| Department | Environmental, Health and Safety | Document no | EHS-010 | ||
| Title | Environmental, Health and Safety – Risk Management | ||||
| Prepared by: | Date: | Supersedes: | |||
| Checked by: | Date: | Date Issued: | |||
| Approved by: | Date: | Review Date: | |||
Document Owner
EHS Manager
Affected Parties
All Site colleagues
Purpose
The purpose of this SOP is to:
Describe the risk management process of identifying EHS hazards, assessing risk, designing appropriate controls and reviewing the controls.
Describe the steps to take and the tool that shall be used to undertake preliminary risk assessments (PRA).
Outline the procedure for using the DR system for reporting EHS hazards that cannot be immediately and simply resolved by the observer.
Scope
A risk assessment approach should be used for the following processes and situations:
– Prior to conducting any maintenance or installation work
– In the design of new plant, equipment and processes
– Prior to making changes to processes and equipment
– During EHS workplace inspections
– When conducting safety audits of new plant and equipment
– Organising job rotation / changes to job design
– Housekeeping audits
– Post incident / accident analysis
– Prior to purchasing new plant, equipment and chemical substances.
The EHS DR system is used to ensure that all corrective actions arising from incidents, EHS hazard identification, EHS audits (Project, operational, EHS inspections) are documented, risk rated and tracked to ensure timely and effective risk treatment implementation.
| EHS Team: | Leading EHS PRA’s and provides advise on EHS issues Monitors progress of EHS deviations through the DR system. |
| All Employees: | Are required to report hazards, incidents and accidents immediately to their line manager and the EHS Team by use of the EHS Incident notification Form. If the hazard cannot be addressed immediately, employees are required to raise a EHS DR (DR2 see SOP QMS-035). |
| Area and Line Managers: | Are responsible for managing hazards in their area of responsibility. Assign a risk rating for hazards identified in their area. In consultation with their teams, determine appropriate Corrective Action and implementation times in EHS Deviations and assign resources. Notify implementation of Corrective Action to EHS Manager. Notify their staff of hazards in their work area and actions taken to address the hazards. |
| QA | Administers Deviation Report system |
| EHS Committee: | Verify that the Corrective Action has been effective at eliminating or minimising the hazard. |
Definition
| DR | Deviation Report |
| QA | Quality Assurance Department |
| EHS | Environmental, Health and Safety |
| Hazard | An attribute of plant, equipment, processes or procedures that has the potential to cause harm to people or an environmental impact. |
| Incident (Near Hit) | An incident is an unplanned event, which could have led to harm to people, premises, the environment or the business. |
| Accident | An accident is an unplanned event, which has caused harm to people, premises or environment. The accidents are classified as fatality, major accident, significant accident or minor accident. |
| Environmental Impact | Any change to the environment resulting from organizational activities, products or services. This includes breaches of licence conditions, excess consumption of resources (electricity, gas, water) and pollution (noise, odour, visual, spills to stormwater, generation of waste, etc.) |
| Risk Rating | Obtained from the risk matrix by comparing the: Likelihood of an accident / incident occurring due to a hazard and; The Severity of the harm caused if the accident / incident occurred. The risk rating determines the priority in which the hazard is addressed. |
| Author | Any person identifying an issue that raises concerns with respect to quality, safety or the environment. |
| Description | Description of the occurrence that gave rise to the EHS DR. |
| Follow ups | Follow up items are raised to address the immediate concern (Corrective Actions) and where required the long-term Preventative Actions. |
| Corrective Action | Actions intended to overcome a particular problem |
| Preventative Action | Actions intended to prevent future occurrences |
| Summary EHS Risk Profile | Document that describes the potential hazards and the control treatments associated with a particular process/area. Used to communicate risks to personnel working in the area or with the process |
Related Documents
| Form-445 | EHS Workplace Instruction Checklist |
| Form-695 | EHS Risk Profile |
| QMS-035 | Deviation Report System |
EHS Statement
Where potential hazards exist, Line management has the responsibility to assess the risks presented, put in place controls/systems to eliminate or minimise these risks, inform their staff of potential hazards in their work area and consult with their staff on actions taken to control the hazards.
Procedure
Risk Management follows the four-step process shown below:
Figure: Risk Management Steps
1. Identification of Hazards
NOTE: When a hazard is identified, steps should be taken to fix the hazard immediately.
Do not wait for someone else to fix it.
If the hazard cannot be fixed immediately, the person who identified the hazard must notify the Area Manager and raise an EHS DR2.
1.1. It is important to consider hazards, which may arise in all situations including:
- Transport
- Installation of plant/equipment
- Commissioning of plant /equipment
- Normal operation
- Cleaning and line clearance
- Set up / change over / loading consumables / waste handling
- Maintenance
- Emergency / abnormal conditions
- Following an accident or incident
1.2. Form-445 shall be used by the EHS Committee to identify potential hazards in work area inspected.
1.3. The EHS Requirements specification includes a checklist for identifying hazards in new plant and equipment.
1.4. Potential hazards and control measures associated with maintenance, installation and process changes must be included in Change Control forms.
1.5. When reporting a EHS hazard, details of the hazard must be recorded in the Header Screen of the EHS DR (See SOP QMS-035).
1.6. The identification of hazards must be comprehensive, systematic and should consider the following:
| The work environment: | The work organisation: | The plant, equipment, tools or substances used: |
Lighting Noise levels Access / egress and layout Floors / surfaces Use of PPE | Work flow Job and task design Job rotation Rate of work Shift arrangements Competency of people using the plant Carrying loads over distances Safe working procedures. | Exposure to Toxic chemicals/gases Noisy machinery Generation of hazardous conditions due to pressurised content, electricity, radiation friction, vibration, fire, explosion, temperature, moisture, vapour, gases, dust, ice, hot or cold parts. Control systems including guarding. Stability Material used for construction. Tools and accessories Task appropriateness for plant. |
2. Assess the risk
Considerations:
2.1. Risk assessment involves analysing all of the risks associated with hazards and evaluating them to determine steps required for risk control and setting priorities.
2.2. Risk assessment considers two main factors as follows:
The likelihood that the hazard will result in injury, illness, loss or damage people, to the environment, property, plant or equipment. It is important to consider the frequency of exposure to the hazard and the potential to avoid the hazard.
The potential severity of that injury, illness, loss or damage.
2.3. The Risk Analysis Matrix combines the severity and likelihood measures to provide a level of risk from 1–6.
Figure: Assess the Risk
- Risk Level 1: Extreme risk – immediate action required, shut down plant / equipment and notify Area Manager immediately. Control measures should attempt to eliminate the hazard.
- Risk Level 2: High risk – eliminate exposure to hazard immediately.
- Risk Level 3: Significant risk – schedule appropriate corrective action for short term.
- Risk Level 4: Moderate risk – schedule corrective action for short to medium term.
- Risk Level 5: Minor risk – manage through signage, training, procedures and PPE or existing controls adequate.
- Risk Level 6: Low risk – manage through SOPs, PPE, etc. – unlikely to need specific allocation of resources or existing controls adequate.
3. EHS Preliminary Risk Assessment
EHS Risk management approach is a systematically assessing process for both new and existing facilities, processes and areas. Triggers for a EHS PRA are:
– Capital project implementation
– Introduction of new plant/equipment/processes/tasks
– Changes to plant/equipment/processes/tasks where a potential EHS impact has been identified
– Post incidents.
The EHS PRA shall be done with members from EHS committee, representatives from Project Engineering and Electrical Engineering, and one or two representatives from the processes/areas being assessed. An EHS Committee representative should also be invited to attend.
The different steps in the PRA are:
3.1. Undertaking Preliminary Risk Assessment – PRA.
Every potential hazard identified during the PRA, needs to be assigned a risk rating with the use of the Risk Analysis Matrix under 2.3. A raw risk rating shall be initially be assigned, assuming that there is no control treatment in place and a revised rating assigned after considering any existing control treatments e.g. machine hazards pre-guarding and with current guards in place. The aim is to assess the effectiveness of all existing control treatments. Where it is identified that there are ineffective control treatments in place, an EHS DR shall be raised and corrective actions assigned.
3.2. Document findings on the EHS Risk Profile Summary
All potential hazards and their risk rating for an area/process shall be summarised using
Form-380. This Summary shall be revised when there are changes made to the control treatments or the profile of the potential hazards changes. The EHS Risk Profile Summary shall be kept in the area and used to educate new staff, support periodic training and used as a reference point when reviewing the “EHS Statement” in SOP’s particular to the area or tasks. The EHS Team have the responsibility for updating the EHS Risk Profile Summary. The Area manager is the owner of the EHS Risk Profile Summary for the corresponding area.
3.3. Communicate Findings
The EHS Risk Profile Summary shall be kept in the area and the Area/line manager shall communicate findings to all personnel, particularly any new staff.
PRA documentation and copies of the EHS Risk Profile Summary shall be accessible in the area manager’s office.
3.4. Review
The Summary EHS Risk Profile will be reviewed by the Area manager, together with the EHS committee, on an annual basis or when there are changes to the process/area that have an impact on the SHE profile. The Area manager shall be responsible for enuring this occurs. All information such as incidents, incident investigations and SHE QN’ relevant to the area/process has to be reviewed.
4. Control the Risk
4.1. The Control treatments for the control of a risk describes, in order of preference, the measures that may need to be used to control a hazard. The hierarchy of control treatment is:
Elimination of the hazard – this means ‘designing out’ hazards when planning new materials, equipment, and work systems.
Substitution of the hazard – removes the hazard or substitute less hazardous materials, equipment or substances. For example, use a less toxic substance, or order smaller/lighter containers of product if manual handling is an issue.
Isolate the hazard.
Redesign – to eliminate the hazard.
Engineering Controls – modify equipment or work area.
Administrative Controls – modify work procedures, such as job rotation, routine maintenance and housekeeping procedures, provide training in relation to hazards and appropriate work procedures.
Personal Protective Equipment.
4.2. Control treatment may include several options. The control treatment/s selected must be appropriate for the level of risk associated with the hazard and should be determined in consultation with staff working with the equipment or in the area. The control treatment should address the root cause or underlying reasons for the hazard rather that treating the symptoms.
4.3. Whatever control treatment is used, the employees must be trained in any changes made to their workplace, or work methods, or use of PPE.
4.4. Additionally, to prevent the introduction of new hazards into the workplace, the hazard identification and risk assessment and control process needs to be integrated into:
Planning & design of new work environment and work tasks or changes to existing ones.
Design and procurement of plant/equipment.
Procurement of all other goods and services.
4.5. Where a EHS DR is raised to correct an identified deficiency, details of the selected risk control treatment need to be outlined in the ‘Follow up’ section of the EHS DR. The Area Manager must also nominate an appropriate time frame to implement the control measure.
5.1. The review process ensures that the implemented control measure:
Has been effective in eliminating / reducing risk from exposure to the hazard?
Has not resulted in the creation of other hazards to the work environment?
5.2. The review of control measures is the final step of the EHS DR system. Once the implementation has been completed, the EHS Committee verifies that hazards have been addressed properly by the corrective action.
5.3. Area Managers must inform their staff of actions taken to eliminate hazards from their work area.
6. Appendix 1 – Hazards and EHS Control Strategies
6.1. Introduction
This is a summary of the potential hazards that may be present within the Manufacturing operations, and the recommended EHS control strategies that shall be considered to control the hazards.
Note: There is a requirement to adequately consult with personnel working in that area when changes to the workplace are being considered.
6.2. Typical Process Hazards and their Control Strategies
| Hazards | Control Strategy |
| MATERIALS | |
| Toxic material | Assessment of the material prior to using it on site. Handle materials in ventilated area or use local exhaust ventilation. Materials only handled by adequately trained personnel. Provision of material safety data sheets for all materials. Materials are correctly labelled. Store materials in designated & secure safe location. Wear suitable PPE when handling the material. |
| Corrosive material | Assessment of the material prior to using it on site. Materials only handled by adequately trained personnel. Wear suitable PPE when handling the material. Provision of material safety data sheets for all materials. Materials are correctly labelled. Store in suitable containers away from reactive materials. Store materials in designated & secure safe location. |
| Flammable material | Assessment of the material prior to using it on site. Restrict volume stored in depot to licence limits. Store materials in designated & secure safe location. Only use flammable cleaning agents in areas where naked flames are controlled and shielded. All ignition sources, such as sparks from grinders, should be a safe distance from material. Materials only handled by adequately trained personnel. Wear suitable PPE when handling the material. Provision of material safety data sheets for all materials. Materials are correctly labelled. |
| Combustible material | All ignition sources, such as sparks from grinders, should be a safe distance from material. Good housekeeping should prevent combustible material for being put in the wrong place. Materials only handled by adequately trained personnel. Assessment the material prior to using it on site. Wear suitable PPE when handling the material. Provision of material safety data sheets for all materials. Materials are correctly labelled. |
| Irritants | Assessment of the material prior to using it on site. Wear suitable PPE when handling the material. Provision of material safety data sheets for all materials. Materials only handled by adequately trained personnel. Materials are correctly labelled. |
| Sensitisers | Assessment of the material prior to using it on site. Wear suitable PPE when handling the material. Provision of material safety data sheets for all materials. Materials only handled by adequately trained personnel. Materials are correct labelled. |
| Environmentally hazardous materials | Use the correct waste disposal methods in accordance with Material Safety Data sheets. Materials to be correctly labelled |
| Emissions to air | Use HEPA filters for all ventilation. When working with solvents, local exhaust ventilation (LEV) using carbon filter shall be provided. |
When welding, use of LEV and suitable PPE shall be worn- undertake in Workshop where possible.Emissions to water
All vessels to be adequately bundled in accordance with legal requirements and installed with high and low level alarms.
All stormwater pits shall be labelled and spill kits be provided.
All emissions to Trade wastewater will be monitored in accordance with Permit requirements.
Waste
Define, separate and label the waste streams.
Seek to identify recycle options vs disposal to landfill.
The use of solvent recovery systems will minimise the waste of solvents.
Minimise waste by “right first time” through smarter production and process innovation.
Materials only handled by adequately trained personnel.
Biological hazards
Assessment of the material prior to using it on site.
Materials only handled by adequately trained personnel.
Material only handled in controlled areas.
Material to be autoclaved/treated prior disposal to site.
Wear suitable PPE when handling the material.
Provision of the adequate information is necessary.
Sharps
Materials only handled by adequately trained personnel.
Sharp waste to be collected into sharps containers/biohazards.
Glass from vials and cartridges to be treated as sharps and segregated from other waste.
Energy
Storage at height
Control the storage of materials in racking according to local Standards.
Materials secured on pallets when in racking.
Racking to be maintained by adequately trained personnel.
Fork lifts only handled by adequately trained personnel.
Procedures in place for checking the racking regularly.
Racking locks and racking protector plates in place.
Working at height
Fall arrest systems are to be used in all situations on all unprotected heights and roofs.
All ladders to be secured before use.
All fall arrest gear to be registered, checked and maintained regularly.
Pressure
All compressed air lines must be labelled and have adequate isolation points.
All maintenance to be carried out by adequately trained personnel.
Adequate PPE shall be used and procedures in place when cleaning with compressed air
Vacuum
All maintenance on the waste granulate system to be carried out by adequately trained personnel.
Adequate procedures in place for removing materials under vacuum.
Stored energy
All equipment shall be earthed.
Areas where stored energy is shall be provided with sufficient guarding.
All steam lines must be labelled and have adequate isolation points.
All steam lines must be insulated.
Moving machinery
Power tools
Machine guarding and interlocks has to be in place according to current Australian Standards.
All work to be carried out by adequately trained personnel.
Only adequate trained staff to use grinders and lathes.
All moving machineries and power tools has to be regularly inspected and maintained.
Vehicle/forklift Traffic
All work involving pallet jacks, fork lifts and truck activity is to be carried out by adequately trained personnel.
Alarm systems to be used to indicate activity.
Clearly defined segregation of work area and pedestrian area shall be in place.
Speed limits to be defined and observed within the site.
Use of mirrors to assist in blind areas.
Vibration
Any large equipment to be assesses prior purchase on its vibration.
All vibrating machinery has to be placed on suitable surface area to dampen vibration.
Hand tools and power tools should be chosen with low vibration factor.
All maintenance work to be carried out by adequately trained personnel.
Using a hand tool/power tool shall only be used for a short periods at a time.
Heat
High temperature
All hot surfaces should be insulated/guarded and clearly labelled.
The steam system shall have built -in relief systems. The positioning of these relief systems discharge point shall take account of potential to hurt personnel working in the area
All heat sources shall be identified and isolated if possible.
Natural gas Flamers must not be located close to flammable material.
Sparks
Welding should only be carried out in designated welding bay whenever possible.
Appropriate fire extinguishers shall be close by and “standby person” appointed to the job.
Light
Visible light
Provide adequate light for all different working areas.
Monitoring of the light to ensure appropriate range.
Only use diffuse light, avoid use of naked light.
Laser
Laser in use on the lines to be positioned to avoid any contact with eyes.
All work to be carried out by adequately trained personnel.
MicrowavesMaintenance of the ovens provided by the company, regular check of the doors and seals.
Electricty
High voltage
All HV maintenance to be carried out by authorised staff.
A high voltage work plan has to be in place before any work to be undertaken and approved by Regulator
Compliance with local Standards through all work.
All high voltage equipment has to be locked and labelled.
Low voltage
All maintenance to be carried out by authorised staff.
All electrical equipment and leads be registered, tagged and tested.
Portable electrical equipment should be tagged and tested according to agreed schedule.
“Piggy backing” of Power boards should not be allowed.
All damage equipment should be taken out of service immediately and tagged as “Do Not Operate”.
Any new equipment shall be tagged, tested and registered.
Static electricity
All equipment to be earthed.
Choose where possible, low static generating material.
Maintain the humidity at an appropriate level.
Any material transfers to be earthed.
Procedures when handling/ pouring solvents into vessels.
Sound
Noise
All new equipment to be confirmed the noise level, the action limit is 85 dB (A) but the aim is to be below 80 dB (A).
When new equipment is installed the noise level of the area has to be re-assessed.
Any noise source in excess of 85 dB (A) to be noise treated, e.g. acoustic or other noise treatments.
Areas that exceed the 85 dB (A) must be sign posted, e.g. service areas.
PPE to be available.
Periodic noise levels monitoring to be done within 3 years, both inside the factory and outside.
Regularly maintenance of equipment to avoid any high frequency noise.
Ultrasound
Ultrasounds only handled by adequately trained personnel.
Equipment regularly maintained.
Ntural Hazards
Storm
The stormwater entry pits to have filters in place and regularly be cleaned (in certain areas led to the trade waste system).
All stormwater pits shall be label and spill kits provided.
Lightning
Lightning rods on all roofs.
Surge protectors in place for “critical equipment”
Work Environment
Psychosocial Workload
Normal hours of work should not exceed 12 hours before having an appropriate break of 10 hours.
Emergency work cannot exceed 16 hours before having an appropriate break of 10 hours. After emergency work, transportation to the home must be provided.
Individual have the right to consult with their managers regarding how the workload is structured and if changes can be implemented
Time to do taskWork tasks to be planned with considerations of people’s need to have regular rest breaks and task rotation.Timely provision of information/team discussion
Every team shall have regular meetings with the team and manager to discuss EHS issues, etc.
These meeting shall be documented.
Lone isolated workersSupervisor system shall be used whenever working alone and/or in isolated areas for extended periods, particularly medium/high risk tasks.
Ergonomics
Work – Machine – Person interface
Regular consultation shall to be undertaken with users of plant and equipment.
Equipment capable of being adjustable should be chosen.
Staff shall be trained in how to adjust equipment.
When designing work areas, the human interaction with the machines should be assessed including maintenance tasks. A detailed ergonomic assessment may be required.
Every task should be assessed as a part of the design layout.
Repetitive tasks
Preference to automate the tasks where possible to reduce incident or reliance on humans to do repetitive tasks.
Regular rotation shall be in place; maximum task time is 1 hr.
Highly repetitive tasks shall not be worked with for more than 20 minutes to 30 minutes.
Every person should encouraged to report early any symptoms of muscular fatigue.
When introducing a new line, a natural rotation sequence must be looked at.
Intense visual task
Regular rotation shall be in place; maximum task time is 1 hr.
Forced flexion of the head should be avoided.
Annual eye testing of inspectors should be carried out.
Only use diffused light, never naked light to avoid visual fatigue.
Lifting and carrying
Weight of lifting should ideally be below 15 kg.
Lifting aid such as cranes or roller lifters should be used when transporting heavier loads if the load is heavier than 15 kg.
Only lights items below 7 kg can be lifted above shoulder height or below hip height.
Pallet jacks, trolleys or ‘Harleys’ shall be used instead of carrying items.
Provision of appropriate training in use of mechanical aids.
Pushing and pulling
When ever possible, an electrical pallet jack should be used for heavier loads. A normal pallet jack should only be used for lighter loads.
Consider motorised trolleys for heavier loads specific to autoclaves.
Training in the right pushing and pulling technique should be used.
Provision of appropriate training in use of mechanical aids.
Summary of Changes
| Version # | Revision History |
| EHS-010 | New |