Developing Effective Health and Safety Procedures  -a Practical Guidance

1. What is the procedure and why is good procedure design important?

Procedures, in relation to health and safety, including the safe system of work, work instructions, permits to work, etc., are agreed safe ways of doing things. They usually consist of step-by-step instructions and related information needed to help carry out tasks safely. They may include checklists, decision aids, diagrams, flow-charts and other types of job aids.

Well-designed procedures are vital in standardising working practice, reducing risks, reducing human error and improving compliance.

During site health and safety inspections, audits and through reviewing incident investigation reports, we are often informed that procedures are not followed. The consequences of not following procedures or inadequate procedures can be disastrous.

2.  Benefits of well-designed procedures 

There are many benefits of well-designed procedures, these include:

  • To minimise errors/mistakes and failures;
  • To ensure critical health and safety steps are carried out;
  • To provide a basis for training and employee induction;
  • To standardise working practice;
  • To protect against loss of operating knowledge (e.g. when experienced employees leave);
  • Act as a basis for auditing and continuous improvement;
  • Identify and promote best practices;
  • To meet statutory requirements.

We often hear people complaining that their procedures are just paperwork. Procedures are not about creating huge amount of paperwork, rather about identifying sensible measures to control the risks in your workplace. Have you achieved any of the above benefits from your procedures? You might complain that experienced employees left which have a big impact of your operation. If you have involved your employees in document the key knowledge and best practices from employee’s experience, the impact of the organisational change can be minimised.

3. Why do people not follow procedures?

Common reasons employees not following procedures are:

  • Procedures do not reflect how tasks are performed;
  • Procedures are not correct or out-of-date;
  • Procedures are difficult to use or follow;
  • Procedures are not readily available;
  • A failure to understand the risks;
  • Compliance to procedures is not monitored enforced;
  • Perceived pressure from management to ‘get the job done’;
  • Pressure from peers;
  • Poor health and safety culture.

By understanding why people not following procedures, we can address one of the root causes by improving the effectiveness of procedures.

4. How to write effective procedures and improve existing procedures?

4.1 Determine the tasks that need written procedures

  • Training needs analysis;
  • Carry out an activity analysis;
  • Visit the workplace and walk-through or talk-through these tasks with employees;
  • Job Safety Analyses – identify safety critical job or tasks, associated health and safety hazards and the control measures;
  • Review the results from risk assessment;
  • Review the results from incidents, accidents investigation, inspections and audits;
  • The industrial best practices;
  • ISO management systems – requirements for documented information;

4.2 Consider factors when deciding on the needs and the level of details needed in the procedure:

  • The risks of the tasks;
  • The consequence of possible human error;
  • The complexity of the task;
  • The difficulty of the task;
  • How often the task is performed (e.g. routine and non-routine/rare);
  • The user of the procedure;
  • The experience and skill level of users;
  • The competence of users;
  • Particular needs of the users.

4.3 Identify safety-critical tasks to control the risks:

  • Commissioning;
  • Plant start-up and shutdown;
  • Abnormal plant operation;
  • Safety critical operations;
  • Non-company personnel, e.g. contractor activities;
  • Emergency operation;
  • Maintenance operations;
  • Maintenance of safety critical systems;
  • Emergency response / spill control;
  • Plant/process change;

4.4 Determine the need for improving the existing procedures

You can follow the above process to review the needs for improving your existing procedures and identify the weaknesses, additional ways include:

  • Talk to employees who use or are involved in supervising/monitoring, auditing and overseeing the procedures;
  • Identify informal procedures and other job aids e.g. the personal ‘black books’ of key information often carried by staff, this is an indicator that the work procedure is not used or not fit-for-purpose;
  • Review an existing procedure with the user/supervisor at the place of work, ask the employee to explain how to do a task
  • Carry out an employee perception survey to collect feedback

4.5 Consult the uses -Questions to ask procedure users

  • Do they always use the procedures? – Why not?
  • Are procedures up-to-date?
  • Were they involved in developing them?
  • Do they reflect how tasks are actually carried out?
  • Are they of the right level of detail?
  • Do they include safety critical tasks?
  • Are they easy to use?
  • Compare and benchmark good practices in similar industry/process
  • Optimise the use of international standards to improve the effectiveness of your procedures e.g. ISO 45001 and Energy Institutes’ High-Level Framework for process safety management

5. Good practices in procedure design and improvement

  • Design in safety and design-out risks and violations through designing the process, environment, equipment and task, e.g. ergonomic design, programmable logic controllers and the error detection.
  • Risk assessment should establish if procedures are an appropriate control measure.

According to the Hierarchy of controls, the control methods at the top of graphic e.g. Elimination and substitution are more effective than those lower down. Procedures are used to control the residual risks if good design and engineering controls are applied.

Working safely during the with the hierarchy of controls

  • Risk assessment should identify possible human failure and consequences in safety-critical tasks, and implement the control measures necessary to prevent it.
  • Involving the workforce in developing procedures to increase their ownership and compliance with procedures. Encourage users in reviewing existing procedures to identify issues and suggest improvements. This also ensures that procedures are relevant and practical.
  • Make it simple and concise, easy to follow and beneficial for the user.
  • Use a format, style and level of detail appropriate to the user, task and risk. For example, use the visual management and What a Good Job Looks Like (WAGJLL)
  • Using job aids to support the successful performance of a task, for example, checklists may be used for hazardous energy isolation. Flow charts reduce the amount of decision-making and decrease the need to memorise key points, e.g. in emergencies.
  • Explaining the risks and consequences of failure to follow procedures/rules and the rationale behind them.
  • Establish a document management process to keep procedures relevant and up-to-date.
  • Training and communication – a formal process in place to ensure that staff are trained in new/updated procedures; An effective two-way communication process in place to receive feedback from employees
  • Monitoring to ensure employees’ compliance with procedures. Effective supervision and the Behaviour Based Safety Observation Programme can be used to improve compliance with procedures and provide feedback to employees.
  • Explore the root cause of violations to procedures and address them
  • Ensure that relevant procedural controls are reviewed and updated as needed following an incident, Near Miss, inspections and audit.
  • Foster a positive health and safety culture so that health and safety procedure is followed and is part of getting the job done

As procedures depend upon employees following them ultimately, the user-centred approach in developing procedures, including involving the workforce in designing and reviewing procedures, providing needed support, supervision and monitoring, and creating a positive culture to support and promote compliance to procedures are all important. Hope this step by step guide can be of any help to you.

Reference:

https://www.hse.gov.uk/pUbns/priced/hsg48.pdf

Writing procedures Guidelines for writing effective operating and maintenance procedures American Institute of Chemical Engineers 1996 ISBN 0 8169 0658 0

https://www.cdc.gov/niosh/topics/hierarchy/default.html

 

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