Basis of Presentation

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Basis of Presentation

• The following notes are based on experience of
  audits in the Chemical Industry both
  operational audits and acquisition due diligence.
• Much of the experience in this field has been for
  a multi-site international manufacturer based in
  Australia, and has covered sites in the UK,
  France, Spain, Austria, The Netherlands, Egypt,
  the USA, and Canada.
• The plants concerned involve medium scale organic
  synthesis, are not large, but are complex, and
  use a wide range of flammable, toxic, corrosive
  and environmentally sensitive materials.
• Based on a multi-site organisation, it is
  nevertheless relevant to any large industrial
  enterprise with multiple operations.
• It is not unusual to combine such audits with a
  simultaneous audit of environmental issues.

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Preamble
A gentle disclaimer

• The author has little knowledge of, and no
  experience of High Energy Physics facilities. It
  is hoped however that the audience can draw
  something useful from experience in a world where
  molecules are of more concern than are particles.

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Typical factory layout
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A selection of typical plant details
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What is it?
Its a bit like a financial audit

• Similarities
• It provides an external overview
• It aims to confirm due propriety of internal
  procedures
• Differences
• It is Management initiated not a regulatory
  imposition
• A principal aim is improvement, training and
  development
• The downside is human suffering not negative
  dollars!

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Why do we have them?

• To justify fine words in policy statements
• A duty of care to employees and neighbours
• To reduce risks to the business of untoward
  events
• Management being seen to be serious about safety
• For consistent interpretation of management
  policy
• To improve safety by training and development
• Internal cross-fertilisation of experience and
  ideas

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Corporate Concerns
Hatfield UK
High Speed Derailment Oct. 2000
July 10 2003 Two rail companies and six of their
executives and staff have been charged with
manslaughter following a police investigation
into the 115 mph Hatfield rail crash.
Four fatalities and 100 injured
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Where in the overall safety scheme of things?

• Tools for Ensuring Safety

MAJOR HAZARDS
OPERATIONAL INTEGRITY
WORKPLACE SAFETY
DESIGN Hazard Analysis Risk Analysis HAZOP Protect
ion Systems
SYSTEMS Procedures Reporting Statistics
Support
ACTIVITIES Housekeeping Vigilance Notificatio
n Compliance
Inspection Tour
Design Team
Health and Safety Audit
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Who is involved?
Typical Organisation Structure
Group Management
Group HSE Manager
Third Party Independent (Occasional)
Data and Statistics
Site A Management
Site B Management
Audit Team Site B Group HSE Manager
(Chair) Safety Manager Operations rep
(varies) Management rep Site A rep
(option) (Third Party Independent)
Safety Officer
Safety Officer
Operations
Operations
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How do we go about it?
Typically annual, the main steps are
1 Collation of statistics and comparative
performance review
2 Circulate self-audit questionnaire to each
site
3 On-site review of responses and Action
Progress
4 Site tour by Audit Team
5 Round up discussion and Action Plan
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What is the Auditor looking for?

• Throughout the process, the Audit Team should be
  asking itself
• Are Systems and Procedures appropriate and
  adequate?
• Are Systems and Procedures correctly followed?
• Are the correct Documentary Records available?
• Are the HS Facilities and Equipment appropriate
  and adequate?
• Is there a general awareness of Safety as an
  issue?
• Is there a programme for safety training?
• Could the organisation respond to a serious
  emergency?

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Typical Audit Team

• Leader Senior Safety Manager
• Responsible directly to Top Management (e.g.
  Group Board)
• Not responsible for operations
• Local personnel
• Local safety officer and a management
  representative
• Operating supervisor of a specific area under
  review
• Visiting representative from another site/area
• Others (if needed)
• To give full experience cover of specialist
  technology and general operation/engineering
  (e.g. Chemist Engineer)
• Independent Neutral (Say every third audit or so)

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Actions and Feedback

• Action Programme to correct deficiencies
  identified
• Agreed actions (Where the team has authority to
  decide)
• Recommended Actions (If 0ther authorisation is
  needed)
• Include Target dates
• Progress Reviews of previous action programme
• Record Completions
• Provide early prompts
• Highlight missed dates
• Record decisions not to proceed with reasons

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Safety Statistics
To be meaningful, statistics must be consistent
and accurate

• Typical statistical analysis would include
• Injury Frequency Rates Lost time, Medical
  treatment
• Injury Severity Index extent of lost time
• Injury analysis - by type, location, worker group

Central recording and analysis ensures
consistency Care with definitions such as
Lost-time injury how many days? Figures are
only useful if lessons are learned and
improvement targets imposed Rigorous recording is
essential
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Procedures availability and adherence
Defined procedures must be set down

• Standard Operating Procedures
• Default procedures for all main operations
• Are they Available, Accessible and Clear
• Use them or change them dont ignore them
• Obtain user views
• Maintenance Safety Procedures
• Permit to Work System hot work, confined
  spaces, heights
• Isolation and Lock-off arrangements a critical
  area
• Authority to sign training essential

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Training Procedures

• Safety Training
• Management, Factory workers, Office workers
• Specialist functions (e.g. Fire, Rescue)
• Induction programmes
• New Employees
• Temporary Employees
• Contractors personnel
• Visitors

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Safety Systems
Some of the more important Systems to check

• Change Control System
• Design vetting of any modification to plant,
  process or alarm and trip functions
• Accident Reporting, Investigation and Remedial
  Actions
• Abnormal Incident Reporting
• Reporting, Investigation and Remedial Actions as
  for Accidents
• Inspection and Testing programmes
• Pressure Systems, Lifting Equipment, Access
  Equipment, etc.

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Change Control
Flixborough UK 1974
Plant modification destroys original design
integrity
Failed flexible connector
Aftermath
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Emergency Procedures
Investigate preparedness for emergencies

• Response Plan for a major emergency
• Does it exist and is it well known and understood
• Liaison with local services e.g. Fire Service?
• Internal Emergency Actions
• Fire fighters trained? equipped?
• First aiders availability and training
• Evacuation drill clearly posted? practiced?
• Notifications to management, authorities, local
  services
• Nominated person? Standard routine?

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Health and Safety Facilities

• First aid
• Location and Equipment
• Trained personnel and call-out arrangements
• Fire fighting and Rescue
• Extinguishers, breathing equipment, trained
  personnel
• Security
• Visitor control record of people on the site
• Intruder prevention

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Health monitoring policy
Requirements depend on local circumstances

• Occupational Health Issues
• General medical checks and hearing tests
• On first employment
• At regular intervals
• Specific Risk Areas
• Exposure to chemicals measurement of ambient
  levels
• Known potential health hazards
• Biological checks

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Some general comments

• Avoid a blame culture
• Encourage positive approach
• Inter site participation helps
• Numerical basis for performance assessment
• Not generally successful unless based on
  objective measures
• Subjective assessment is not usually satisfactory
• Site visits help to reinforce comments
• Photographs of areas of concern
• Review meetings are as much about Training as
  Communication

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Especially Vulnerable Situations

• Growth by Acquisition
• High Staff Turnover
• Regular use of Temporary Staff
• Extensive use of Contractors
• Language Differences

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In Conclusion
A systematic and regular audit of Safety Systems
and Performance can lead to significant
improvements.
Benefits include Consistent and effective
implementation of policy. Protection against
corporate exposure. Reductions in accident
rates. Improvements in Safety Training and
Development. Cross fertilisation in Safety
thinking. Increased awareness of the importance
attaching to Safety issues.
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Dont be like this guy!