sic codes:

	Employee Health and Safety
	Process Safety
	Community Awareness and Emergency Response (CAER)
	Pollution Prevention Resources Manual
	Product Stewardship
	Distribution

These codes used to be contained in manuals which one could buy from the American Chemical Manufacturers Association. That was some time ago. Browsing the Internet, I could no longer find them but I give below the main headings of each of the codes as I used to know them. If you want to know more about Responsible Care, I can only advise you to search the Internet. Starting points may be the sites of the ACC or the CCPA.

Process Safety Code

	Commitment
	Accountability
	Performance Measurement
	Incident Investigation
	Information Sharing
	CAER Integration
	Design Documentation
	Process hazard Information
	Process Hazard Analysis
	Management of Change
	Siting
	Codes and Standards
	Safety Reviews
	Maintenance and Inspection
	Multiple Safeguards
	Emergency Management
	Job Skills
	Safe Work Practices
	Initial Training
	Employee Proficiency
	Fitness for Duty
	Contractors

Employee Health and Safety Code

	Management Commitment
	Employee Participation
	Contractor Selection and Oversight
	Written Programs
	Program Assessments
	Data Collection and Analysis
	Hazard Identification
	Hazard Evaluation
	Medical Fitness
	Medical Surveillance
	Design and Operations Review
	Health and Safety Equipment
	Preventive Maintenance and Housekeeping Programs
	Incident Investigation
	Site Security
	Emergency Medical Assistance
	Communications
	Training Programs

Community Awareness and Emergency Response (CAER) code

	Employee concern assessment
	Communications training (internal/external)
	Employee education and emergency response plan and HSE programs
	Ongoing employee dialogue and outreach
	Evaluation of employee communication efforts
	Ongoing assessment of community concerns
	Outreach program on emergency response program and community risks
	Ongoing dialogue with local citizens
	Policy of openness
	Regular evaluation of community communications
	Ongoing assessment of risks from accidents
	Written emergency response plan
	Ongoing employee training on response responsibilities
	Emergency exercises to test emergency response plan
	Communication to local emergency planning committee
	Familiarize emergency responders to facility
	Coordination of facility emergency response plan with community plan
	Participation in testing community emergency response plan
	Sharing emergency response plan information with other facilities

Pollution Prevention Resources Manual

	Management commitment
	Quantitative inventory
	Impact assessment
	Education and dialogue
	Priorities, goals and plan for release reduction
	Implementation of reduction activities
	Measurement of progress
	Communicate progress
	Waste and release in research and design
	Promotion and support of waste and release reduction by others
	Periodic evaluation of waste management practices
	Selection etc of contractors and toll manufacturers
	Ground water protection programs
	Addressing past practices

Product Stewardship

	Leadership
	Accountability and performance measurement
	Resources
	HSE information
	Product risk characterization
	Risk management system
	product and process design and improvement
	Employee education and products use feedback
	Contract manufacturers
	Suppliers
	Distributors
	Customers and other direct products receivers

Distribution

	Risk management
	Compliance reviews and training
	Carrier safety
	Handling and storage
	Emergency preparedness

CCPS - Center for Chemical Process Safety

CCPS is affiliated with the AIChE. The Center is committed to developing practices to control accidental release of chemicals and their consequences.

There are several publications by CCPS that refer to management system contents. These publications include: " Guidelines for Auditing Process Safety Management Systems", "Guidelines for Implementing Process Safety Management Systems" and "Guidelines for integrating Process Safety management, Environmental, Safety and Health into a Quality management system". From these publications the following list of topics can be distilled:

	Commitment and Accountability
	Management system
	Process safety information
	Process hazards
	Hazard assessment
	Operating procedures / safe work practices
	Training
	Pre-startup review
	Maintenance / mechanical integrity
	Hot work permits
	Management of change
	Accident / incident investigation
	Emergency planning and response
	Audits

Further information on CCPS and their publications: http://www.aiche.org/ccps/.

SCC - Safety Certification of Contractors

The SCC (Safety Certification of Contractors) originated in The Netherlands as the VCA and in 1994 started as the first accredited safety certification scheme that I am aware of. Presently SCC is operational in Holland, Belgium, Germany, Austria and Switzerland. In Holland and Belgium alone about 10.000 certificates are "on the market". The SCC contains 10 chapters:

	Safety, health and environmental (SHE) policy and organization, management involvement
	SHE risk analysis / plan of action
	Training, information and instructions
	SHE communications and consultations
	SHE project plan
	Environmental protection
	Preparations for emergency situations
	SHE inspections
	Company health service
	Purchase and inspection of materials, equipment and tools
	Procurement of services
	Notification, registration and investigation of incidents

For further information on SCC visit the SSVV website.

NDUSTRY EXAMPLES

Company 1 - Oil and chemical company

	Management leadership, commitment and accountability
	Risk assessment and control
	Design and construction of installations
	Information and documentation
	Safety of personnel
	Health
	Philosophy???
	Training
	Operations and maintenance procedures
	Work permits
	Inspection and maintenance
	Reliability of HSE critical systems
	Environmental care
	Regulatory compliance
	Management of change
	Third party services
	Incident reporting, analysis and follow-up
	Emergency preparedness
	Community Awareness
	Operations integrity assessment and improvement

Company 2 - Chemical Company

	Leadership
	Training for leadership
	Operational objectives and action-plan
	Selection and coaching
	Job introduction
	Technical training
	Task analysis and work instructions
	HSE – Rules, permits and PPE
	Study of HSE risks
	Technical control during planning, construction and commissioning
	Maintenance and inspection
	Control of changes and improvement projects
	Product control
	Work by contractors
	Health
	Internal communication
	External communication
	Control of emergency situations
	Investigation and analysis of incidents
	Measurement and evaluation of HSE
	HSE -audits
	Control of documents and HSE - records
	Development and innovation
	Purchasing of products
	Handling of products
	Marketing and sales

Company 3 - Chemical company

	Safety, health and environmental commitment
	Management and resources
	Communication and consultation
	Training
	Materials hazards
	Acquisitions and divestments
	New plant, equipment and process design
	Modifications and changes
	She assurance
	Systems of work
	Emergency plans
	Contractors and suppliers
	Environmental impact assessments
	Resource conservation
	Waste management
	Soil and groundwater pollution
	Products stewardship
	SHE performance and reporting
	Auditing

Company 4 - Electronic company

	Management commitment and responsibilities
	Safety training
	Safe work practices
	Self assessments
	Government inspections and surveys
	Accident, incident and illness reporting
	Safe environment
	Mechanical safety
	Maintenance safety
	Contractor safety
	Electrical safety
	Fire prevention, fire protection and emergency response
	Chemical control program
	Process hazard reviews
	Materials handling safety
	Ergonomics
	Industrial hygiene exposure assessments
	Asbestos management
	Hearing conservation
	Ionizing and non-ionizing radiation protection
	Laser safety
	Ventilation
	Personal protective equipment
	Motor vehicle safety
	Meetings in non-Company facilities
	Sports safety program

Company 5 - Oil and chemical company

	Leadership and administration
	Management training
	Planned inspections
	Task analysis and procedures
	Accident/incident investigation
	Task observation
	Emergency preparedness
	Organizational rules
	Accident/incident analysis
	Employee training
	Program evaluation system
	Engineering controls
	Personal communications
	Group communications
	General promotion
	Hiring and placement
	Purchasing controls
	Off-the-job safety
	Hazard awareness
	Personal protective equipment
	Health protection
	Drug and alcohol abuse
	Environment
	S

Company 6 - Chemical company

	Process safety information
	Operating procedures and safe practices
	Management of technology change
	Process hazard analysis
	Quality assurance
	Pre-start-up safety reviews
	Mechanical integrity
	Management of facilities change
	Training and performance
	Contractors
	Incident investigation and reporting
	Management of personnel change
	Emergency planning and response
	Auditing

Company 7 - Oil company

	Leadership and commitment
	Policy and strategic objectives

Strategic objectives

Policy statement

Organization, resources and documentation

Structure and responsibilities

Management representative

Resources

Competence

Contractors

Communication

Documentation and its control

Evaluation and risk management

Hazard and effects management process

Identification of hazards and effects

Evaluation

Recording of hazards and effects

Objectives and performance criteria

Risk reduction measures

Planning

Asset integrity

Procedures and work instructions

Management of change

Contingency and emergency planning

Implementation and monitoring

Activities and tasks

Monitoring

Records

Non-compliance and corrective action

Incident reporting

Incident follow-up

Auditing and reviewing

Company 8 - Food company

	Leadership and administration
	Hazards to the environment and identification of critical issues
	Environmental program
	Organizational rules and permits to operate
	Analysis of critical tasks/work activities
	Hiring and placement
	Training
	Communication and motivation
	Engineering controls
	Purchasing controls
	Health control
	Formal inspections
	Environmental performance monitoring and assessment
	Personal protective equipment
	Emergency preparedness
	Reporting/investigation and analysis of undesired events
	EH&S program evaluation

Commercial audit systems

Audit system 1

	Leadership and administration
	Leadership training
	Planned inspections and maintenance
	Critical task analysis and -procedures
	Accident/incident analysis
	Job observations
	Emergency preparedness
	Rules and work permits
	Accident/incident analysis
	Knowledge and skill training
	Personal protective equipment
	Health and hygiene control
	System evaluation
	Engineering and change management
	Individual communications
	Group communications
	General promotion
	Hiring and placement
	Materials and services management
	Off-the-job safety

Audit system 2

	Leadership, commitment and accountability
	Training
	Process safety and management of change
	Environmental management
	Organizational culture and behavior management
	Product stewardship
	Task and operating procedures
	Recruitment and placement
	Occupational health
	Inspection, maintenance and work permits
	Procurement and services
	Information and documentation
	Internal communication
	Emergency preparedness
	Incident investigation, follow-up and prevention
	Security

Audit system 3

This audit system is made available through IRCA

	Planning and Leadership
	Training and Communications
	Job / Operation Analysis and Controls
	Change Management.
	Purchasing Systems
	Work Rules and Operating Permits
	Inspections
	Occupational Health and Hygiene Systems
	Personal protective Equipment
	Incident Investigation and Analysis
	Emergency Preparedness
	Audits and Reviews
	Corrective and Preventative Action Systems
	Environmental Management Systems lSO 14001
	Quality Management Systems

OPTIONAL TECHNICAL ELEMENTS

	Hazard Identification and Risk Assessment
	Security Management
	Fire Protection
	Product Stewardship
	Seismicity
	Fleet Management

THE principle of RESISTANCE TO CHANGE

"The greater the departure of any planned change from the accepted ways of the past, the greater the potential resistance by the people involved.