Monday, October 14, 2024
Risk Analysis Programs
Risk Analysis Programs - Design a System Safety Program for any system in any application.
https://youtu.be/rEjfdX34t-4
Introduction to the System Safety Risk Analysis Programs Course.
Risk Analysis Programs: Learning Objectives
At the end of this course, you will be able to:
- Describe fundamental risk concepts;
- Explain what a system safety approach is and does;
- Define what a risk analysis program is;
- List the hazard analysis tasks that make up a program;
- Select tasks to meet your needs;
- Design a tailored analysis program for any application; and
- Know how to get more information and resources.
get the full course
Risk Analysis Programs: Transcript
Introduction
Hello and welcome to this course on Systems Safety Risk Analysis Programs. I'm Simon Di Nucci, The Safety Artisan, and I've been a safety engineer and consultant for over 20 years.
I've worked on a wide range of safety programs doing risk analysis on all kinds of things. Ships, planes, trains, air traffic management systems, software systems, you name it. I've worked in the U.K., in Australia, and on many systems from the US.
I've also trained hundreds of people on safety. And now I'vegot the opportunity to share some of that knowledge with you online.
So, what are the benefits of this course?
First of all, you will learn about basic concepts. About system safety, what it is, and what it does. You will know how to apply a risk analysis program to a very complex system and how to manage that complexity. So, that's what you'll know.
At the end of the course, you will also be able to do things that you might not have been able to do before. You will be able to take the elements of a risk analysis program and the different tasks. Select the right tasks and form a program to suit your application, whatever it might be.
You might have a full, high-risk bespoke development system. Or take a commercial system off the shelf and do something new with it. You might be taking a product and using it in a new application or a new location. Whatever it might be, you will learn how to tailor your risk analysis program.
This program will give you the analyses you need, to meet your legal and regulatory requirements. Once you've learned how to do this, you can apply it to almost any system.
Finally, you will feel confident doing this. I will be interpreting the terminology used in the tasks and applying my experience. So, instead of reading the standard and being unsure of your interpretation, you can be sure of what you need to do. Also, I will show you how you can get good results and avoid some of the pitfalls.
So, these are the three benefits of the program:
- You will know what to do.
- You will be able to do things, and …
- You'll be feeling confident doing the tasks.
At the end of the course, I will also show you where to find further resources. There are free resources to choose from. But there are also paid resources for those who want to take their studies to the next level. I hope you enjoy the course.
Get the supporting safety analysis courses here.
Meet the Author
Learn safety engineering with me, an industry professional with 25 years of experience, I have:
•Worked on aircraft, ships, submarines, ATMS, trains, and software;
•Tiny programs to some of the biggest (Eurofighter, Future Submarine);
•In the UK and Australia, on US and European programs;
•Taught safety to hundreds of people in the classroom, and thousands online;
•Presented on safety topics at several international conferences.
#RiskAssessment #riskassess #riskassessInternettutorial #riskassessBest #riskassessBuy #riskassessFreetutorial #riskassessGet #riskassessGuide #riskassessHowto #riskassessImprove #riskassessInstruction #riskassessMethod #riskassessOnlinetutorial #riskassessReview #riskassessSolution #riskassessSolve #riskassessStudy #riskassessTechnique #riskassessThatworks #riskassessTips #riskassessTop #riskassessTraining #riskassessTutorial #riskassessValue #riskassessVideo
Simon Di Nucci https://www.safetyartisan.com/2021/01/28/risk-analysis-programs/
Friday, October 11, 2024
Guide to Establishing and Running a Project Safety Committee (PSC)
Our Second Safety Management Procedure is the Project Safety Committee. Okay, so committees are not the sexiest subject, but we need to get stakeholders together to make things happen!
Project Safety Committee: Introduction
In safety-critical industries such as defense, aerospace, and engineering, maintaining a robust safety management system (SMS) is paramount. A Project Safety Committee (PSC) plays a vital role in overseeing, coordinating, and ensuring safety compliance throughout the lifecycle of equipment and systems. This guide will explore the role, objectives, and procedures of a PSC, as defined in UK Def Stan 00-56, and provide insights on how to structure and run a PSC effectively.
What is a Project Safety Committee (PSC)?
A Safety Committee is defined as:
A group of stakeholders that exercises, oversees, reviews and endorses safety management and safety engineering activities.Def Stan 00-56
Simply put, the PSC is a formal body composed of experts and decision-makers from various disciplines, convened to ensure that safety-related decisions are well-founded, thoroughly vetted, and correctly implemented.
Objectives of a PSC
The key objectives of a PSC are to ensure effective coordination, agreement, and proper response from those with safety responsibilities. Specifically, the PSC achieves the following:
- Coordination of Safety Issues: The PSC acts as a platform where all stakeholders responsible for safety management can ensure coordination on safety issues, eliminating silos.
- Access to Knowledge: It provides decision-makers with access to relevant knowledge and expertise across different domains, including engineering, maintenance, user experience, and risk management.
- Oversight of the Safety Case: The PSC ensures competent oversight of the safety case throughout its development and maintenance.
- Audit Trail: keep detailed meeting records, and establish an audit trail showing that advice was sought and safety decisions were grounded in expertise.
The PSC should facilitate smaller working groups or sub-committees to address specific safety issues when necessary, ensuring that no aspect of the safety management process is overlooked.
In Australia, it is a legal requirement for those with safety responsibilities (Duty Holders) to consult, coordinate and cooperate with others. Other countries may use different terms for similar requirements. The bottom line is that it's a good idea!Top Tip
Project Safety Committee: Procedure
Membership of the PSC
The effectiveness of a PSC largely depends on its membership, which should include representatives with specific roles and expertise, as appropriate to the project. Typical members might include:
- Delivery Team Representatives (e.g., Project Safety Manager)
- Logistics Support Teams
- Equipment Support Teams
- Customer and User Representatives
- Prime Contractors and Subcontractors
- Design Organization
- Independent Safety Auditor
- Specialist Advisors
- Regulator / Safety Authority
- Safety and Environmental Protection Group
Moreover, it may also include contractors, consultants, and subject matter experts from other government departments or foreign defense bodies.
However, don't invite anybody and everybody 'just in case', as this devalues the PSC and its work. Top Tip
More information on PSC membership has been provided in Annex A - example Terms of Reference for a PSC.
Chair and Quorum
A critical element of any PSC is competent leadership. The PSC Chair must be a safety-competent individual holding formally-delegated authority for the program's safety tasks, typically defined in a Letter of Delegation. This document outlines the chairperson’s responsibilities and authority.
For a PSC to conduct its business, it must be quorate, meaning a minimum number of key members must be present. This quorum usually consists of:
- Delivery Team safety delegation holder
- Project Safety Manager
- Design organization representative
- Customer representative
- Safety Case author
If a quorum is not achieved, the meeting can still proceed, but decisions will only be implemented after receiving approval from the absent quorum members..
Quorum
In order for a PSC to make decisions concerning the safety of a capability or equipment, it should be declared quorate at the beginning of the meeting. In order for a PSC to be declared quorate, the following SQEP and authorized members should be in attendance:
- Delivery Team safety delegation holder
- Project Safety Manager
- Design organization
- Customer representative (Project Sponsor)
- Safety Case author
The quorate for a PSC can be expanded depending on the nature of the project. Details should be provided in the Project Safety Management Plan (SMP) or Terms of Reference.
If a quorum is not achieved, the meeting can still proceed, but decisions will only be implemented after receiving approval from the absent quorum members.
This is a good point. PSCs don't always meet frequently, and getting some members to attend can be challenging. Nevertheless, it is important to keep moving forwards.Top Tip
Meeting Frequency and Structure
PSC meetings should be scheduled regularly, though the frequency will depend on the project’s complexity and phase. Typically, meetings occur more frequently during the early design and review stages, and less frequently once the system is in service.
For smaller projects, PSC activities can be integrated into broader project meetings, ensuring safety remains a specific agenda item. Larger or more complex projects may require dedicated PSC meetings with support from Working Groups to assess hazards or system integrity.
Working Level Support
Depending on the complexity of the project, one or more working groups may be established that support the PSC by assessing hazards or reviewing the integrity of specific systems. Integrity working groups could consider structure, propulsion or other electrical or mechanical systems, reporting significant issues to the PSC.
Role of the Safety Management Committee (SMC)
For large-scale projects or portfolios, a Safety Management Committee (SMC) may be established to manage multiple PSCs across similar systems. This ensures consistency in safety management policy and strategy across projects. The SMC will oversee the activities of individual PSCs, ensuring adherence to safety management plans (SMPs).
Figure 2.1 shows an example of a Safety Committee structure, together with the management documents that sit at the relevant committee level.
Figure 2.1 - Safety Committee Structure
Safety Committee Structure
Figure 2.1 represents an example of a Safety Committee structure, with supporting working groups and hazard reviews in place. Teams can modify the structure of the Safety Committees to suit the specific organization of the program. The emphasis should be on establishing a Safety Committee with suitable chairmanship and Terms of Reference.
The structure shown in Figure 2.1 would be suitable for a large Program managing several important projects. However, it is probably overkill for most projects. With committees, less is sometimes more.Top Tip
Project Safety Committee Authority and Competence
The chairman of the PSC should hold a Letter of Delegation detailing the authority for carrying out the safety management tasks on that program.
The PSC exists to provide information and specialist advice to those who have specific responsibility for safety management on an acquisition project so that they can reach informed decisions. The Project safety delegation holder should seek and consider relevant advice through the PSC but remain the decision-maker.
While not all members of the PSC need to have specific competence and experience in Safety Management, some committee members must have this competence and are consulted. In addition to the safety delegation holder, whose competence must be established before their delegation being issued, other members of the PSC who must be safety competent would typically include the Project Safety Manager and the Independent Safety Auditor (if appointed).
As a minimum, the Project Safety Manager should have system safety competence at the practitioner level. Competence requirements for the safety delegation holder will be defined in a relevant Assignment Specification.
The level of competence needed is driven by many factors - size, complexity, novelty - and this will be discussed under a post on 'Proportionality' (TBD). Top Tip
Where beneficial, combine committees for safety and environmental management activities. Align programs as far as possible and share data where relevant.
Where there are separate safety and environmental committees, these could meet consecutively over the morning and afternoon. Members and specialists should attend as appropriate to each.
The PSC covers groups of similar projects within a Delivery Team where common activities are required. Separate committees are better for very large, high risk or diverse projects within a Delivery Team.
The PSC meets regularly as a body, or its work is included as a permanent item in another forum (in this instance care should be taken that all relevant parties are included), or simply through written communications. This last option is less desirable because there is no opportunity for direct interaction.
Record-Keeping and Documentation
Accurate record-keeping is vital to ensure transparency, accountability, and auditability. PSC meeting minutes should document:
- Attendees
- Key discussions
- Advice and recommendations
- Decisions made
- Agreed actions
These records often feed into larger project documentation, such as the System Requirements Document, Through Life Management Plan, and Safety Management System (SMS).
Review and Agreement of Safety Documents
A key PSC function is reviewing safety documents and advising the safety delegation holder on their suitability. Agreement can be recorded formally via document sign-offs or recommendations in PSC minutes. This process ensures that all safety documentation, including the Safety Case, meets the required standards before formal approval and implementation.
Risks and Pitfalls
Failure to establish or effectively run a PSC can lead to significant risks for a project, including:
- Incomplete stakeholder engagement, leading to safety requirements not being adequately defined.
- Inappropriate safety activities, if the PSC does not review and approve the SMP.
- Infrequent meetings, potentially delaying issue identification, risking project time and cost.
- Lack of clear authority, causing confusion between Enterprise and contractor responsibilities, which could shift accountability from the designers to the PSC.
By mitigating these risks through clear terms of reference, structured meetings, and well-defined roles, the PSC can ensure project safety management remains robust and reliable.
Beware of the PSC delving into detail and doing what is expedient, rather than was is needed. Set appropriate TORs and agendas and stick to them.Tip Top
If the PSC does not meet with sufficient frequency, then they may not identify in a timely manner, any issues with the safety program. This could result in impacts on project time and cost.
If the PSC attempts to control the detailed design solutions, rather than relying on the contractor’s Safety Committee and design function, then Enterprise will take responsibility from the designer. Enterprise staff will be represented on the contractor’s Safety Committee and shall exercise influence at that forum and through setting appropriate requirements.
Project Safety Committee: Timing
Formation
Establish the PSC during the Concept phase of a project by the Customer, or Requirements Manager, through the Capability Working Group, in conjunction with the relevant Project Director, to set out the safety requirements for the equipment.
The PSC has an important role to play in influencing safety requirements. This is not mentioned in 'PSC: Required Outputs', below, but is possibly the PSC's most important contribution.Top Tip
Meetings
The required frequency of the PSC meetings depends on various factors including the stage of the project, the complexity of the system, and whether the PSC is supported by Working Groups or has complete responsibility. Hold meetings at greater frequency during periods of significant review and decision-making, typically when project milestones are approaching.
PSC meetings may occur less frequently during periods of stability, such as during the in-service phase, when fewer safety decisions are necessary. However, the PSC still has an important duty to provide oversight of the Safety Case and ensure that it remains valid and monitoring safety performance. Consider whether the system or its usage is changing and seeking counter-evidence that shows the predicted level of safety performance is not being achieved in practice.
Project Safety Committee: Required Inputs
The procedure may use the following reference inputs, as available:
- Outputs from procedure SMP01 – Safety Initiation;
- Documents to be reviewed such as:
- Project Safety Management Plan;
- Independent Safety Auditor Audit Plan (if appointed);
- Independent Safety Auditor Audit Report (if appointed);
- Other Safety Audit Plans (e.g. self or Peer audit);
- Safety Audit Report;
- Hazard Log Report;
- Safety Requirements;
- Safety Assessment Report;
- Safety Case Report.
- Acquisition System Guidance Functional Competencies for System Safety Management;
- Records of previous meetings of the Safety Committee.
Project Safety Committee: Required Outputs
The outputs of the procedure will comprise:
- Established Safety Committee membership;
- Defined Terms of Reference for the Safety Committee (see Further Guidance – Examples Terms of Reference for Project Safety Committee);
- Records of Safety Committee meetings, including advice given and the actions, agreed;
- The advice given by members of the Safety Committee should include recommendations on whether a reviewed document (e.g. Safety Management Plan or Safety Case Report) should be authorized by the Project Director. If authorization is not recommended, then the reasons should be recorded.
Conclusion
The establishment and management of a Project Safety Committee (PSC) are critical to the safe delivery of defense and engineering projects. Through clear objectives, expert membership, and rigorous oversight, the PSC ensures that safety remains at the forefront of project decision-making, thereby protecting both people and assets.
By following this comprehensive guide, organizations can structure their PSCs effectively, aligning with safety standards and regulatory requirements. The PSC is not just a procedural necessity; it is a cornerstone of responsible project management in safety-critical environments.
Annex A
Example Terms of Reference for Project Safety Committee
Terms of Reference for – Project XXXX
Purpose:
To provide a forum for monitoring and coordinating all safety management and risk reduction activities associated with the project to ensure effective levels of safety and provide an appraisal of the Safety Case. The Project Safety Committee reports to the Project Director or in a larger Delivery Team to the Safety Management Committee.
Tasks:
- Set and keep under review the project’s safety policy and strategy;
- Set and keep under review the project’s safety targets and objectives;
- Define the system boundaries for safety responsibility;
- Advise the Chairperson of the Safety Committee on the safety responsibilities of each authority associated with the project;
- Advise the Chairperson of the Safety Committee on the standards, statutory regulations, and any restrictions with which the projects should comply;
- Review, monitor, classify and allocate new equipment hazards as they are identified;
- Carry out reviews of the project’s Safety Case and progress on achieving safety targets, to a predetermined program, issuing the results to the Delegated Authority;
- Agree on any control measures necessary to reduce identified risks to ALARP;
- Ensure proper and timely availability of training and issue of documentation;
- Carry out actions from ISA, regulatory or internal audit findings;
- Operate a system for reviewing and monitoring safety performance and maintain the Safety Case.
Membership:
- Delivery Team responsible for the procurement aspects of the project;
- Customer representative (Capability or Equipment Customer);
- Safety Officer (if appointed);
- Design organization;
- Delivery Team responsible for the support aspects of the project;
- Equipment User;
- Training Authority;
- Maintainer;
- Maintenance Authority;
- Specialist Advisors (as required):
- Defense Safety Regulators;
- Defense Ordnance Safety Group;
- Land Accident Prevention and Investigation Team;
- Military Aviation Accident Investigation Team;
- Serious Equipment Failure Investigation Team;
- Independent Safety Auditor;
- Interfacing Delivery Teams;
- Technical Specialists.
Acknowledgment of Copyright
In this article, I have used material from a UK Ministry of Defence guide, reproduced under the terms of the UK’s Open Government Licence.
Project Safety Committee: Who Would You Include?
#defstan0056 #DefenseSafetyAuthority #howtoselectsafetycommitteemembers #ProjectManagementSafety #ProjectSafetyCommittee #RiskManagementinEngineering #SafetyCaseManagement #safetycommittee #safetycommitteechairmanresponsibilities #safetycommitteechairpersonresponsibilities #safetycommitteediscussiontopics #safetycommitteegoalsexamples #safetycommitteeiscomprisedof #safetycommitteetermsofreference #safetycommitteevisionstatementexamples #safetyengineering #SafetyManagementCommittee #SafetyOversightinEngineering #systemsafety
Simon Di Nucci https://www.safetyartisan.com/?p=2354
Thursday, October 10, 2024
Guide to Establishing and Running a Project Safety Committee (PSC)
Our Second Safety Management Procedure is the Project Safety Committee. Okay, so committees are not the sexiest subject, but we need to get stakeholders together to make things happen!
Project Safety Committee: Introduction
In safety-critical industries such as defense, aerospace, and engineering, maintaining a robust safety management system (SMS) is paramount. A Project Safety Committee (PSC) plays a vital role in overseeing, coordinating, and ensuring safety compliance throughout the lifecycle of equipment and systems. This guide will explore the role, objectives, and procedures of a PSC, as defined in UK Def Stan 00-56, and provide insights on how to structure and run a PSC effectively.
What is a Project Safety Committee (PSC)?
A Safety Committee is defined as:
A group of stakeholders that exercises, oversees, reviews and endorses safety management and safety engineering activities.Def Stan 00-56
Simply put, the PSC is a formal body composed of experts and decision-makers from various disciplines, convened to ensure that safety-related decisions are well-founded, thoroughly vetted, and correctly implemented.
Objectives of a PSC
The key objectives of a PSC are to ensure effective coordination, agreement, and proper response from those with safety responsibilities. Specifically, the PSC achieves the following:
- Coordination of Safety Issues: The PSC acts as a platform where all stakeholders responsible for safety management can ensure coordination on safety issues, eliminating silos.
- Access to Knowledge: It provides decision-makers with access to relevant knowledge and expertise across different domains, including engineering, maintenance, user experience, and risk management.
- Oversight of the Safety Case: The PSC ensures competent oversight of the safety case throughout its development and maintenance.
- Audit Trail: keep detailed meeting records, and establish an audit trail showing that advice was sought and safety decisions were grounded in expertise.
The PSC should facilitate smaller working groups or sub-committees to address specific safety issues when necessary, ensuring that no aspect of the safety management process is overlooked.
In Australia, it is a legal requirement for those with safety responsibilities (Duty Holders) to consult, coordinate and cooperate with others. Other countries may use different terms for similar requirements. The bottom line is that it's a good idea!Top Tip
Project Safety Committee: Procedure
Membership of the PSC
The effectiveness of a PSC largely depends on its membership, which should include representatives with specific roles and expertise, as appropriate to the project. Typical members might include:
- Delivery Team Representatives (e.g., Project Safety Manager)
- Logistics Support Teams
- Equipment Support Teams
- Customer and User Representatives
- Prime Contractors and Subcontractors
- Design Organization
- Independent Safety Auditor
- Specialist Advisors
- Regulator / Safety Authority
- Safety and Environmental Protection Group
Moreover, it may also include contractors, consultants, and subject matter experts from other government departments or foreign defense bodies.
However, don't invite anybody and everybody 'just in case', as this devalues the PSC and its work. Top Tip
More information on PSC membership has been provided in Annex A - example Terms of Reference for a PSC.
Chair and Quorum
A critical element of any PSC is competent leadership. The PSC Chair must be a safety-competent individual holding formally-delegated authority for the program's safety tasks, typically defined in a Letter of Delegation. This document outlines the chairperson’s responsibilities and authority.
For a PSC to conduct its business, it must be quorate, meaning a minimum number of key members must be present. This quorum usually consists of:
- Delivery Team safety delegation holder
- Project Safety Manager
- Design organization representative
- Customer representative
- Safety Case author
If a quorum is not achieved, the meeting can still proceed, but decisions will only be implemented after receiving approval from the absent quorum members..
Quorum
In order for a PSC to make decisions concerning the safety of a capability or equipment, it should be declared quorate at the beginning of the meeting. In order for a PSC to be declared quorate, the following SQEP and authorized members should be in attendance:
- Delivery Team safety delegation holder
- Project Safety Manager
- Design organization
- Customer representative (Project Sponsor)
- Safety Case author
The quorate for a PSC can be expanded depending on the nature of the project. Details should be provided in the Project Safety Management Plan (SMP) or Terms of Reference.
If a quorum is not achieved, the meeting can still proceed, but decisions will only be implemented after receiving approval from the absent quorum members.
This is a good point. PSCs don't always meet frequently, and getting some members to attend can be challenging. Nevertheless, it is important to keep moving forwards.Top Tip
Meeting Frequency and Structure
PSC meetings should be scheduled regularly, though the frequency will depend on the project’s complexity and phase. Typically, meetings occur more frequently during the early design and review stages, and less frequently once the system is in service.
For smaller projects, PSC activities can be integrated into broader project meetings, ensuring safety remains a specific agenda item. Larger or more complex projects may require dedicated PSC meetings with support from Working Groups to assess hazards or system integrity.
Working Level Support
Depending on the complexity of the project, one or more working groups may be established that support the PSC by assessing hazards or reviewing the integrity of specific systems. Integrity working groups could consider structure, propulsion or other electrical or mechanical systems, reporting significant issues to the PSC.
Role of the Safety Management Committee (SMC)
For large-scale projects or portfolios, a Safety Management Committee (SMC) may be established to manage multiple PSCs across similar systems. This ensures consistency in safety management policy and strategy across projects. The SMC will oversee the activities of individual PSCs, ensuring adherence to safety management plans (SMPs).
Figure 2.1 shows an example of a Safety Committee structure, together with the management documents that sit at the relevant committee level.
Figure 2.1 - Safety Committee Structure
Safety Committee Structure
Figure 2.1 represents an example of a Safety Committee structure, with supporting working groups and hazard reviews in place. Teams can modify the structure of the Safety Committees to suit the specific organization of the program. The emphasis should be on establishing a Safety Committee with suitable chairmanship and Terms of Reference.
The structure shown in Figure 2.1 would be suitable for a large Program managing several important projects. However, it is probably overkill for most projects. With committees, less is sometimes more.Top Tip
Project Safety Committee Authority and Competence
The chairman of the PSC should hold a Letter of Delegation detailing the authority for carrying out the safety management tasks on that program.
The PSC exists to provide information and specialist advice to those who have specific responsibility for safety management on an acquisition project so that they can reach informed decisions. The Project safety delegation holder should seek and consider relevant advice through the PSC but remain the decision-maker.
While not all members of the PSC need to have specific competence and experience in Safety Management, some committee members must have this competence and are consulted. In addition to the safety delegation holder, whose competence must be established before their delegation being issued, other members of the PSC who must be safety competent would typically include the Project Safety Manager and the Independent Safety Auditor (if appointed).
As a minimum, the Project Safety Manager should have system safety competence at the practitioner level. Competence requirements for the safety delegation holder will be defined in a relevant Assignment Specification.
The level of competence needed is driven by many factors - size, complexity, novelty - and this will be discussed under a post on 'Proportionality' (TBD). Top Tip
Where beneficial, combine committees for safety and environmental management activities. Align programs as far as possible and share data where relevant.
Where there are separate safety and environmental committees, these could meet consecutively over the morning and afternoon. Members and specialists should attend as appropriate to each.
The PSC covers groups of similar projects within a Delivery Team where common activities are required. Separate committees are better for very large, high risk or diverse projects within a Delivery Team.
The PSC meets regularly as a body, or its work is included as a permanent item in another forum (in this instance care should be taken that all relevant parties are included), or simply through written communications. This last option is less desirable because there is no opportunity for direct interaction.
Record-Keeping and Documentation
Accurate record-keeping is vital to ensure transparency, accountability, and auditability. PSC meeting minutes should document:
- Attendees
- Key discussions
- Advice and recommendations
- Decisions made
- Agreed actions
These records often feed into larger project documentation, such as the System Requirements Document, Through Life Management Plan, and Safety Management System (SMS).
Review and Agreement of Safety Documents
A key PSC function is reviewing safety documents and advising the safety delegation holder on their suitability. Agreement can be recorded formally via document sign-offs or recommendations in PSC minutes. This process ensures that all safety documentation, including the Safety Case, meets the required standards before formal approval and implementation.
Risks and Pitfalls
Failure to establish or effectively run a PSC can lead to significant risks for a project, including:
- Incomplete stakeholder engagement, leading to safety requirements not being adequately defined.
- Inappropriate safety activities, if the PSC does not review and approve the SMP.
- Infrequent meetings, potentially delaying issue identification, risking project time and cost.
- Lack of clear authority, causing confusion between Enterprise and contractor responsibilities, which could shift accountability from the designers to the PSC.
By mitigating these risks through clear terms of reference, structured meetings, and well-defined roles, the PSC can ensure project safety management remains robust and reliable.
Beware of the PSC delving into detail and doing what is expedient, rather than was is needed. Set appropriate TORs and agendas and stick to them.Tip Top
If the PSC does not meet with sufficient frequency, then they may not identify in a timely manner, any issues with the safety program. This could result in impacts on project time and cost.
If the PSC attempts to control the detailed design solutions, rather than relying on the contractor’s Safety Committee and design function, then Enterprise will take responsibility from the designer. Enterprise staff will be represented on the contractor’s Safety Committee and shall exercise influence at that forum and through setting appropriate requirements.
Project Safety Committee: Timing
Formation
Establish the PSC during the Concept phase of a project by the Customer, or Requirements Manager, through the Capability Working Group, in conjunction with the relevant Project Director, to set out the safety requirements for the equipment.
The PSC has an important role to play in influencing safety requirements. This is not mentioned in 'PSC: Required Outputs', below, but is possibly the PSC's most important contribution.Top Tip
Meetings
The required frequency of the PSC meetings depends on various factors including the stage of the project, the complexity of the system, and whether the PSC is supported by Working Groups or has complete responsibility. Hold meetings at greater frequency during periods of significant review and decision-making, typically when project milestones are approaching.
PSC meetings may occur less frequently during periods of stability, such as during the in-service phase, when fewer safety decisions are necessary. However, the PSC still has an important duty to provide oversight of the Safety Case and ensure that it remains valid and monitoring safety performance. Consider whether the system or its usage is changing and seeking counter-evidence that shows the predicted level of safety performance is not being achieved in practice.
Project Safety Committee: Required Inputs
The procedure may use the following reference inputs, as available:
- Outputs from procedure SMP01 – Safety Initiation;
- Documents to be reviewed such as:
- Project Safety Management Plan;
- Independent Safety Auditor Audit Plan (if appointed);
- Independent Safety Auditor Audit Report (if appointed);
- Other Safety Audit Plans (e.g. self or Peer audit);
- Safety Audit Report;
- Hazard Log Report;
- Safety Requirements;
- Safety Assessment Report;
- Safety Case Report.
- Acquisition System Guidance Functional Competencies for System Safety Management;
- Records of previous meetings of the Safety Committee.
Project Safety Committee: Required Outputs
The outputs of the procedure will comprise:
- Established Safety Committee membership;
- Defined Terms of Reference for the Safety Committee (see Further Guidance – Examples Terms of Reference for Project Safety Committee);
- Records of Safety Committee meetings, including advice given and the actions, agreed;
- The advice given by members of the Safety Committee should include recommendations on whether a reviewed document (e.g. Safety Management Plan or Safety Case Report) should be authorized by the Project Director. If authorization is not recommended, then the reasons should be recorded.
Conclusion
The establishment and management of a Project Safety Committee (PSC) are critical to the safe delivery of defense and engineering projects. Through clear objectives, expert membership, and rigorous oversight, the PSC ensures that safety remains at the forefront of project decision-making, thereby protecting both people and assets.
By following this comprehensive guide, organizations can structure their PSCs effectively, aligning with safety standards and regulatory requirements. The PSC is not just a procedural necessity; it is a cornerstone of responsible project management in safety-critical environments.
Annex A
Example Terms of Reference for Project Safety Committee
Terms of Reference for – Project XXXX
Purpose:
To provide a forum for monitoring and coordinating all safety management and risk reduction activities associated with the project to ensure effective levels of safety and provide an appraisal of the Safety Case. The Project Safety Committee reports to the Project Director or in a larger Delivery Team to the Safety Management Committee.
Tasks:
- Set and keep under review the project’s safety policy and strategy;
- Set and keep under review the project’s safety targets and objectives;
- Define the system boundaries for safety responsibility;
- Advise the Chairperson of the Safety Committee on the safety responsibilities of each authority associated with the project;
- Advise the Chairperson of the Safety Committee on the standards, statutory regulations, and any restrictions with which the projects should comply;
- Review, monitor, classify and allocate new equipment hazards as they are identified;
- Carry out reviews of the project’s Safety Case and progress on achieving safety targets, to a predetermined program, issuing the results to the Delegated Authority;
- Agree on any control measures necessary to reduce identified risks to ALARP;
- Ensure proper and timely availability of training and issue of documentation;
- Carry out actions from ISA, regulatory or internal audit findings;
- Operate a system for reviewing and monitoring safety performance and maintain the Safety Case.
Membership:
- Delivery Team responsible for the procurement aspects of the project;
- Customer representative (Capability or Equipment Customer);
- Safety Officer (if appointed);
- Design organization;
- Delivery Team responsible for the support aspects of the project;
- Equipment User;
- Training Authority;
- Maintainer;
- Maintenance Authority;
- Specialist Advisors (as required):
- Defense Safety Regulators;
- Defense Ordnance Safety Group;
- Land Accident Prevention and Investigation Team;
- Military Aviation Accident Investigation Team;
- Serious Equipment Failure Investigation Team;
- Independent Safety Auditor;
- Interfacing Delivery Teams;
- Technical Specialists.
Acknowledgment of Copyright
In this article, I have used material from a UK Ministry of Defence guide, reproduced under the terms of the UK’s Open Government Licence.
Project Safety Committee: Who Would You Include?
#defstan0056 #DefenseSafetyAuthority #howtoselectsafetycommitteemembers #ProjectManagementSafety #ProjectSafetyCommittee #RiskManagementinEngineering #SafetyCaseManagement #safetycommittee #safetycommitteechairmanresponsibilities #safetycommitteechairpersonresponsibilities #safetycommitteediscussiontopics #safetycommitteegoalsexamples #safetycommitteeiscomprisedof #safetycommitteetermsofreference #safetycommitteevisionstatementexamples #safetyengineering #SafetyManagementCommittee #SafetyOversightinEngineering #systemsafety
Simon Di Nucci https://www.safetyartisan.com/?p=2354
Monday, October 7, 2024
Welcome to the New Website!
Welcome to the New Website! It has been professionally redesigned to provide a much better user experience by the awesome Sam Jusaitis. My thanks to him for doing such a great job.
The Main Pages
You can now browse through the main pages, which give you all the content that you might need, in the order that you choose it:
- Topics. This page showcases the main safety topics that I cover, so far they are:
- Start Here. Mostly free introductory videos for those new to safety;
- Safety Analysis. A complete and in-depth suite of lessons on this subject; and
- Work Health & Safety. All you need to know about Australian WHS legislation and practice.
- About. Some information about The Safety Artisan - why you would choose safety tuition from me.
- Connect. Here, you can sign up for free email newsletters, subscribe to our YouTube Channel, and follow us on social media.
- Frequently Asked Questions. The most commonly Googled questions are here, with links to posts and videos that answer them.
- Checkout. You'll get there if you purchase any of the downloadable videos and content - but there's plenty of free stuff too!
Welcome to the New Website Logo
Sam also designed the new logo, which reminds some people of the human eye. It was actually derived from the shapes of various warning signs, as shown below. Clever, eh?
Meet the Author
Learn safety engineering with me, an industry professional with 25 years of experience, I have:
•Worked on aircraft, ships, submarines, ATMS, trains, and software;
•Tiny programs to some of the biggest (Eurofighter, Future Submarine);
•In the UK and Australia, on US and European programs;
•Taught safety to hundreds of people in the classroom, and thousands online;
•Presented on safety topics at several international conferences.
#coursesafetyengineering #engineersafety #ineedsafety #knowledgeofsafety #learnsafety #needforsafety #safetyartisan #safetyblog #safetydo #safetyengineer #safetyengineerskills #safetyengineertraining #safetyengineering #safetyengineeringcourse #safetyprinciples #safetytraining #softwaresafety #theneedforsafety #Welcome
Simon Di Nucci
https://www.safetyartisan.com/2020/11/29/welcome-to-the-new-website/
Welcome to the New Website! It has been professionally redesigned to provide a much better user experience by the awesome Sam Jusaitis. My thanks to him for doing such a great job.
The Main Pages
You can now browse through the main pages, which give you all the content that you might need, in the order that you choose it:
- Topics. This page showcases the main safety topics that I cover, so far they are:
- Start Here. Mostly free introductory videos for those new to safety;
- Safety Analysis. A complete and in-depth suite of lessons on this subject; and
- Work Health & Safety. All you need to know about Australian WHS legislation and practice.
- About. Some information about The Safety Artisan - why you would choose safety tuition from me.
- Connect. Here, you can sign up for free email newsletters, subscribe to our YouTube Channel, and follow us on social media.
- Frequently Asked Questions. The most commonly Googled questions are here, with links to posts and videos that answer them.
- Checkout. You'll get there if you purchase any of the downloadable videos and content - but there's plenty of free stuff too!
Welcome to the New Website Logo
Sam also designed the new logo, which reminds some people of the human eye. It was actually derived from the shapes of various warning signs, as shown below. Clever, eh?
Meet the Author
Learn safety engineering with me, an industry professional with 25 years of experience, I have:
•Worked on aircraft, ships, submarines, ATMS, trains, and software;
•Tiny programs to some of the biggest (Eurofighter, Future Submarine);
•In the UK and Australia, on US and European programs;
•Taught safety to hundreds of people in the classroom, and thousands online;
•Presented on safety topics at several international conferences.
#coursesafetyengineering #engineersafety #ineedsafety #knowledgeofsafety #learnsafety #needforsafety #safetyartisan #safetyblog #safetydo #safetyengineer #safetyengineerskills #safetyengineertraining #safetyengineering #safetyengineeringcourse #safetyprinciples #safetytraining #softwaresafety #theneedforsafety #Welcome
Simon Di Nucci
https://www.safetyartisan.com/2020/11/29/welcome-to-the-new-website/
Monday, September 30, 2024
Consultation, Cooperation & Coordination CoP
In this 30-minute session, we look at the Consultation, Cooperation & Coordination Code of Practice (CC&C CoP). We cover the Commonwealth and Model versions of the CoP, appendices & a summary of detailed requirements; and further commentary. This CoP is one of the two that are generally applicable.
https://youtu.be/CARK4tJnX28
This is the three-minute demo of the full, 30-minute video.
buy the full-length video here
Consultation, Cooperation & Coordination CoP: Topics
- CC&C in the Federal or Commonwealth CoP;
- Extra CC&C in the Model CoP;
- (Watch out for Jurisdiction);
- Further commentary; and
- Where to get more information.
Consultation, Cooperation & Coordination CoP: Transcript
Click Here for the Transcript
Consultation, Cooperation & Coordination CoP
Hello, everyone, and welcome to The Safety Artisan. I'm Simon and today we're going to be talking about a very useful subject, which is Codes of Practice. And one Code of Practice in particular, which is the Code of Practice for Consultation, Cooperation and Coordination. And it doesn't sound like the most exciting subject, I'll admit, but this is one of only two Codes of Practice that you must be aware of if operating in Australia, or exporting to Australia, or importing stuff to Australia, whatever it might be. The other Code of Practice that you must be aware of is the Risk Management Code of Practice. There are a lot more Code of Practices than these two, but they don't always apply. So, I mean if you're not doing anything to do with asbestos, you don't have to worry about what it says in the Asbestos Code of Practice. But this one you do because it applies to everything.
Topics for this Session
And I've used this Code of Practice to help clients and to do particular things and help everybody understand what we have to do, and it’s very useful. And in this session, I will be explaining how to get the best out of this Code of Practice and, at the end, where to get more information. So, I hope you'll find that useful. So we're going to be talking about the - I'm just going to call it the C, C & C CoP for short because it's a dreadful mouthful, isn't it? We're going to be looking at the federal or Commonwealth Code of Practice and then we're going to look at some extras in the Model Code of Practice. So just to explain that briefly, the Model Code of Practice is on the Safe Work Australia website, and that is the Model from which all other CoPs are developed. However, Safe Work Australia is not a regulator. So individual regulators and the example I'm using is the Commonwealth one- or Comcare, as it's known- they have chosen to edit the Model CoP and change it and remove quite a bit of material. Now, why they chose to do that, I do not know. So, you have to be careful which jurisdiction you're operating in, in Australia. If you are in a Commonwealth workplace, then you need to apply the Commonwealth or the federal version of WHS, including this CoP. And if you're in a state or territory workplace, or a commercial workplace in a state or territory, you need to apply the relevant one there. And just to complicate matters, Western Australia has not yet introduced WHS and Victoria has no plans to do so. So, of course, in Australia, we like to make life simple for ourselves, don't we? Oh no, we don't!
So after I've gone through some basics of what's in the CoP, because you'll see there's an awful lot of material in there that I'm not going to talk about. I produced some commentary that I think you will find helpful and where to get more information, as I promised. So, let's get on with it!
When to Consult
So, first of all- and you'll notice that I'm only including those bits really that say when you must do something. So, this is quoting Section 49 of the WHS Act, which says that if you're conducting a business or some kind of undertaking- so it's not just a commercial business, but anything- you must consult with your workers when identifying hazards and assessing risks, making decisions about how you're going to control those risks, making decisions about the adequacy of facilities for welfare, proposing changes that affect health and safety, and making decisions about procedures for consulting with workers, providing information and training, and so on and so forth. So, there's a whole raft of things that you have to consult your workers on. So, this is all workplace so far. Now, in my role as a safety consultant, I'm often working with people who are introducing they're buying bits of kit, or designing or importing bits of kit, and there is no work yet, so there's no workers. But we always try and get a representative of the end-user involved because that really does help you do good quality safety work and avoid- to be honest- wasting time and money on things that are theoretically possible or theoretically sound problematic but in reality, it just doesn't arise for whatever reason. So, I really do recommend getting those end-user representatives involved.
Effective Consultation
And if we go on to Section 48- for some reason, the cop quotes these things in reverse order- to be effective in consultation, we require information to be shared. Workers have got to have a reasonable opportunity to express their views. They've got to have a reasonable opportunity to contribute to decisions. Their views must be taken into account and they must be advised of the outcomes of consultation. So, all good common-sense stuff, I would think. Nothing controversial about this and that- to be honest- that's a feature of CoPs. They tell you to do things that you think, “Yeah, I really ought to be doing that!”.
Consultation Procedures
Continuing with the countdown, we're on to Section 47. Consultation procedures, again more basic common sense. If you’ve agreed to procedures for consultation, you must follow those procedures. It's not rocket science, is it, folks? Let's move on.
Sections 16 & 46
OK, now this is a bit more interesting, I think. This is getting into the real guts of this Code of Practice because where consultation, cooperation and coordination really come into play is where you've got multiple stakeholders, multiple duty holders- that is to say, those with a duty to protect the health and safety of people. Where multiple stakeholders, duty holders, have to get together and work together in order to come up with a solution. So the law says- Section 16 says where more than one person has a duty for the same thing, for the same matter, each person retains that responsibility. You cannot wriggle out of your responsibility just because you only control a bit over here and not over here. So, the two duty holders who have control here and here, they have to work together. The law says so. And so this is really the guts of this Code of Practice. And they must work together to discharge their duties to the extent to which they can. And the extent to which you can is the extent to which you influence and control the matter. So, WHS law is very big about control. If you have control of the bit, you've got to do your bit and you must work with people who have control of other things. You might be designing or buying a piece of kit. Other people might control the workplace. There might be another group of people who represent the operators, and then another group who represent the maintainers, and so on and so forth. They've all got to be involved if they're relevant to managing risk. And of course, as risk in WHS is cradle to grave, then pretty much everyone is involved.
So, Section 46, and in these situations where you have got multiple duty holders, each person with a duty must, so far as is reasonably practicable, consult, cooperate and coordinate with all other persons. And I'm going to do a session quite soon on so far as is reasonably practicable, or SOFARP, and in it, I will tell you that SOFARP is an objective test and the law sets objective expectations for what a reasonable person would do. So, you can't just say, “Well, I'll decide what is reasonable or not reasonable.”. The law has already done it for you and there's guidance out there to help you so follow it. So, we will do something on that guidance, about what is reasonable and what is reasonably practicable. But we've got to work with each other SOFARP. For the greater good! Sorry, that's a quote from one of my favourite comedy films, by the way.
CoP Appendices
So, appendices to the CoP. If we look at the appendices in the federal or Commonwealth CoP, there are only three. So, they've got some examples of arrangements. They've got a consultation checklist, and they've got an appendix on C, C and C activities, which is all good. That's all good stuff. In addition, if you go back to the Model Code of Practice, you will find that there's also a glossary. Yes, they've got the consultation checklist. And then in Appendix E, you've got a summary of all the consultation requirements in the WHS regulations, which is really useful. So even if in the CoP that applies to you, your version of the CoP doesn't have the appendix, I would recommend going and having a look in the Model CoP. And if you're not aware what you got, if you've got a high-risk business, then you're going to find some extra requirements in the regulations. So, I would go and have a look at Appendix E if you're doing anything that could kill one or more people. So, if you're dealing with more serious risks, then I would go and have a look at that just to- as a good lead in to the regulations. If you already know the regulations backwards, then great, you don't need to bother. But there are over 600 regulations in WHS, so it's always worth checking up to make sure you haven't missed anything.
Extras in the Model CoP
We've kind of started already, but now we've really started we're going to talk about the extras in the Model Code of Practice.
Further Duties of PCBUs
In the modal Code of Practice, we get a reminder that designers, manufacturers, importers and suppliers have got safety responsibilities to ensure, so far as is reasonably practicable, that the plant's substance or structure that they are designing, etc, etc, is without risks to health and safety. And they've got a duty to carry out testing and analysis and to provide specific safety-related information about plant or substance. So there's a good reminder in there that we all, wherever we are in the supply chain, we've all got these responsibilities. And to assist in meeting these duties, the WHS regulations require manufacturers to consult with designers, importers to consult with designers and manufacturers, and whoever commissions construction work to consult with the designer of the structure, for example. There's a lot of useful extra pointers in the Model Code of Practice, which may not be in the version that, technically speaking/strictly speaking, you have to follow. So, worth a look.
Officers (of the PCBU)
And then there's also a reminder to officers of the business or undertaking. Basically, officers says- for example, company directors, those kinds of people, have a duty to exercise due diligence. And you have to go look at due diligence to see what that is. There are basically six bullet points in the act that describe due diligence. Again, it's all good common-sense stuff. There’s nothing esoteric in there or objectionable. And that due diligence includes taking reasonable steps to ensure that you've got appropriate processes for complying with the duty to consult as well as to duty- with workers sorry, as well as consulting, cooperating and coordinating with other duty holders. And there's further guidance on what's an officer in that interpretive guideline and under Section 27 of the law.
Principal Contractors
And then here is one I picked out. I've not got all of the requirements, but here's a useful one. There’s a particular regulation, number 309, that says if you're doing construction work the principal contractor for a construction project has a specific duty under WHS regulations to document in their WHS management plan the arrangements for consultation, cooperation and coordination. Now that's not unique, as we've just seen, to construction, but there is a specific requirement in there for a principal contractor. And WHS assumes a particular structure where you've got a prime contractor, or a principal contractor, who is leading the construction for the customer. So, have a look at that. There's also a CoP on the construction of structures so if you're in that game you'll find that useful too.
Major Hazard Facilities
And then I've got one slide on major hazard facilities. Now, a major hazard facility, strictly speaking, is a facility where you've got enough of a dangerous chemical- and it might be flammable, it might be toxic, it might be explosive, whatever it is. There's a whole list of chemicals in the regulations and it says if you've got so many tons of this or that, you've hit the threshold and you are operating a major hazard facility. There's a whole raft of extra regulations that apply to MHFs. And it says, for example, regulation 552 requires a major facility- sorry, a major hazard facilities safety case outline- so a safety case report by another name- to include a description of the consultation with workers that's been undertaken in the preparation of the safety case. Again, you've got a very specific requirement to consult with workers and to document it. Which, interestingly enough, generally, you don't have a duty to do that. It's not mandatory to document consultation. It's recommended. It's a good idea but you don't, strictly speaking, have to do it unless you're operating an MHF. And as it says there, there's a whole bunch of regulations that cover consultation about MHFs. But as I said, if you look at Appendix E of the Model Code of Practice, it's got them all listed, which is very helpful.
Detailed Requirements
A quick word about detailed requirements. Every Code of Practice contains detailed requirements that follow this formula. So, there are three words that indicate a legal requirement that must be complied with. And those three words are ‘must’, ‘requires’- or variations on that word-, and ‘mandatory’. So, any instances of those words- Probably not always, because they occasionally you come across a usage of ‘must’ or ‘requires’ where you go “Actually, that's just an English use-“ (if you know what I mean)- “That’s just an English use of those words! It’s not really indicating a mandatory requirement”. But most of them do. So, in the Commonwealth Code of Practice, we have 41 instances of ‘must’. So, you've got to comply with those. You have 46 instances of ‘require’ and you've got to comply with those by law. Now, interestingly, in the Model Code of Practice, those numbers go up to 71 and 58, respectively. So, there're a lot more requirements in the Model Code of Practice. So, again, do make sure you've got the right Code of Practice that's been issued by the regulator for your jurisdiction. Because otherwise you might miss something you need to comply with or you might be complying with something that, strictly speaking, you don't have to. Although, of course, it's not a bad thing to do that but you don't have to.
Then there's the use of the word ‘should’, which is a recommended course of action, and ‘may’, suggests something that is optional. And again, in the Commonwealth Code of Practice, there are 62 instances of ‘should’ and 86 of ‘may’. Although I note that one of those instances of may, at least one, refers to the month of May when that Code of Practice was published. So, you've got to go through and make sure that they are relevant. And then it's slightly more in the Model Code of Practice. It’s 66 and 90, respectively. But the difference is not so great for the mandatory stuff. Now as I've said before, and in the risk management Code of Practice, my advice to you is you must comply with ‘musts’ and ‘required’s. ‘Should’ is recommendation so I would suggest complying with that unless you've got a good reason not to. In which case, I would document the fact that you've got a good reason not to and why you're not going to. And then ‘may’ is optional. You can do it if you want to and you can record the fact that you've considered those things and reject them if you want to but they are only options. So, I think there's- effectively we've got three tiers here. We've got ‘must comply’, ‘recommended’, and ‘you can do this if you think it's a good idea’.
And so the comment at the bottom, CoPs are not huge documents that typically a few tens of pages long. They will repay careful reading because you do have to comply with quite a lot of stuff that's in there and that's very clearly signposted, by the way. And also, of course, this particular Code of Practice is very useful for safety management plans. If you've got to write a safety management plan and you want to know what you have to include in it, then look in this Code of Practice and look in the Risk Management Code of Practice and make sure you include everything that is mandatory or ‘must’ or ‘requires’ and look at all the other stuff as well. And why not? If the copyright permits you to do so, which it usually does- not always, but usually. If the copyright permits you to do so and just copy and paste the stuff into your plan and then you know that you've got what you need. Then you can change the wording if you need to. But it will save you a lot of bother if you've got to write a safety management plan. It'll help you to make sure you've got everything you need to and it will save you a lot of effort. So, I recommend that I've done that myself.
Commentary #1
I think I've just got a couple of slides of commentary. It's worth reiterating that Codes of Practice are for all Australian industry. Whether it be a sole trader like myself operating out of our study or their garage or something, or whether it be a small operation- a family-run garage or shop, or whether it be the biggest corporation in Australia, whoever that is- if you're running a major mining operation. So, Codes of Practice provide minimum requirements. These are the things that you must comply with. In high-risk industries, you're probably going to have to do a lot more. And they do have a workplace application. So, they are written for the workplace. They're not really written for the designer, manufacturer, importer, supplier, etc. But nevertheless, it is very, very helpful if you are those people to look at the CoP in order to get an idea of what your customers have got to comply with and therefore what you're going to have to supply.
And as I've already said, CoP will repay careful reading because whilst they are guidance, they are really more than guidance. If you are ignorant of CoP and you don't do what they say you are exposing yourself to prosecution. So, see my introduction to Codes of Practice where I talk about that. There are three reasons why you must be aware of Codes of Practice. And this is one of those two Codes of Practice that everyone must be aware of. The others- if you're working with asbestos or welding or whatever it might be then there are specific Codes of Practice that you must be aware of for those activities. But this is one of those ones that applies to absolutely everybody, potentially. And as I've said before, the Model CoP has more detail than maybe some of the regulator-enforced Codes of Practice, which you will, I think, find helpful for higher risk applications. Whether legally you've got an MHF or not.
Commentary #2
And in fact, that's my point in slide two. So, not everyone is required to have a formal safety management system for managing safety risk in a- while something is in service, while it's being used. So, this CoP does not require us to have a formal safety management system, but it is required for major hazard facilities.
#AustralianWHS #CodesofPractice #Consult #Cooperate #Coordinate #coursesafetyengineering #engineersafety #ineedsafety #knowledgeofsafety #learnsafety #needforsafety #safetyblog #safetydo #safetyengineer #safetyengineerskills #safetyengineertraining #safetyengineeringcourse #safetyprinciples #softwaresafety #theneedforsafety #WHSCodeofPractice
Simon Di Nucci
https://www.safetyartisan.com/2020/11/21/consultation-cooperation-coordination-cop/
In this 30-minute session, we look at the Consultation, Cooperation & Coordination Code of Practice (CC&C CoP). We cover the Commonwealth and Model versions of the CoP, appendices & a summary of detailed requirements; and further commentary. This CoP is one of the two that are generally applicable.
https://youtu.be/CARK4tJnX28
This is the three-minute demo of the full, 30-minute video.
buy the full-length video here
Consultation, Cooperation & Coordination CoP: Topics
- CC&C in the Federal or Commonwealth CoP;
- Extra CC&C in the Model CoP;
- (Watch out for Jurisdiction);
- Further commentary; and
- Where to get more information.
Consultation, Cooperation & Coordination CoP: Transcript
Click Here for the Transcript
Consultation, Cooperation & Coordination CoP
Hello, everyone, and welcome to The Safety Artisan. I'm Simon and today we're going to be talking about a very useful subject, which is Codes of Practice. And one Code of Practice in particular, which is the Code of Practice for Consultation, Cooperation and Coordination. And it doesn't sound like the most exciting subject, I'll admit, but this is one of only two Codes of Practice that you must be aware of if operating in Australia, or exporting to Australia, or importing stuff to Australia, whatever it might be. The other Code of Practice that you must be aware of is the Risk Management Code of Practice. There are a lot more Code of Practices than these two, but they don't always apply. So, I mean if you're not doing anything to do with asbestos, you don't have to worry about what it says in the Asbestos Code of Practice. But this one you do because it applies to everything.
Topics for this Session
And I've used this Code of Practice to help clients and to do particular things and help everybody understand what we have to do, and it’s very useful. And in this session, I will be explaining how to get the best out of this Code of Practice and, at the end, where to get more information. So, I hope you'll find that useful. So we're going to be talking about the - I'm just going to call it the C, C & C CoP for short because it's a dreadful mouthful, isn't it? We're going to be looking at the federal or Commonwealth Code of Practice and then we're going to look at some extras in the Model Code of Practice. So just to explain that briefly, the Model Code of Practice is on the Safe Work Australia website, and that is the Model from which all other CoPs are developed. However, Safe Work Australia is not a regulator. So individual regulators and the example I'm using is the Commonwealth one- or Comcare, as it's known- they have chosen to edit the Model CoP and change it and remove quite a bit of material. Now, why they chose to do that, I do not know. So, you have to be careful which jurisdiction you're operating in, in Australia. If you are in a Commonwealth workplace, then you need to apply the Commonwealth or the federal version of WHS, including this CoP. And if you're in a state or territory workplace, or a commercial workplace in a state or territory, you need to apply the relevant one there. And just to complicate matters, Western Australia has not yet introduced WHS and Victoria has no plans to do so. So, of course, in Australia, we like to make life simple for ourselves, don't we? Oh no, we don't!
So after I've gone through some basics of what's in the CoP, because you'll see there's an awful lot of material in there that I'm not going to talk about. I produced some commentary that I think you will find helpful and where to get more information, as I promised. So, let's get on with it!
When to Consult
So, first of all- and you'll notice that I'm only including those bits really that say when you must do something. So, this is quoting Section 49 of the WHS Act, which says that if you're conducting a business or some kind of undertaking- so it's not just a commercial business, but anything- you must consult with your workers when identifying hazards and assessing risks, making decisions about how you're going to control those risks, making decisions about the adequacy of facilities for welfare, proposing changes that affect health and safety, and making decisions about procedures for consulting with workers, providing information and training, and so on and so forth. So, there's a whole raft of things that you have to consult your workers on. So, this is all workplace so far. Now, in my role as a safety consultant, I'm often working with people who are introducing they're buying bits of kit, or designing or importing bits of kit, and there is no work yet, so there's no workers. But we always try and get a representative of the end-user involved because that really does help you do good quality safety work and avoid- to be honest- wasting time and money on things that are theoretically possible or theoretically sound problematic but in reality, it just doesn't arise for whatever reason. So, I really do recommend getting those end-user representatives involved.
Effective Consultation
And if we go on to Section 48- for some reason, the cop quotes these things in reverse order- to be effective in consultation, we require information to be shared. Workers have got to have a reasonable opportunity to express their views. They've got to have a reasonable opportunity to contribute to decisions. Their views must be taken into account and they must be advised of the outcomes of consultation. So, all good common-sense stuff, I would think. Nothing controversial about this and that- to be honest- that's a feature of CoPs. They tell you to do things that you think, “Yeah, I really ought to be doing that!”.
Consultation Procedures
Continuing with the countdown, we're on to Section 47. Consultation procedures, again more basic common sense. If you’ve agreed to procedures for consultation, you must follow those procedures. It's not rocket science, is it, folks? Let's move on.
Sections 16 & 46
OK, now this is a bit more interesting, I think. This is getting into the real guts of this Code of Practice because where consultation, cooperation and coordination really come into play is where you've got multiple stakeholders, multiple duty holders- that is to say, those with a duty to protect the health and safety of people. Where multiple stakeholders, duty holders, have to get together and work together in order to come up with a solution. So the law says- Section 16 says where more than one person has a duty for the same thing, for the same matter, each person retains that responsibility. You cannot wriggle out of your responsibility just because you only control a bit over here and not over here. So, the two duty holders who have control here and here, they have to work together. The law says so. And so this is really the guts of this Code of Practice. And they must work together to discharge their duties to the extent to which they can. And the extent to which you can is the extent to which you influence and control the matter. So, WHS law is very big about control. If you have control of the bit, you've got to do your bit and you must work with people who have control of other things. You might be designing or buying a piece of kit. Other people might control the workplace. There might be another group of people who represent the operators, and then another group who represent the maintainers, and so on and so forth. They've all got to be involved if they're relevant to managing risk. And of course, as risk in WHS is cradle to grave, then pretty much everyone is involved.
So, Section 46, and in these situations where you have got multiple duty holders, each person with a duty must, so far as is reasonably practicable, consult, cooperate and coordinate with all other persons. And I'm going to do a session quite soon on so far as is reasonably practicable, or SOFARP, and in it, I will tell you that SOFARP is an objective test and the law sets objective expectations for what a reasonable person would do. So, you can't just say, “Well, I'll decide what is reasonable or not reasonable.”. The law has already done it for you and there's guidance out there to help you so follow it. So, we will do something on that guidance, about what is reasonable and what is reasonably practicable. But we've got to work with each other SOFARP. For the greater good! Sorry, that's a quote from one of my favourite comedy films, by the way.
CoP Appendices
So, appendices to the CoP. If we look at the appendices in the federal or Commonwealth CoP, there are only three. So, they've got some examples of arrangements. They've got a consultation checklist, and they've got an appendix on C, C and C activities, which is all good. That's all good stuff. In addition, if you go back to the Model Code of Practice, you will find that there's also a glossary. Yes, they've got the consultation checklist. And then in Appendix E, you've got a summary of all the consultation requirements in the WHS regulations, which is really useful. So even if in the CoP that applies to you, your version of the CoP doesn't have the appendix, I would recommend going and having a look in the Model CoP. And if you're not aware what you got, if you've got a high-risk business, then you're going to find some extra requirements in the regulations. So, I would go and have a look at Appendix E if you're doing anything that could kill one or more people. So, if you're dealing with more serious risks, then I would go and have a look at that just to- as a good lead in to the regulations. If you already know the regulations backwards, then great, you don't need to bother. But there are over 600 regulations in WHS, so it's always worth checking up to make sure you haven't missed anything.
Extras in the Model CoP
We've kind of started already, but now we've really started we're going to talk about the extras in the Model Code of Practice.
Further Duties of PCBUs
In the modal Code of Practice, we get a reminder that designers, manufacturers, importers and suppliers have got safety responsibilities to ensure, so far as is reasonably practicable, that the plant's substance or structure that they are designing, etc, etc, is without risks to health and safety. And they've got a duty to carry out testing and analysis and to provide specific safety-related information about plant or substance. So there's a good reminder in there that we all, wherever we are in the supply chain, we've all got these responsibilities. And to assist in meeting these duties, the WHS regulations require manufacturers to consult with designers, importers to consult with designers and manufacturers, and whoever commissions construction work to consult with the designer of the structure, for example. There's a lot of useful extra pointers in the Model Code of Practice, which may not be in the version that, technically speaking/strictly speaking, you have to follow. So, worth a look.
Officers (of the PCBU)
And then there's also a reminder to officers of the business or undertaking. Basically, officers says- for example, company directors, those kinds of people, have a duty to exercise due diligence. And you have to go look at due diligence to see what that is. There are basically six bullet points in the act that describe due diligence. Again, it's all good common-sense stuff. There’s nothing esoteric in there or objectionable. And that due diligence includes taking reasonable steps to ensure that you've got appropriate processes for complying with the duty to consult as well as to duty- with workers sorry, as well as consulting, cooperating and coordinating with other duty holders. And there's further guidance on what's an officer in that interpretive guideline and under Section 27 of the law.
Principal Contractors
And then here is one I picked out. I've not got all of the requirements, but here's a useful one. There’s a particular regulation, number 309, that says if you're doing construction work the principal contractor for a construction project has a specific duty under WHS regulations to document in their WHS management plan the arrangements for consultation, cooperation and coordination. Now that's not unique, as we've just seen, to construction, but there is a specific requirement in there for a principal contractor. And WHS assumes a particular structure where you've got a prime contractor, or a principal contractor, who is leading the construction for the customer. So, have a look at that. There's also a CoP on the construction of structures so if you're in that game you'll find that useful too.
Major Hazard Facilities
And then I've got one slide on major hazard facilities. Now, a major hazard facility, strictly speaking, is a facility where you've got enough of a dangerous chemical- and it might be flammable, it might be toxic, it might be explosive, whatever it is. There's a whole list of chemicals in the regulations and it says if you've got so many tons of this or that, you've hit the threshold and you are operating a major hazard facility. There's a whole raft of extra regulations that apply to MHFs. And it says, for example, regulation 552 requires a major facility- sorry, a major hazard facilities safety case outline- so a safety case report by another name- to include a description of the consultation with workers that's been undertaken in the preparation of the safety case. Again, you've got a very specific requirement to consult with workers and to document it. Which, interestingly enough, generally, you don't have a duty to do that. It's not mandatory to document consultation. It's recommended. It's a good idea but you don't, strictly speaking, have to do it unless you're operating an MHF. And as it says there, there's a whole bunch of regulations that cover consultation about MHFs. But as I said, if you look at Appendix E of the Model Code of Practice, it's got them all listed, which is very helpful.
Detailed Requirements
A quick word about detailed requirements. Every Code of Practice contains detailed requirements that follow this formula. So, there are three words that indicate a legal requirement that must be complied with. And those three words are ‘must’, ‘requires’- or variations on that word-, and ‘mandatory’. So, any instances of those words- Probably not always, because they occasionally you come across a usage of ‘must’ or ‘requires’ where you go “Actually, that's just an English use-“ (if you know what I mean)- “That’s just an English use of those words! It’s not really indicating a mandatory requirement”. But most of them do. So, in the Commonwealth Code of Practice, we have 41 instances of ‘must’. So, you've got to comply with those. You have 46 instances of ‘require’ and you've got to comply with those by law. Now, interestingly, in the Model Code of Practice, those numbers go up to 71 and 58, respectively. So, there're a lot more requirements in the Model Code of Practice. So, again, do make sure you've got the right Code of Practice that's been issued by the regulator for your jurisdiction. Because otherwise you might miss something you need to comply with or you might be complying with something that, strictly speaking, you don't have to. Although, of course, it's not a bad thing to do that but you don't have to.
Then there's the use of the word ‘should’, which is a recommended course of action, and ‘may’, suggests something that is optional. And again, in the Commonwealth Code of Practice, there are 62 instances of ‘should’ and 86 of ‘may’. Although I note that one of those instances of may, at least one, refers to the month of May when that Code of Practice was published. So, you've got to go through and make sure that they are relevant. And then it's slightly more in the Model Code of Practice. It’s 66 and 90, respectively. But the difference is not so great for the mandatory stuff. Now as I've said before, and in the risk management Code of Practice, my advice to you is you must comply with ‘musts’ and ‘required’s. ‘Should’ is recommendation so I would suggest complying with that unless you've got a good reason not to. In which case, I would document the fact that you've got a good reason not to and why you're not going to. And then ‘may’ is optional. You can do it if you want to and you can record the fact that you've considered those things and reject them if you want to but they are only options. So, I think there's- effectively we've got three tiers here. We've got ‘must comply’, ‘recommended’, and ‘you can do this if you think it's a good idea’.
And so the comment at the bottom, CoPs are not huge documents that typically a few tens of pages long. They will repay careful reading because you do have to comply with quite a lot of stuff that's in there and that's very clearly signposted, by the way. And also, of course, this particular Code of Practice is very useful for safety management plans. If you've got to write a safety management plan and you want to know what you have to include in it, then look in this Code of Practice and look in the Risk Management Code of Practice and make sure you include everything that is mandatory or ‘must’ or ‘requires’ and look at all the other stuff as well. And why not? If the copyright permits you to do so, which it usually does- not always, but usually. If the copyright permits you to do so and just copy and paste the stuff into your plan and then you know that you've got what you need. Then you can change the wording if you need to. But it will save you a lot of bother if you've got to write a safety management plan. It'll help you to make sure you've got everything you need to and it will save you a lot of effort. So, I recommend that I've done that myself.
Commentary #1
I think I've just got a couple of slides of commentary. It's worth reiterating that Codes of Practice are for all Australian industry. Whether it be a sole trader like myself operating out of our study or their garage or something, or whether it be a small operation- a family-run garage or shop, or whether it be the biggest corporation in Australia, whoever that is- if you're running a major mining operation. So, Codes of Practice provide minimum requirements. These are the things that you must comply with. In high-risk industries, you're probably going to have to do a lot more. And they do have a workplace application. So, they are written for the workplace. They're not really written for the designer, manufacturer, importer, supplier, etc. But nevertheless, it is very, very helpful if you are those people to look at the CoP in order to get an idea of what your customers have got to comply with and therefore what you're going to have to supply.
And as I've already said, CoP will repay careful reading because whilst they are guidance, they are really more than guidance. If you are ignorant of CoP and you don't do what they say you are exposing yourself to prosecution. So, see my introduction to Codes of Practice where I talk about that. There are three reasons why you must be aware of Codes of Practice. And this is one of those two Codes of Practice that everyone must be aware of. The others- if you're working with asbestos or welding or whatever it might be then there are specific Codes of Practice that you must be aware of for those activities. But this is one of those ones that applies to absolutely everybody, potentially. And as I've said before, the Model CoP has more detail than maybe some of the regulator-enforced Codes of Practice, which you will, I think, find helpful for higher risk applications. Whether legally you've got an MHF or not.
Commentary #2
And in fact, that's my point in slide two. So, not everyone is required to have a formal safety management system for managing safety risk in a- while something is in service, while it's being used. So, this CoP does not require us to have a formal safety management system, but it is required for major hazard facilities.
#AustralianWHS #CodesofPractice #Consult #Cooperate #Coordinate #coursesafetyengineering #engineersafety #ineedsafety #knowledgeofsafety #learnsafety #needforsafety #safetyblog #safetydo #safetyengineer #safetyengineerskills #safetyengineertraining #safetyengineeringcourse #safetyprinciples #softwaresafety #theneedforsafety #WHSCodeofPractice
Simon Di Nucci
https://www.safetyartisan.com/2020/11/21/consultation-cooperation-coordination-cop/
Monday, September 23, 2024
Risk Management Code of Practice
In this 40-minute session, we look at the Risk Management Code of Practice (CoP). We cover: who has WHS duties; the four-step process; keeping records, appendices & a summary of detailed requirements; and further commentary. This CoP is one of the two that are generally applicable.
https://youtu.be/9WFZrPVWIEU
The Risk Management Code of Practice (Demo of the full, 40-minute, video).
buy the full-length video here
Risk Management Code of Practice: Topics
Risk Management Code of Practice (CoP):
- Who has WHS duties;
- The four-step process;
- Keeping records, appendices & summary of detailed requirements;
- Further commentary; and
- Where to get more information.
Risk Management Code of Practice: Transcript
Risk Management Code of Practice: Transcript
Hello, everyone, and welcome to the Safety Artisan. I'm Simon, your host, and today we're going to be talking about the Risk Management Code of Practice.
Today we're talking about the Risk Management Code of Practice. It's a code of practice that I've used myself. I've used it to guide my work and to guide other people to help them in their work. I've used it to simplify the whole practice of what we do because once you know what you're supposed to do, you can do that and then you don't have to worry about working out what you need to do. And conversely, it's giving you everything you need to do so you can do more if you want to, but you don't have to. So, it makes life a lot easier and simpler. And then finally, you can use it to justify what you've done. That what you've done is correct, and what you've done is complete and is enough. So, it's very useful and that's why I'm teaching it because it makes life easier.
And I'm going to explain how to use it- you'll still need to go away and read the Code of Practice, as you'll see, to get all the details – but I'm going to go through the leading particulars and explain how to use it. And then finally, at the end of the session, I'm going to show you where you can get more help on this topic and indeed other related topics because this Code of Practice is one of several. And there's one other that you must refer to. This Risk Management Code of Practice is one that you really can't do without. There is one more and then the others are optional, depending on whether you're working in their respective areas. Anyway, let's get on with it.
Code of Practice: Risk Management
So we're talking about the Risk Management Code of Practice, which is under Australian Work Health and Safety Law. Now, if you're not operating in Australia, this is not a requirement for you but nevertheless, it does contain some very useful guidance. And I've seen similar requirements in the US and in the UK, and I suspect all across the English-speaking world.
Topics for this Session
So, what we're going to cover today. First of all, who has WHS duties because it's a wider group of people than you might think it is. There's the four-step process for actually doing risk management. And then I think we've got a slide each on keeping records, the appendices in the Code of Practice, and a summary of the detailed requirements in the Code of Practice. Then I’ve provided some further commentary and, as I’ve said before, where to get more information.
Who has WHS Duties?
So, first of all, who has WHS duties? Well, it's kind of everybody. First of all, if you are a person conducting a business or undertaking or a PCBU for short, then you have duties. And it says business or undertaking, so it includes voluntary groups, non-profit, government, military, you name it. It doesn't have to be a commercial business. Then you have duties if you are a designer, manufacturer, importer, supplier, or if you install test or commission plant substances or structures. So again, a wide range of people.
And it's not just about managing safety in a workplace. There're lots of duties on duty holders with upstream software- sorry not software, upstream safety duties. Like designers and manufacturers. Then finally, officers have additional duties and an officer basically is like a director of a company that sort of level. So, senior management with control over resources and they have to provide due diligence. So, there's a bunch of requirements on them as well. And then, of course, there's the workers and any visitors. They've got to cooperate and take reasonable care of themselves and look out for each other, which is all very important.
And as it says, and this is a quote from the CoP, “A person can have more than one duty at the same time, and more than one person can share the same duty”. So, you can't go playing tag, as it were. A sort of a responsibility tag. ‘It wasn't me. It was him. Governor!’ The court ultimately decides who is responsible.
A Four-Step Process
So, in our four-step process, we have; first of all, we have to identify hazards. We have to assess the risks. So, we need to look at causes and consequences. And the CoP doesn't say this, but exposure comes into it as well. So, a risk might be present, but if nobody is exposed to that risk, then you can't hurt them. So, that's an important point to remember. And controlling exposure is important to one degree or another in almost all areas, but very important in certain industries. Those industries that have got the real estate to be able to separate the risky thing from the human and this is very useful. So step three, we have to control risks. And then step four, we have to review control measures because it's recognized that these control measures will be in place for some time, for the lifetime of whatever it is we're doing or undertaking. So, they need to be periodically reviewed and there's guidance on that.
Now, I keep saying guidance – take a look at the introduction to Codes of Practice and you will see why Codes of Practice are a bit more than guidance. They are guidance that you cannot afford to ignore because if things go wrong, you will get hung out to dry based on what CoP said you should have done. So, if you are ignorant of what CoP said and haven't done it, then you're stuffed basically before you even start. That's point one to note.
And secondly, you'll notice in the diagram on the left, we've got management commitment at the centre and we've got consultation all the way around. And there's another Code of Practice, the Code of Practice on Communication, Cooperation and Coordination . So the C,C&C CoP and that is the other CoP that is essential. So, this one and the C, C and C CoP you must have a look at because they apply to everything in effect. Let's move on.
Step 1, Identify Hazards
So, first of all, we need to identify hazards. Now, CoP is written for any Australian business or undertaking, so it's pretty basic. It's pretty pragmatic, but it's pretty basic and it's got a workplace focus. So, it says inspect the workplace, look around, talk to your workers. Now, I work in a business and day job for a consultancy where we, generally speaking, are not looking at an existing workplace, but we're helping a customer buy or assure a complex product that's going to come into service at some time in the future. So, there are no current workers to discuss, but we always do try and include end-user representatives in our safety workshops. So, you may not be able to consult workers directly, but you should try and include people who have relevant work experience.
Secondly, the CoP tells us to use good work design and safe design. Now that's a whole topic in itself and I've got some guidance on safe design. If you go to that safety artisan.com page on safe design (www.safetyartisan.com/welcome/safe-design), you will see it and I'll take you through the subject and refer you on to the source material itself.
Thirdly, we need to consult supply chains and networks. I think that works two ways. First of all, when you get people to supply you stuff, make sure that they supply the data that you need. The safety data, all the information that you need to take and use the product safely. And that's part of the duty on all of these duty holders, on the designer, the manufacturer, the importer, the supplier. They all have duties to pass on the relevant safety information but make sure you ask for it in your contract. And secondly, suppliers, particularly if you're buying an expensive piece of kit off them, suppliers can be an excellent source of information. If they're the designers, then they know this kit better than anybody else. Make use of their expertise, contract them to do some work for you and take part of the load off you. They are best placed to do some of the work, so get them to do it.
And then fourthly, it says review available information. Now, this is very important. There's historical information or there should be – it’s not always easy to come by sometimes. Do make the effort to get actual historical information for your piece of kit, maybe from the supplier. Or if you can't do that, if it's a new piece of kit, then try and get information on similar equipment, or services, or functionality, or go to a trade organization, or go to the regulator depending on what domain you're in. Do look around for historical information. It is out there. It can be hard to find, but it is worth the effort because, again, the guidance requires it. So, if you don't do it, if you don't bother or you've not made reasonable efforts to do so, you'll get clobbered if things go wrong.
And then it's also advisable to compliment that historical information with diverse approaches. One of them is you can use a hazard checklist approach, and we talk about that in the session on preliminary hazard identification. There are lots of checklists freely available out there on the Internet. Some are general and some are more specific to different pieces of kit or different domains. Try and find the most relevant one for you and use it. And then maybe there are specific safety analyses techniques that you can use as well so have a go at those. And a lot of them are quite simple so don't be put off. You don't have to necessarily have to get an expensive consultant in to do this for you. A lot of these techniques are really quite simple and just require a bit of imagination and a little bit of self-discipline in the way you go about it. And I talk about analysis methods for hazard identification in that same session on Preliminary Hazard Identification (PHI).
So, that's identifying hazards.
Step 2, Assess Risks
Step two, we need to assess the risks. So, if we recall risk is a combination of likelihood and severity. So, how likely is the harm could arise? And how severe is that harm? The way to do that, the CoP says, is to work out how hazards may cause harm. And as always, don't be afraid to ask the dumb questions. That's part of my job as a consultant. You're allowed to turn up and ask dumb questions. Or maybe sensitive questions that nobody in the firm dares to ask because they think they get fired. So, be brave and do try and work out how to ask the questions in a non-threatening way, but do ask the questions.
Work out how severe the harm could be. What is the worst credible consequence? And also, to keep it simple, what's the worst direct consequence? Yes, you can come up with a fanciful chain of events that will lead to ‘it's the end of the world as we know it’, but keep it direct would be my advice. At least to start with. It's better to get a range of stuff than to work one scenario to the nth degree, I would suggest.
Then work out the likelihood of that harm occurring. Very often the most severe harm can only occur when there is a particular combination of circumstances. And if you read any kind of accident report, even in the press, you'll very often say this was happening and it just so happened on this particular day that somebody wasn't available to supervise and then this went wrong and something else went wrong. And then the final result of this chain of consequences was somebody gets hurt. So, do factor in all of those things.
There are probably lots of existing controls already unless you're doing something very novel indeed, which is unusual. So, do look at what's there and record it all. Conversely, do be aware of the ‘it will never happen brigade’ is I've met several people who say, ‘Oh, that will never happen; or was it ‘No British pilot would be stupid enough to do that. Ho, ho, ho.’ I was foolish enough to believe that. Anyway, that's another story. So, don't believe the people who say, ‘It can never happen’. Well, if I say, ‘OK, what's the justification? Why can it never happen? Where's the evidence for that claim?’ So, do dig into those responses.
There's more detail in the Code of Practice. There are some good questions to ask in the workplace. And with a bit of imagination, you can take your imaginary piece of kit and sort of think about it in the workplace and go, ‘Well, let's think up a suitable question.’ So, there's good guidance in there. Historical data can't be beat as a reality check and it shuts up the naysayers as well because if you can pull out information, say, ‘Well this accident has happened and it's happened lots of times to lots of good people who thought they were clever’. So, it shuts up the naysayers do work hard to get the historical data. It's fantastic if you can get it.
And then, as I said before, there are multiple specialist cause and consequence analysis techniques available. I talk about some of them and in other posts that I've already done, and I will talk about more in the future. But you may not need that level of sophistication. It's always better to do some good basic work as early as you can. Then maybe if you come up against something and say, ‘We're not cracking this. We suspect there's a problem, but we can't be sure’ then think about bringing out big guns. But if you've done the basic work first, that will really help you zero in on the areas where you think you need to do more work.
Step 3, Control Risks
The third one, controlling risks. Really, this is what it's all about because you can do all the analysis you like, but you don't do analysis for the sake of it. You do analysis in order to inform your selection of risk controls. And we are required to use a hierarchy of control measures, and that's a legal requirement in Australia. It's also a requirement in other jurisdictions and in other many other standards – safety standards that you'll see it just may not be called this. But it will talk about more and less effective controls.
At the top of the control hierarchy, we've got the most effective control which is to eliminate the risk entirely. And by that, I mean you get rid of it. Let's say you're working in an explosive atmosphere and you've decided you don't want any electrical devices in that explosive atmosphere. So, if you need to have power for machinery, you're going to do it with pneumatics, let's say, or hydraulics. So, you've eliminated the electrical risk. Elimination does not mean massaging the probability figures to get them very low and then you have eliminated the risk you have not. You've just played games with probability figures. So first off, that's what elimination really means.
The second level, you've got three choices. We can substitute something hazardous with a safer alternative. I've mentioned getting rid of electricity entirely. You could say, ‘Well, I've got hydraulics, but they can burst and cause damage so I'll have something else. Or let's say there was a particular lubricant, which is ideal, but actually it's quite dangerous this lubricant, so we'll pick something safer. Maybe it doesn't perform quite as well. Or a refrigerant, let's say, an ideal refrigerant might be a potent greenhouse gas so we go ‘We're going to have something else instead’.
You can isolate the hazard from people – I've spoken about that before. Some industries you've got a lot of real estate to play with. You can keep the hazard away from people. Or you can reduce the risk through engineering controls. And by engineering controls, I mean, you can build a safety feature or an interlock or something physically into the product. You're not relying on a person to avoid the risk. It's been done for them. It's automatic or built-in.
At third level, we can use admin controls. So we can give people procedures and rules and we can say, ‘Do this, don't do that’. And most of the time they'll probably do it and obey the rules, but sometimes they won't. And sometimes for good reason, by the way, because people come up with ridiculous rules that can't be obeyed or that make the task or the job so difficult that people break the rules all the time because that's the only way to get the job done effectively. So, do be aware of putting silly controls onto people because they won't get obeyed. It's your responsibility to consult the workers and come up with something practical.
And then finally, we can use personal protective equipment. Now that doesn't do anything to the probability of the accident, but it reduces the severity. So, for example, if I'm wearing a hard hat, something falls on my head. It reduces the severity of the accident. If I'm wearing protective goggles and there's a spark or a piece of debris flies out of the machine. If I'm wearing the goggles, it just bounces off probably and saves my eyes. So, there's a couple of really good examples of where the PPE will help us. And of course, in this season of COVID, we've all got PPE bonkers. It's become headline news all over the world. So, we all now know what PPE is, which is great. Well, and it's not great. It's terrible, but it's good for knowledge.
So, we have to work through that hierarchy in that order. We have to see whether it's feasible to eliminate the risk to start at the top with the most effective controls and work our way down. We have to do that. And the subject of another chat, another lesson, we have to apply all reasonably practical controls in order to say that we have eliminated or minimized risks SFARP. So far as is reasonably practicable. So, we've got to apply all reasonably practical controls. I'll explain exactly what that means in a separate session.
Aside: Control Effectiveness
A Quick aside: are controls effective? I've sort of hinted at this before about the admin stuff. How do we get effective controls? Well, the CoP says we need people to be accountable for health and safety. We need maintenance of plant and equipment. We need up to date training and competency for our people. We need up to date hazard information – that's a duty in its own right. And we need regular review and consultation. And you'll find out about that in the CC&C CoP in my next lesson.
Now, these things are required everywhere, they can be achieved informally. If you work in a high-risk industry, you'll probably have a thing called a safety management system. And your safety management system will be documented in a safety management plan. And typically, the safety management system is the thing that delivers all of these things, all five of these things and much more. So, that's what you'll probably end up doing.
First thing to say on that, of course, is that this information has got to be generated. You've got to get it from source and it's usually the designer, the manufacturer, and the installer, and the testers who can provide this information. So, do make sure that you are imposing requirements on your suppliers, on your subcontractors to do this stuff and to provide you with the information. It is their duty to do so. It's a legal duty, but you're probably still going to have to pay for it and say when you want it and in what format that's most useful to you and all the other good stuff.
Step 4, Reviewing Controls
Step four, which is maybe not so obvious. We've got some controls, we're up and running, we need to review those controls.
#coursesafetyengineering #engineersafety #ineedsafety #knowledgeofsafety #learnsafety #needforsafety #riskanalysis #riskassessment #riskmanagement #safetyblog #safetydo #safetyengineer #safetyengineerskills #safetyengineertraining #safetyengineeringcourse #safetyprinciples #softwaresafety #theneedforsafety #WHSCodeofPractice
Simon Di Nucci
https://www.safetyartisan.com/2020/10/19/risk-management-code-of-practice/
In this 40-minute session, we look at the Risk Management Code of Practice (CoP). We cover: who has WHS duties; the four-step process; keeping records, appendices & a summary of detailed requirements; and further commentary. This CoP is one of the two that are generally applicable.
https://youtu.be/9WFZrPVWIEU
The Risk Management Code of Practice (Demo of the full, 40-minute, video).
buy the full-length video here
Risk Management Code of Practice: Topics
Risk Management Code of Practice (CoP):
- Who has WHS duties;
- The four-step process;
- Keeping records, appendices & summary of detailed requirements;
- Further commentary; and
- Where to get more information.
Risk Management Code of Practice: Transcript
Risk Management Code of Practice: Transcript
Hello, everyone, and welcome to the Safety Artisan. I'm Simon, your host, and today we're going to be talking about the Risk Management Code of Practice.
Today we're talking about the Risk Management Code of Practice. It's a code of practice that I've used myself. I've used it to guide my work and to guide other people to help them in their work. I've used it to simplify the whole practice of what we do because once you know what you're supposed to do, you can do that and then you don't have to worry about working out what you need to do. And conversely, it's giving you everything you need to do so you can do more if you want to, but you don't have to. So, it makes life a lot easier and simpler. And then finally, you can use it to justify what you've done. That what you've done is correct, and what you've done is complete and is enough. So, it's very useful and that's why I'm teaching it because it makes life easier.
And I'm going to explain how to use it- you'll still need to go away and read the Code of Practice, as you'll see, to get all the details – but I'm going to go through the leading particulars and explain how to use it. And then finally, at the end of the session, I'm going to show you where you can get more help on this topic and indeed other related topics because this Code of Practice is one of several. And there's one other that you must refer to. This Risk Management Code of Practice is one that you really can't do without. There is one more and then the others are optional, depending on whether you're working in their respective areas. Anyway, let's get on with it.
Code of Practice: Risk Management
So we're talking about the Risk Management Code of Practice, which is under Australian Work Health and Safety Law. Now, if you're not operating in Australia, this is not a requirement for you but nevertheless, it does contain some very useful guidance. And I've seen similar requirements in the US and in the UK, and I suspect all across the English-speaking world.
Topics for this Session
So, what we're going to cover today. First of all, who has WHS duties because it's a wider group of people than you might think it is. There's the four-step process for actually doing risk management. And then I think we've got a slide each on keeping records, the appendices in the Code of Practice, and a summary of the detailed requirements in the Code of Practice. Then I’ve provided some further commentary and, as I’ve said before, where to get more information.
Who has WHS Duties?
So, first of all, who has WHS duties? Well, it's kind of everybody. First of all, if you are a person conducting a business or undertaking or a PCBU for short, then you have duties. And it says business or undertaking, so it includes voluntary groups, non-profit, government, military, you name it. It doesn't have to be a commercial business. Then you have duties if you are a designer, manufacturer, importer, supplier, or if you install test or commission plant substances or structures. So again, a wide range of people.
And it's not just about managing safety in a workplace. There're lots of duties on duty holders with upstream software- sorry not software, upstream safety duties. Like designers and manufacturers. Then finally, officers have additional duties and an officer basically is like a director of a company that sort of level. So, senior management with control over resources and they have to provide due diligence. So, there's a bunch of requirements on them as well. And then, of course, there's the workers and any visitors. They've got to cooperate and take reasonable care of themselves and look out for each other, which is all very important.
And as it says, and this is a quote from the CoP, “A person can have more than one duty at the same time, and more than one person can share the same duty”. So, you can't go playing tag, as it were. A sort of a responsibility tag. ‘It wasn't me. It was him. Governor!’ The court ultimately decides who is responsible.
A Four-Step Process
So, in our four-step process, we have; first of all, we have to identify hazards. We have to assess the risks. So, we need to look at causes and consequences. And the CoP doesn't say this, but exposure comes into it as well. So, a risk might be present, but if nobody is exposed to that risk, then you can't hurt them. So, that's an important point to remember. And controlling exposure is important to one degree or another in almost all areas, but very important in certain industries. Those industries that have got the real estate to be able to separate the risky thing from the human and this is very useful. So step three, we have to control risks. And then step four, we have to review control measures because it's recognized that these control measures will be in place for some time, for the lifetime of whatever it is we're doing or undertaking. So, they need to be periodically reviewed and there's guidance on that.
Now, I keep saying guidance – take a look at the introduction to Codes of Practice and you will see why Codes of Practice are a bit more than guidance. They are guidance that you cannot afford to ignore because if things go wrong, you will get hung out to dry based on what CoP said you should have done. So, if you are ignorant of what CoP said and haven't done it, then you're stuffed basically before you even start. That's point one to note.
And secondly, you'll notice in the diagram on the left, we've got management commitment at the centre and we've got consultation all the way around. And there's another Code of Practice, the Code of Practice on Communication, Cooperation and Coordination . So the C,C&C CoP and that is the other CoP that is essential. So, this one and the C, C and C CoP you must have a look at because they apply to everything in effect. Let's move on.
Step 1, Identify Hazards
So, first of all, we need to identify hazards. Now, CoP is written for any Australian business or undertaking, so it's pretty basic. It's pretty pragmatic, but it's pretty basic and it's got a workplace focus. So, it says inspect the workplace, look around, talk to your workers. Now, I work in a business and day job for a consultancy where we, generally speaking, are not looking at an existing workplace, but we're helping a customer buy or assure a complex product that's going to come into service at some time in the future. So, there are no current workers to discuss, but we always do try and include end-user representatives in our safety workshops. So, you may not be able to consult workers directly, but you should try and include people who have relevant work experience.
Secondly, the CoP tells us to use good work design and safe design. Now that's a whole topic in itself and I've got some guidance on safe design. If you go to that safety artisan.com page on safe design (www.safetyartisan.com/welcome/safe-design), you will see it and I'll take you through the subject and refer you on to the source material itself.
Thirdly, we need to consult supply chains and networks. I think that works two ways. First of all, when you get people to supply you stuff, make sure that they supply the data that you need. The safety data, all the information that you need to take and use the product safely. And that's part of the duty on all of these duty holders, on the designer, the manufacturer, the importer, the supplier. They all have duties to pass on the relevant safety information but make sure you ask for it in your contract. And secondly, suppliers, particularly if you're buying an expensive piece of kit off them, suppliers can be an excellent source of information. If they're the designers, then they know this kit better than anybody else. Make use of their expertise, contract them to do some work for you and take part of the load off you. They are best placed to do some of the work, so get them to do it.
And then fourthly, it says review available information. Now, this is very important. There's historical information or there should be – it’s not always easy to come by sometimes. Do make the effort to get actual historical information for your piece of kit, maybe from the supplier. Or if you can't do that, if it's a new piece of kit, then try and get information on similar equipment, or services, or functionality, or go to a trade organization, or go to the regulator depending on what domain you're in. Do look around for historical information. It is out there. It can be hard to find, but it is worth the effort because, again, the guidance requires it. So, if you don't do it, if you don't bother or you've not made reasonable efforts to do so, you'll get clobbered if things go wrong.
And then it's also advisable to compliment that historical information with diverse approaches. One of them is you can use a hazard checklist approach, and we talk about that in the session on preliminary hazard identification. There are lots of checklists freely available out there on the Internet. Some are general and some are more specific to different pieces of kit or different domains. Try and find the most relevant one for you and use it. And then maybe there are specific safety analyses techniques that you can use as well so have a go at those. And a lot of them are quite simple so don't be put off. You don't have to necessarily have to get an expensive consultant in to do this for you. A lot of these techniques are really quite simple and just require a bit of imagination and a little bit of self-discipline in the way you go about it. And I talk about analysis methods for hazard identification in that same session on Preliminary Hazard Identification (PHI).
So, that's identifying hazards.
Step 2, Assess Risks
Step two, we need to assess the risks. So, if we recall risk is a combination of likelihood and severity. So, how likely is the harm could arise? And how severe is that harm? The way to do that, the CoP says, is to work out how hazards may cause harm. And as always, don't be afraid to ask the dumb questions. That's part of my job as a consultant. You're allowed to turn up and ask dumb questions. Or maybe sensitive questions that nobody in the firm dares to ask because they think they get fired. So, be brave and do try and work out how to ask the questions in a non-threatening way, but do ask the questions.
Work out how severe the harm could be. What is the worst credible consequence? And also, to keep it simple, what's the worst direct consequence? Yes, you can come up with a fanciful chain of events that will lead to ‘it's the end of the world as we know it’, but keep it direct would be my advice. At least to start with. It's better to get a range of stuff than to work one scenario to the nth degree, I would suggest.
Then work out the likelihood of that harm occurring. Very often the most severe harm can only occur when there is a particular combination of circumstances. And if you read any kind of accident report, even in the press, you'll very often say this was happening and it just so happened on this particular day that somebody wasn't available to supervise and then this went wrong and something else went wrong. And then the final result of this chain of consequences was somebody gets hurt. So, do factor in all of those things.
There are probably lots of existing controls already unless you're doing something very novel indeed, which is unusual. So, do look at what's there and record it all. Conversely, do be aware of the ‘it will never happen brigade’ is I've met several people who say, ‘Oh, that will never happen; or was it ‘No British pilot would be stupid enough to do that. Ho, ho, ho.’ I was foolish enough to believe that. Anyway, that's another story. So, don't believe the people who say, ‘It can never happen’. Well, if I say, ‘OK, what's the justification? Why can it never happen? Where's the evidence for that claim?’ So, do dig into those responses.
There's more detail in the Code of Practice. There are some good questions to ask in the workplace. And with a bit of imagination, you can take your imaginary piece of kit and sort of think about it in the workplace and go, ‘Well, let's think up a suitable question.’ So, there's good guidance in there. Historical data can't be beat as a reality check and it shuts up the naysayers as well because if you can pull out information, say, ‘Well this accident has happened and it's happened lots of times to lots of good people who thought they were clever’. So, it shuts up the naysayers do work hard to get the historical data. It's fantastic if you can get it.
And then, as I said before, there are multiple specialist cause and consequence analysis techniques available. I talk about some of them and in other posts that I've already done, and I will talk about more in the future. But you may not need that level of sophistication. It's always better to do some good basic work as early as you can. Then maybe if you come up against something and say, ‘We're not cracking this. We suspect there's a problem, but we can't be sure’ then think about bringing out big guns. But if you've done the basic work first, that will really help you zero in on the areas where you think you need to do more work.
Step 3, Control Risks
The third one, controlling risks. Really, this is what it's all about because you can do all the analysis you like, but you don't do analysis for the sake of it. You do analysis in order to inform your selection of risk controls. And we are required to use a hierarchy of control measures, and that's a legal requirement in Australia. It's also a requirement in other jurisdictions and in other many other standards – safety standards that you'll see it just may not be called this. But it will talk about more and less effective controls.
At the top of the control hierarchy, we've got the most effective control which is to eliminate the risk entirely. And by that, I mean you get rid of it. Let's say you're working in an explosive atmosphere and you've decided you don't want any electrical devices in that explosive atmosphere. So, if you need to have power for machinery, you're going to do it with pneumatics, let's say, or hydraulics. So, you've eliminated the electrical risk. Elimination does not mean massaging the probability figures to get them very low and then you have eliminated the risk you have not. You've just played games with probability figures. So first off, that's what elimination really means.
The second level, you've got three choices. We can substitute something hazardous with a safer alternative. I've mentioned getting rid of electricity entirely. You could say, ‘Well, I've got hydraulics, but they can burst and cause damage so I'll have something else. Or let's say there was a particular lubricant, which is ideal, but actually it's quite dangerous this lubricant, so we'll pick something safer. Maybe it doesn't perform quite as well. Or a refrigerant, let's say, an ideal refrigerant might be a potent greenhouse gas so we go ‘We're going to have something else instead’.
You can isolate the hazard from people – I've spoken about that before. Some industries you've got a lot of real estate to play with. You can keep the hazard away from people. Or you can reduce the risk through engineering controls. And by engineering controls, I mean, you can build a safety feature or an interlock or something physically into the product. You're not relying on a person to avoid the risk. It's been done for them. It's automatic or built-in.
At third level, we can use admin controls. So we can give people procedures and rules and we can say, ‘Do this, don't do that’. And most of the time they'll probably do it and obey the rules, but sometimes they won't. And sometimes for good reason, by the way, because people come up with ridiculous rules that can't be obeyed or that make the task or the job so difficult that people break the rules all the time because that's the only way to get the job done effectively. So, do be aware of putting silly controls onto people because they won't get obeyed. It's your responsibility to consult the workers and come up with something practical.
And then finally, we can use personal protective equipment. Now that doesn't do anything to the probability of the accident, but it reduces the severity. So, for example, if I'm wearing a hard hat, something falls on my head. It reduces the severity of the accident. If I'm wearing protective goggles and there's a spark or a piece of debris flies out of the machine. If I'm wearing the goggles, it just bounces off probably and saves my eyes. So, there's a couple of really good examples of where the PPE will help us. And of course, in this season of COVID, we've all got PPE bonkers. It's become headline news all over the world. So, we all now know what PPE is, which is great. Well, and it's not great. It's terrible, but it's good for knowledge.
So, we have to work through that hierarchy in that order. We have to see whether it's feasible to eliminate the risk to start at the top with the most effective controls and work our way down. We have to do that. And the subject of another chat, another lesson, we have to apply all reasonably practical controls in order to say that we have eliminated or minimized risks SFARP. So far as is reasonably practicable. So, we've got to apply all reasonably practical controls. I'll explain exactly what that means in a separate session.
Aside: Control Effectiveness
A Quick aside: are controls effective? I've sort of hinted at this before about the admin stuff. How do we get effective controls? Well, the CoP says we need people to be accountable for health and safety. We need maintenance of plant and equipment. We need up to date training and competency for our people. We need up to date hazard information – that's a duty in its own right. And we need regular review and consultation. And you'll find out about that in the CC&C CoP in my next lesson.
Now, these things are required everywhere, they can be achieved informally. If you work in a high-risk industry, you'll probably have a thing called a safety management system. And your safety management system will be documented in a safety management plan. And typically, the safety management system is the thing that delivers all of these things, all five of these things and much more. So, that's what you'll probably end up doing.
First thing to say on that, of course, is that this information has got to be generated. You've got to get it from source and it's usually the designer, the manufacturer, and the installer, and the testers who can provide this information. So, do make sure that you are imposing requirements on your suppliers, on your subcontractors to do this stuff and to provide you with the information. It is their duty to do so. It's a legal duty, but you're probably still going to have to pay for it and say when you want it and in what format that's most useful to you and all the other good stuff.
Step 4, Reviewing Controls
Step four, which is maybe not so obvious. We've got some controls, we're up and running, we need to review those controls.
#coursesafetyengineering #engineersafety #ineedsafety #knowledgeofsafety #learnsafety #needforsafety #riskanalysis #riskassessment #riskmanagement #safetyblog #safetydo #safetyengineer #safetyengineerskills #safetyengineertraining #safetyengineeringcourse #safetyprinciples #softwaresafety #theneedforsafety #WHSCodeofPractice
Simon Di Nucci
https://www.safetyartisan.com/2020/10/19/risk-management-code-of-practice/
Monday, September 16, 2024
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