Principles of control
6.5 Safe systems of work
6.5.1 What is a safe system of work?
A safe system of work has been defi ned as:
The integration of personnel, articles and sub- stances in a laid out and considered method of working which takes proper account of the risks to employees and others who may be affected, such as visitors and contractors, and provides a formal framework to ensure that all of the steps necessary for safe work- ing have been anticipated and implemented.
In simple terms, a safe system of work is a defi ned method for doing a job in a safe way. It takes account of all foreseeable hazards to health and safety and seeks to eliminate or minimize these. Safe systems of work are normally formal and documented, for example, in written operating procedures but, in some cases, they may be verbal.
The particular importance of safe systems of work stems from the recognition that most accidents are caused by a combination of factors (plant, substances, lack of training, supervision, etc.). Hence preven- tion must be based on an integral approach and not one which only deals with each factor in isolation. The adoption of a safe system of work provides this integral approach because an effective safe system:
➤ is based on looking at the job as a whole
➤ starts from an analysis of all foreseeable hazards, e.g. physical, chemical, health;
➤ brings together all the necessary precautions, includ- ing design, physical precautions, training, monitor- ing, procedures and personal protective equipment.
It follows from this that the use of safe systems of work is in no way a replacement for other precautions, such as good equipment design, safe construction and the use of physical safeguards. However, there are many situations where these will not give adequate protection in them- selves, and then a carefully thought-out and properly implemented safe system of work is especially important.
The best example is maintenance and repair work, which will often involve as a fi rst stage dismantling the guard or breaking through the containment, which exists for the protection of the ordinary process operator. In some of these operations, a permit to work procedure will be the most appropriate type of safe system of work.
Figure 6.7 Multi-padlocked hasp for locking off an isola- tion valve.
Multi-padlockable hasp for locking off isolating valve
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Principles of control
87 The operations covered may be simple or complex,
routine or unusual.
Whether the system is verbal or written, and whether the operation it covers is simple or complex, routine or unusual, the essential features are forethought and planning – to ensure that all foreseeable hazards are iidentifi ed and controlled. In particular, this will involve scrutiny of:
➤ the sequence of operations to be carried out
➤ the equipment, plant, machinery and tools involved
➤ chemicals and other substances to which people might be exposed in the course of the work
➤ the people doing the work – their skill and experience
➤ foreseeable hazards (health, safety, environment), whether to the people doing the work or to others who might be affected by it
➤ practical precautions which, when adopted, will eliminate or minimize these hazards
➤ the training needs of those who will manage and operate under the procedure
➤ monitoring systems to ensure that the defi ned pre- cautions are implemented effectively.
6.5.2 Legal requirements
The HSW Act Section 2 requires employers to provide safe plant and systems of work. In addition, many regu- lations made under the Act, such as the Provision and Use of Equipment Regulations 1998, require information and instruction to be provided to employees and others.
In effect, this is also a more specifi c requirement to pro- vide safe systems of work. Many of these safe systems, information and instructions will need to be in writing.
6.5.3 Assessment of what safe systems of work are required
Requirement
It is the responsibility of the management in each organ- ization to ensure that its operations are assessed to deter- mine where safe systems of work need to be developed.
This assessment must, at the same time, decide the most appropriate form for the safe system, that is:
➤ is a written procedure required?
➤ should the operation only be carried out under per- mit to work?
➤ is an informal system suffi cient?
Factors to be considered
It is recognized that each organization must have the freedom to devise systems that match the risk potential
of their operations and which are practicable in their situ- ation. However, they should take account of the follow- ing factors in making their decision:
➤ types of risk involved in the operation
➤ magnitude of the risk, including consideration of the worst foreseeable loss
➤ complexity of the operation
➤ past accident and loss experience
➤ requirements and recommendations of the relevant health and safety authorities
➤ the type of documentation needed
➤ resources required to implement the safe system of work (including training and monitoring).
6.5.4 Development of safe systems
Role of competent person
Primarily management is responsible to provide safe systems of work. Managers and employees know the detailed way in which the task should be carried out.
The competent person appointed under the MHSW Regulations should assist managers to draw up guide- lines for safe systems of work with suitable forms and should advise management on the adequacy of the safe systems produced.
Analysis
The safe system of work should be based on a thorough analysis of the job or operation to be covered by the system. The way this analysis is done will depend on the nature of the job/operation.
If the operation being considered is a new one involving high loss potential, the use of formal hazard analysis techniques such as HAZOP (Hazard and Operability study), FTA (Fault Tree Analysis) or Failure Modes and Effects Analysis should be considered.
However, where the potential for loss is lower, a more simple approach, such as JSA (Job Safety Analysis), will be suffi cient. This will involve three key stages:
➤ identifi cation of the key steps in the job/operation – what activities will the work involve?
➤ analysis and assessment of the risks associated with each stage – what could go wrong?
➤ defi nition of the precautions or controls to be taken – what steps need to be taken to ensure the operation proceeds without danger, either to the people doing the work, or to anyone else?
The results of this analysis are then used to draw up the safe operating procedure. (See Appendix 6.2 for a suit- able form.)
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88 Consultation
Many people operating a piece of equipment or process are in the best position to help with the preparation of safe systems of work. Consultation with those employees who will be exposed to the risks, either directly or through their representatives, is also a legal requirement. The importance of discussing the proposed system with those who will have to work under it, and those who will have to supervise its operation, cannot be emphasized enough.
6.5.5 Preparation of safe systems
A checklist for use in the preparation of safe systems of work is set out as follows:
➤ what is the work to be done?
➤ what are the potential hazards?
➤ is the work covered by any existing instructions or procedures? If so, to what extent (if any) do these need to be modifi ed?
➤ who is to do the work?
➤ what are their skills and abilities – is any special training needed?
➤ under whose control and supervision will the work be done?
➤ will any special tools, protective clothing or equip- ment (e.g. breathing apparatus) be needed? Are they ready and available for use?
➤ are the people who are to do the work adequately trained to use the above?
➤ what isolations and locking-off will be needed for the work to be done safely?
➤ is a permit to work required for any aspect of the work?
➤ will the work interfere with other activities? Will other activities create a hazard to the people doing the work?
➤ have other departments been informed about the work to be done, where appropriate?
➤ how will the people doing the work communicate with each other?
➤ have possible emergencies and the action to be taken been considered?
➤ should the emergency services be notifi ed?
➤ what are the arrangements for handover of the plant/
equipment at the end of the work? (For maintenance/
project work etc.)
➤ do the planned precautions take account of all fore- seeable hazards?
➤ who needs to be informed about or receive copies of the safe system of work?
➤ what arrangements will there be to see that the agreed system is followed and that it works in practice?
➤ what mechanism is there to ensure that the safe system of work stays relevant and up-to-date?
6.5.6 Documentation
Safe systems of work should be properly documented.
Wherever possible, they should be incorporated into normal process operating procedures. This is so that:
➤ health and safety are seen as an integral part of, and not add-on to, normal production procedures
➤ the need for operators and supervisors to refer to separate manuals is minimized.
Whatever method is used, all written systems of work should be signed by the relevant managers to indicate approval or authorization. Version numbers should be included so that it can quickly be verifi ed that the most up-to-date version is in use. Records should be kept of copies of the documentation, so that all sets are amended when updates and other revisions are issued.
As far as possible, systems should be written in a non-technical style and should specifi cally be designed to be as intelligible and user-friendly as possible. It may be necessary to produce simple summary sheets, which contain all the key points in an easy-to-read format.
6.5.7 Communication and training
People doing work or supervising work must be made fully aware of the laid-down safe systems that apply. The preparation of safe systems will often identify a training need that must be met before the system can be imple- mented effectively.
In addition, people should receive training in how the system is to operate. This applies not only to those directly involved in doing the work but also to supervi- sors/managers who are to oversee it.
In particular, the training might include:
➤ why a safe system is needed
➤ what is involved in the work
➤ the hazards which have been identifi ed
➤ the precautions which have been decided and, in particular
➤ the isolations and locking-off required, and how this is to be done
➤ details of the permit to work system, if applicable
➤ any monitoring (e.g. air testing) which is to be done during the work, or before it starts
➤ how to use any necessary personal protective equipment
➤ emergency procedures.
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Principles of control
89 6.5.8 Monitoring safe systems
Safe systems of work should be monitored to ensure that they are effective in practice. This will involve:
➤ reviewing and revising the systems themselves, to ensure they stay up-to-date
➤ inspection to identify how fully they are being implemented.
In practice, these two things go together, since it is likely that a system that is out of date will not be fully imple- mented by the people who are intended to operate it.
All organizations are responsible for ensuring that their safe systems of work are reviewed and revised as appropriate. Monitoring of implementation is part of all line managers’ normal operating responsibilities, and should also take place during health and safety audits.