Safety Management Principles

Training of

Certified Airfield Safety Auditorsby

The Hong Kong Polytechnic University &

Airport Authority Hong Kong

Course OutlineDay 1

Ir. Patrick S.K. Poon Module 1: Safety Management Principles

Mr. Fenkins Chow Module 2: Risk Management Concepts

Day 2

Mr. Lawrence Law Module 3: Local & ICAO Safety Audit Requirement

Mr. Lawrence Law Module 4: Airfield Activities Safety Audit

Day 3

Mr. YK Kam Module 5: Development of safety audit protocols

Mr. YK Kam Module 6: Safety Audit Technique

Day 4

Mr. Law & Kam Fieldwork project (Airfield Audit) presentation

Introduction

Course Objectives:

– A comprehensive understanding of the safety and risk management principles

– A mastery of the safety audit techniques and competence to conduct “safety audits” of the airfield activities

What is safety?

What is safety?

Safety is the state in which the risk of harm to persons or property damage is reduced to, and maintained at or below, an acceptable level through a continuing process of hazard identification and risk management.

-- ICAO (2005)

Historical Development

Safety Perspectives

• Safety is often viewed from different perspectives:

• as an externally-imposed obligation (law)

• as an engineering problem (technology)

• as a psychological problem (people’s belief)

• as a behavioural problem (people’s behaviour)

• as a cultural issue (organization)

The fable of boiled frog

ICAO Purposes

Safety has always been the most important issue in all aviation activities.

This is reflected in the aims and objectives of ICAO as stated in Article 44 of the Convention on International Civil Aviation (Doc 7300), which charges ICAO with ensuring the safe and orderly growth of international civil aviation throughout the world.

• Safety audits ( 安全稽核 )

• Safety performance monitoring• Safety occurrences

Safety Assurance

Safety Management in Hong Kong

Safety Management in HK

• Legislation on safety management (2002)#• OSH Ordinance, Cap 509 (1997)*• General Duties (1997)*• Liabilities• Safety audits or reviews at regular intervals

# The Regulation provides a legal framework for the implementation of safety management system. It requires certain high-risk industrial undertakings, including construction sites, with a workforce of 50 or more, or a construction project with a contract value of HK$100 million (US$12.8 million) or more, to implement safety management systems of varying complexity. The Regulation also requires these industrial undertakings to conduct safety audits or reviews at regular intervals.

* In 1997, the government enacted the Occupational Safety and Health Ordinance which extended safety and health protection to practically all economic sectors.

Laws related to safety management

• Factories and Industrial Undertakings(Safety Management) Regulation, Cap 59AF– Most sections have come into force, leaving the Part 3 of Schedule 4

• Factories and Industrial Undertakings Ordinance, Cap 59, Section 6A, since 1997:– General duties of a proprietor

• Occupational Safety and Health Ordinance, Cap 509, Sections 6 and 7, since 1997:– Employers to ensure safety and health of employees

– Occupier of premises to ensure safety and health …

Safety Audit - a short history

• Sections about registration as safety auditors (his function is to audit existing SMS) commenced on 19 Jun 2000

• Then, most of the sections commenced on 1 April 2002, except Part 3 of Schedule 4

Who are affected

• Proprietor of – factory , shipyard business, electricity industry, town gas / LPG gas

industry, or container handling industry, and withand with– 50 or above workers in a day

• Contractor of construction work with 50 or above workers in a day

• Contractor of construction work with contract value of HK$100 million or higher

ReferencesReferences

• Factories and Industrial Undertakings (Safety Management) Regulation, Section 2 and Schedule 3

– Develop, implement and maintain a SSafety Management System (SMS) which contains the specified elements

ReferenceReference

• Factories and Industrial Undertakings (Safety Management) Regulation, Section 8

What shall the “proprietor” do?

What shall the Non-construction Proprietorwith 50 – 99 workers do?

• DDevelop, implement and maintain– an SMS which contains the first 8 elements8 elements (Part 1) (Part 1)

• AAppoint a competent safety review officer to conduct a Safety Review annually

• RRead, countersign and date the Safety Review Report

• DDraw up and submit a plan based on the recommendations

ReferencesReferences

• Factories and Industrial Undertakings (Safety Management) Regulation, Sections 8, 19 and 22

What shall the Non-construction Proprietorwith > 99 workers do?

• DDevelop, implement and maintain– an SMS which contains the first 1100 elements elements (Parts 1 & 2) (Parts 1 & 2)

• AAppoint a registered safety auditor to conduct a Safety Audit annually

• RRead, countersign and date the Safety Audit Report

• DDraw up and submit a plan based on the recommendations

ReferencesReferences

• Factories and Industrial Undertakings (Safety Management) Regulation, Sections 8, 13 and 16

General Duties of A Proprietor

• Factories and Industrial Undertaking Ordinance, Section 6A (General duties of a proprietor):

– 1) It shall be the duty of every proprietor of an industrial undertaking to ensure,

– so far as is reasonably practicable,

– the health and safety at work of all persons employed by him at the industrial undertaking

General Duties of A Proprietor

• FIUO, OSH Ordinance, Section 6A(2): – So far as is reasonably practicable to ensure S&H at

work of all employees, 5 elements of duties but not limited to imposed on proprietor under Section 6A(1):

• plant and systems of work

• use, handling, storage or transport

• information, instruction, training and supervision

• means of access and egress

• working environment

Legal Liability

Which of the following is the most important consideration when discharging employer’s general duties?

• Zero risk• 5 elements of general duties• Reasonably practicable

What does reasonably practicable mean?

• A self-regulatory approach• Up to the proprietor’s discretion to design or use

any SMS of international recognized standard or even look to FIU(SM)Reg

• One critical point should be borne in mind is the compliance of reasonably practicable requirement

Edwards Vs National Coal Board [1949]

'Reasonably practicable' is narrower term than 'physically possible' and seems to me to imply that a computation must be made by the owner, in which the quantum or risk is placed on one scale and the sacrifice involved in the measures necessary for averting the risk (whether in money, time or trouble) is placed on the other; and that if it be shown that there is a gross disproportion between them - the risk being insignificant in relation to the sacrifice – the defendants discharge the onus on them. Moreover, this computation falls to be made by the owner at a point of time anterior to the accident.

Likelihood of Likelihood of InjuryInjury Cost of safetyCost of safety

Edwards Vs National Coal Board, 1949Edwards Vs National Coal Board, 1949

Self-regulatory approach:The law will aim at

balancing through reasonably practicable

Liabilities after Accident

• In case your fellow got seriously injured, will you – be shocked, uncomfortable?

– know what to do?

– be busy?

– be sued?

– be blamed?

– be leaving?

– be asked for compensations?

Uninsurable Costs

• Fine of max $500K• Legal fees• Increased insurance premiums• Lost / reduced production• Damage to plant / equipment• Loss of time for other employees• Training of replacement employees• Damage to company’s good will• Loss of business

• Who is responsible for ensuring safety at workplace?

• Safety personnel• Workplace-in-charge

Question

General Duties

• Occupational Safety and Health Ordinance, Cap 509, Sections 6 and 7, since 1997:– Employers ( 僱主 ) to ensure safety and health of

employees

– Occupier ( 佔用人 ) of premises to ensure safety and health …

• 5 elements of duties• Non-compliance offence with fine of 200K• Mens rea (intentionally, knowingly, recklessly)

offence with fine of 200K and 6 mths in prison

Note: all charges go to employer

References

• Occupational Safety and Health Ordinance, Section 6

General Duties of Employer

Duty of Care applicable to Employee

• Take reasonable care for the health and safety of himself and of other persons

• Co-operate with proprietor, employer

References

• Factories and Industrial Undertakings (Safety Management) Regulation, Section 6B

• Occupational Safety and Health Ordinance, Section 8

• Ensure safety and without risks to health of the following:– Premises

– Means of access and egress

– Plant or substances kept

• Non-compliance offence with fine of 200K

• Mens rea (intentionally, knowingly, recklessly) offence with fine of 200K and 6 mths in prison

• Note: all charges go to occupier

References

• Occupational Safety and Health Ordinance, Section 7

General Duties of Occupier

Safety Management Principles

What areas does an organization need to manage?It depends on scope and nature of activities, complexity and size but typically:

• product/service realization• customer satisfaction• quality• occupational health and safety• environmental management• security • people issues• finance

Options Considered By ISO

1 2 3 41 2 3 4

Integration or Alignment

OH&S E

CORE

CORE CORE CORE

E OH&S Q

Basic Process Model

INPUT OUTPUT

MANAGEMENT

ACTIVITIES

ENABLERS

= CUSTOMER SATISFACTION

DO

ACT

PLAN

CHECK

Plan-Do-Check-Act (PDCA)Also commonly known as the Demming wheel, named after W. Edwards Demming, a Quality Management pioneer

• A plan can be to initiate a new process or improve an existing one

• it should be based upon customer needs, and

• resolve to more effectively fulfill the organization’s mission

Plan

Implementing the proposed change on an incremental basis

Do

Review the gathered data to determine if the planned and implemented change has created the quality improvement intended

Check

• Take action, either to implement the change or change variables to see if the process can be made more effective, or

• “Standardize” the new, successful process

Act

• Define the scope of work Missions are translated into work, expectations are set, tasks are identified and prioritized, and

resources are allocated.

• Analyze the hazards Hazards are associated with the work identified, analyzed, and categorized.

• Develop and implement controls Applicable standards and requirements are identified and agreed-upon, controls to

prevent/mitigate hazards are identified, the safety envelope is established, and controls are implemented.

• Perform work within controls Readiness is confirmed and work is performed safely.

• Provide feedback and continuous improvement

5 core safety management functions

Requirements of - ISO 14001

Environmental Policy

Planning

Implementation& Operation

ManagementReview

Checking &Corrective Action

Continual Improvement

OHSAS 18001

This is a specification - a “shall” document that is not a standard

It is certifiable

It is not accredited

All the major certification bodies have adopted it and certification is going ahead world-wide.

Continual Improvement

(Initial Status Review)

OH&S Policy

Planning

Implementation & Operation

Checking & Corrective Action

Management Review

OHSAS 18001

ELEMENTS

Carry out an annual review of causal factors for accidents– Identify disparities in accident rates between

Regions– Update, on a yearly basis, a table of safety

related tasks aimed at improving safety

GLOBAL AVIATION SAFETY PLAN (GASP)

ELEMENTS (cont)• Review and improve existing safety database

systems– Address shortcomings and deficiencies

identified in the Air Navigation field– Introduce improvements to safety identified by

the USOAP– Collaborate with regulatory and industry to

identify additional safety measures

GLOBAL AVIATION SAFETY PLAN (GASP)

In an Ideal World

Safety Management Systems Standards would:

• Be generically applicable world-wide, e.g. ILO/OSH 2001

• Use common terminology

• Use the same definitions for similar terms

• Use a common methodology - where this is possible

• Have a common architecture

• Allow a consistent auditing approach

• Facilitate ease of use for those adopting them

ISO Guide 72 Approach

• Policy

• Planning

• Implementation and Operation

• Performance Assessment

• Improvement

• Management Review

The Need for Integration Guidance

• Reactive to pro-active management

• Standards for OH&S, quality & environmental management - contrast, e.g., risk management, fire and security

• Controversy

• Organizations should in any event now be considering the development of an IMS

Policy

Top management should ensure that the stated policy

a) is appropriate to the organization

b) includes a commitment to comply with all relevant requirements and continually to improve the effectiveness of the management system

c) provides a framework for establishing and reviewing objectives

d) is communicated, where appropriate, and is understood within the organization, and

e) is reviewed for continuing suitability

• Identification of aspects and risks

• Selection of significant aspects to be addressed

• Objectives and targets

• Identification of resources

• Identification of organizational structures, roles, responsibilities and authorities

• Planning of operational control

• Contingency preparedness for foreseeable events

Planning

Key areas of planning that are distinct:

1. The organization should establish a process for identifying those aspects of its operation which need to be controlled and/or improved in order to satisfy the relevant interested party(ies). This includes research and design

Where appropriate, legal requirements should be identified

2. The organization should establish a process for prioritising its aspects, so that those that would have a significant impact are readily identified for control measures where this is appropriate.

3. The organization should establish and maintain a process for identifying and responding to any potential emergency situation. The process should seek to prevent and mitigate the consequences of any occurrence.

Planning

1. Operation

2. Management of Human Resources

3. Management of other resources

4. Documentation and its control

5. Communication

6. Relationship with suppliers/contractors

Implementation and Operation

HSE - 1995

Key issues for the SMS to be effective

• CONTROL - is there an adequate structure?• CO-OPERATION - are there adequate

arrangements? • COMMUNICATIONS - are the arrangements

effective?• COMPETENCE - are the systems and competencies

available?

Clear definition of responsibilities: include in job descriptions

authority and resources

arrangements: accountability

reporting arrangements: clear and unambiguous

where personal appraisal: include IMS performance

Senior managers should demonstrate commitment by active involvement

Structure & Responsibilities

Why SMS succeed?

Case Example

Why SMS succeed?• The OHSMS is directly aimed at managing critical risks • Senior managers or owners/operators practice what they

preach and make decisions to eliminate or reduce hazards.

• Supervisors and employees understand their role in the system and are closely involved in its development and operation.

• The system is commensurate with the risks to be managed and is absolutely tailored to the organization’s requirements.

• The OHSMS is able to withstand, and welcomes, robust questioning and review from everyone involved.

Why SMS fail?

Why SMS fail?• Management support is irregular and inconsistent.• Everyone treats the system as “paper warfare” and follow

procedures to keep the bosses happy regardless of their effectiveness.

• The OHSMS is established in response to external demands and never really “owned” or understood by those subject to it.

• The system is imposed without effective participation by those who have to make it work.

• The effort to build an organization specific system is not made and “off the shelf” solutions are applied that have little relevance to the culture of the workplace.

AA’s OHS Priority

• CEO expects “that safety must always be given the highest priority” and;

• in particular that “managers and supervisors are accountable for the safety practices of employees and safety performance in their area of responsibility”.

Major Considerations

Safety & Health Risk

CommitmentStaff

Participation

Legal Liability Cost-Benefit

Degree of accomplishment in safety performance

0 10 20 30 40 50 60 70 80 90 100

Percent

Policy, Leadership and Worker Empowerment

Roles, Responsibilities and Accountability

Competence Commensurate with Responsibility

Balanced Priorities and Implementation Planning

Standards and Requirements

Hazard Control and Implementation

Performance Evaluation and Feedback

Highest Level (Scale of 4)

High Level (Scale of 3)

74

55

54

72

53

70

56

Review of SMS

Encouraging results found in following key performance areas:

1.  Policy, Leadership and worker empowerment2.  Priorities and implementation planning3.  Hazard control and implementation

Review of SMS (cont’d)

Safety clearly seen as the first priority. However, relatively weak performance areas in:

1.  Roles, responsibilities and accountability2.  Competence commensurate with responsibility3.  Standards and requirements4.  Performance evaluation and feedback

Implications of IPBRM(Integrated Performance-based Risk Management)

• Integrated with other business functions and external environment

• Safety review/audit an essential tool for monitoring safety performance

• Need to– strengthen existing 2-tiered SM structure– strengthen the role of Corp. SM– empower LM and depts. to assume self-regulatory SMS– LM to devise risk control and safety audit/review strategies

for contractors, etc.

Integrated Performance-based Safety Management

• In line with current trends RBSMS could be enhanced by adopting an integrated performance-based approach

• AA could now move into the next continuous improvement phase, following by adopting the recommendations of the current review 

• Risk-based strategy can be integrated with a performance enhanced safety management system utilizing :–  Safety audits

–  Training

–  Monitoring task performance

–  Performance monitoring tools 

System Approach

Integrated Performance-based Risk Management

•Stakeholders•Regulating Agencies/units•Stakeholders•Regulating Agencies/units

The External Environment

Continuous ImprovementIntegrationSafety Management Review

Continuous ImprovementIntegrationSafety Management Review

CommunicationAudit / Review SystemCommunicationAudit / Review System

Evaluation of Performance

OSH PolicyGoals & ObjectivesPerformance StandardsSystem Planning/DevelopmentManual & Procedures

OSH PolicyGoals & ObjectivesPerformance StandardsSystem Planning/DevelopmentManual & Procedures

Formulation

OSH Process

Training SystemHazard Control SystemPrevent / Correct ActionsProcurement / Contractors

Training SystemHazard Control SystemPrevent / Correct ActionsProcurement / Contractors

Implementation / Operations

•OSH Goals & Objectives•Illness & Injury Rates•Workforce Health•Changes in Efficiency•Overall Organization Performance

•OSH Goals & Objectives•Illness & Injury Rates•Workforce Health•Changes in Efficiency•Overall Organization Performance

Safety Management System

Airport Authority

Corporate Safety ManagementManagement Commitment and ResourcesSafety Policy, Goals & Objectives

Safety SectionOSH AdvisorOverall Planning and Performance Monitoring

Corporate Safety ManagementManagement Commitment and ResourcesSafety Policy, Goals & Objectives

Safety SectionOSH AdvisorOverall Planning and Performance Monitoring

Initiation(OSH inputs)

L1 L2 L3

Contractors

Line DepartmentsEmployee Participation

Contractors Contractors

Integrated Performance-based Risk Management

SafetyPerformance(Outputs)

Conclusion

In considering a conclusion to the presentation it became apparent that a closing argument for SMS isn’t needed.

SMS clearly speaks for itself

To managemanage your organisational risksorganisational risks with a resilient risk management system.