Examiners’ Report NEBOSH International Diploma in Occupational Health and Safety (Unit IA)
Examiners’ Report NEBOSH INTERNATIONAL DIPLOMA IN OCCUPATIONAL HEALTH AND SAFETY Unit IA: International management of health and safety JULY 2008
Comments on individual questions
© 2008 NEBOSH, Dominus Way, Meridian Business Park, Leicester LE19 1QW tel: 0116 263 4700
fax: 0116 282 4000
email: [email protected]
The National Examination Board in Occupational Safety and Health is a registered charity, number 1010444 T(s):exrpts/J/J-A0807
NEBOSH (The National Examination Board in Occupational Safety and Health) was formed in 1979 as an independent examining board and awarding body with charitable status. We offer a comprehensive range of globally-recognised, vocationally-related qualifications designed to meet the health, safety, environmental and risk management needs of all places of work in both the private and public sectors. Courses leading to NEBOSH qualifications attract over 25,000 candidates annually and are offered by over 400 course providers in 65 countries around the world. Our qualifications are recognised by the relevant professional membership bodies including the Institution of Occupational Safety and Health (IOSH) and the International Institute of Risk and Safety Management (IIRSM). NEBOSH is an awarding body to be recognised and regulated by the UK regulatory authorities: • • •
The Office of the Qualifications and Examinations Regulator (Ofqual) in England The Department for Children, Education, Lifelong Learning and Skills (DCELLS) in Wales The Council for the Curriculum, Examinations and Assessment (CCEA) in Northern Ireland
NEBOSH follows the “GCSE, GCE, VCE, GNVQ and AEA Code of Practice 2007/8” published by the regulatory authorities in relation to examination setting and marking (available at the Ofqual website www.ofqual.gov.uk). While not obliged to adhere to this code, NEBOSH regards it as best practice to do so. Candidates’ scripts are marked by a team of Examiners appointed by NEBOSH on the basis of their qualifications and experience. The standard of the qualification is determined by NEBOSH, which is overseen by the NEBOSH Council comprising nominees from, amongst others, the Health and Safety Executive (HSE), the Department for Education and Skills (Df ES), the Confederation of British Industry (CBI), the Trades Union Congress (TUC) and the Institution of Occupational Safety and Health (IOSH). Representatives of course providers, from both the public and private sectors, are elected to the NEBOSH Council. This report on the Examination provides information on the performance of candidates which it is hoped will be useful to candidates and tutors in preparation for future examinations. It is intended to be constructive and informative and to promote better understanding of the syllabus content and the application of assessment criteria. © NEBOSH 2008
Any enquiries about this report publication should be addressed to: NEBOSH Dominus Way Meridian Business Park Leicester LE10 1QW Tel: 0116 263 4700 Fax: 0116 282 4000 Email: [email protected]
Many candidates are well prepared for this unit assessment and provide comprehensive and relevant answers in response to the demands of the question paper. This includes the ability to demonstrate understanding of knowledge by applying it to workplace situations. There are always some candidates, however, who appear to be unprepared for the unit assessment and who show both a lack of knowledge of the syllabus content and a lack of understanding of how key concepts should be applied to workplace situations. In order to meet the pass standard for this assessment, acquisition of knowledge and understanding across the syllabus are prerequisites. However, candidates need to demonstrate their knowledge and understanding in answering the questions set. Referral of candidates in this unit is invariably because they are unable to write a full, well-informed answer to the question asked. Some candidates find it difficult to relate their learning to the questions and as a result offer responses reliant on recalled knowledge and conjecture and fail to demonstrate any degree of understanding. Candidates should prepare themselves for this vocational examination by ensuring their understanding, not rote-learning pre-prepared answers. Recurrent Problems It is recognised that many candidates are well prepared for their assessments. However, recurrent issues, as outlined below, continue to prevent some candidates reaching their full potential in the assessment. −
Many candidates fail to apply the basic principles of examination technique and for some candidates this means the difference between a pass and a referral.
In some instances, candidates are failing because they do not attempt all the required questions or are failing to provide complete answers. Candidates are advised to always attempt an answer to a compulsory question, even when the mind goes blank. Applying basic health and safety management principles can generate credit worthy points.
Some candidates fail to answer the question set and instead provide information that may be relevant to the topic but is irrelevant to the question and cannot therefore be awarded marks.
Many candidates fail to apply the command words (also known as action verbs, eg describe, outline, etc). Command words are the instructions that guide the candidate on the depth of answer required. If, for instance, a question asks the candidate to ‘describe’ something, then few marks will be awarded to an answer that is an outline.
Some candidates fail to separate their answers into the different sub-sections of the questions. These candidates could gain marks for the different sections if they clearly indicated which part of the question they were answering (by using the numbering from the question in their answer, for example). Structuring their answers to address the different parts of the question can also help in logically drawing out the points to be made in response.
Candidates need to plan their time effectively. Some candidates fail to make good use of their time and give excessive detail in some answers leaving insufficient time to address all of the questions.
Candidates should also be aware that Examiners cannot award marks if handwriting is illegible.
UNIT IA – International management of health and safety
Section A – all questions compulsory
Outline, with examples, the benefits and limitations of: (a)
The wording of the question provided a clear guide on how best to structure the answer and candidates were expected to provide answers dealing with the benefits and limitations of each type of legislation in turn. The benefits of prescriptive legislation are that its requirements are clear and easy to apply, it provides the same standard for all, it is not difficult to enforce and does not require a high level of expertise. Its limitations are that it is inflexible, may be inappropriate in some circumstances by requiring too high or too low a standard, it does not take account of local risks and may need frequent revision to keep up with changes in technology and knowledge. The benefits of goal-setting legislation are that it has more flexibility in the way compliance may be achieved, it is related to actual risk and can apply to a wide variety of workplaces and it is less likely to become out of date. These are countered by the fact that it may be open to wide interpretation and the duties it lays and the standards it requires may be unclear until tested in courts of law. As a result it may be more difficult to enforce and may require a higher level of expertise to achieve compliance.
Explain the difference between accident incidence rate and accident frequency rate.
A site is divided into a small number of large departments and the number of workers in each department is variable. You have been asked to collate details of first-aid treatment cases for the site and to present on a monthly basis, data in graphical and / or numerical format, in a way that would be helpful to site and departmental management. Describe how you could present this data indicating clearly the types of graphical presentation you would use AND in EACH case the data it would contain.
In answering part (a) of the of the question, candidates should have explained that an accident incidence rate is calculated by dividing the number of accidents occurring over a period of time by the average number of persons employed during the period with the result being multiplied by 10,000. An accident frequency rate is calculated by dividing the number of accidents occurring during a period by the total hours worked during the period and multiplying the result by 1,000,000.
For part (b), candidates were asked to describe how they would collate and present details of first aid treatment for a site comprising a number of departments. Since the intention was to present information in a way that would be helpful both to site and departmental management, it would be necessary to collate details firstly for the site as a whole and then for each separate department. The first option would be to produce a line graph to show the total number of treatment cases each month and then indicate the trend by the use of a trend line or moving average. Using a frequency or incidence rate would enable changes in employee numbers to be taken into account. A line graph could also be used to show any trend in specific causes or types of injury whilst a chart or histogram could highlight the number by site or department. Another option would be to use pie charts, bar charts or histograms to present information both for the whole site and individual departments on the cause of the injuries requiring treatment and for the site of the injuries by body part.
Describe the possible strengths and weaknesses of the role of the employee representative in improving workplace health and safety standards and culture for the groups of employees that they represent.
The possible strengths of the role of the employee representative in improving the standards of health and safety at the workplace would include ensuring that employee concerns which might otherwise remain unknown, are brought to the attention of management (and if necessary to an inspector from the enforcing authority), and applying pressure to ensure that the action promised to improve working conditions was taken; ensuring employee involvement in and commitment to good health and safety practices; encouraging and supporting active monitoring by exercising the entitlement to carry out inspections of the workplace and ensuring employee input during the investigation of accidents and incidents; and acting as a champion for health and safety and so promoting awareness and interest and encouraging employee input on proposals affecting health and safety. The appointment of a safety representative could have its weaknesses in that it could result in less direct engagement and consultation by management with the workforce on health and safety issues. The investigative role could lead to a focusing on compensation claims rather than on the introduction of control measures to prevent a recurrence and there is a danger that health and safety issues might be mixed up and confused with other employment relations issues. A representative who has not received appropriate training may fail to establish correct priorities and cause resources to be wasted while one who is ineffective or unmotivated may undermine the existing safety culture of the organisation by failing to represent the views and opinions of employees.
A poor organisational safety culture is said to lead to higher levels of violation by employees. (a)
Explain the meaning of the term ‘violation’ and the classification of violation as ‘routine’, ‘situational’ or ‘exceptional’.
Outline the reasons why a poor safety culture might lead to higher levels of violation by employees.
For part (a) of this question candidates were expected to explain that a “violation” is a deliberate deviation from a rule, procedure, instruction or regulation. A routine violation involves continually breaking a rule or procedure to the extent that it becomes the normal way of working. This can be due to the belief that the rule no longer applies or because there is a desire to cut corners to save time. In the case of a situational violation, rules are broken due to pressures from the job such as insufficient staff for the workload, time pressures, adverse conditions or because the right equipment for the job is not available. Exceptional violations are rare and only happen when things have gone wrong and a risk is taken to solve an urgent problem. A good answer to part (b) would have outlined that a good or poor safety culture in an organisation is based on the common beliefs and perceptions of the staff and then outlined that a lack of a shared perception about the importance of safety could lead to individual employees violating a rule or procedure because they are driven by their own perception of what is really important or they may be influenced by peer pressure. A negative perception that rules are not important and that production is more important – both prime factors of a poor safety culture – could lead to higher levels of violation.
Outline what is meant by punitive damages in relation to a compensation award, clearly stating their purpose and to whom the damages are paid.
In relation to claims for compensation outline the meaning of the terms: (i)
no fault liability;
breach of duty of care.
For part (a) of the question, in outlining the meaning of “punitive damages”, candidates should have explained that they are a financial or monetary award which, whilst paid to a claimant, are not awarded to compensate, but in order to reform or deter the defendant and similar persons from pursuing a course of action such as that which damaged the claimant. As such they are both a punishment and a deterrent. The amount of the award is determined by a court and is not linked to the losses suffered by the claimant. “No fault liability” is a liability which is independent of any wrongful intent or negligence. As such, an injury alone is sufficient to confer liability with compensation being paid either by an insurance company or from a government fund. There are three standard conditions that must be satisfied in order to establish a breach of duty of care. These are that a duty of care was owed by an employer to his employee; that the employer acted in breach of that duty by not doing everything that was reasonable to prevent foreseeable harm and lastly that the breach led directly to the loss damage or injury.
In relation to a binding contractual agreement state the meaning of: (i)
express terms, and
In relation to a new grounds maintenance contract, give examples of the information which should be stated in the contract terms, in order for the work to be undertaken safely.
Express terms are those specifically mentioned and agreed by all parties at the time the contract is made. They may take account of unusual circumstances but should not include unfair terms. Implied terms are neither written in the contract nor specifically agreed. They include terms such as matters of fact, matters of law and matters of custom and practice. In cases of dispute they may ultimately have to be determined by a court of law. Part (b) required candidates to give examples of information which should be included in a grounds maintenance contract to ensure the work was carried out in a safe manner. Examples could have included the responsibility of the contractor to provide a safe working environment including safe means of access and egress to the site; to provide safe plant and equipment tested and examined in accordance with any legal requirements; to provide adequate welfare facilities for the workforce and to ensure they were given relevant information, instruction and training and were properly supervised and to put in place procedures for dealing with any emergency that might occur.
Section B – three from five questions to be attempted
A chemical reaction vessel is partially filled with a mixture of highly flammable liquids. It is possible that the vessel headspace may contain a concentration of vapour which, in the presence of sufficient oxygen, is capable of being ignited. A powder is then automatically fed into this vessel. Adding the powder may sometimes cause an electrostatic spark to occur with enough energy to ignite any flammable vapour. There is concern that there may be an ignition during addition of the powder. To reduce the risk of ignition, an inert gas blanket system is used within the vessel headspace designed to keep oxygen below levels required to support combustion. In addition, a sensor system is used to monitor vessel oxygen levels. Either system may fail. If the inert gas blanketing system and the oxygen sensor fail simultaneously, oxygen levels can be high enough to support combustion. Probability and frequency data for this system are given below. Failure type/event Vessel headspace contains concentration of vapour capable of being ignited Addition of powder produces spark with enough energy to ignite vapour Inert gas blanketing system fails Oxygen system sensor fails
Probability 0.5 0.8 0.2 per year 0.1
Draw a simple fault tree AND using the above data calculate the frequency of an ignition.
Describe, with justification, TWO plant OR process modifications that you would recommend to reduce the risk of an ignition in the vessel headspace.
In answering part (a) of the question, Examiners were expecting candidates to supply a simple fault tree similar to that shown below and to calculate that the frequency of ignition would be 0.008/yr or once in every 125 years. Those candidates who had a good understanding of the construction of a fault tree did well.
Ignition 0.008/yr (once every 125 years)
Oxygen > limit 0.02
Flammable vapours 0.5
Blanketing system fail 0.2/yr
O2 sensor system fail 0.1
In answering part (b), candidates could have included a description of any relevant modifications but were expected to select those which would make a greater contribution to reducing the overall risk. These could have included replacing the powder feed with a slurry in a conducting liquid; selecting and using materials with higher flashpoints to minimise the probability of a flammable atmosphere; and redesigning the nitrogen blanketing system to improve reliability.
A production process has a safety critical control system that depends on a single component to remain effective. Outline ways of reducing the likelihood of failure of this component AND describe additional ways to increase the reliability of the system.
Describe the meaning of ‘common mode failure’ AND outline equipment design features which could help to minimise the probability of such failures.
Good answers to part (a) of this question would have dealt separately with component and system reliability in the circumstances described. This type of answer would have included such issues as burning in the component before placing it correctly in the system; planned replacement of the component before wear out; increasing its useful life by a planned programme of maintenance; and the initial design of and material specification for the component together with the use of quality assurance. The reliability of the system might be increased by the use of parallel components and standby systems and parallel redundancy; operational and detection protective systems to maintain the system within its design specification; the use of hazard analysis techniques to predict failure routes; the use of more reliable components to minimise failures to danger and the monitoring, collection and use of failure data.
For part (b), a common mode failure might be described as a type or cause of failure that could affect more than one component at a time, even when the components are supposed to be arranged to operate independently of each other. It is particularly relevant for components in parallel designed to improve reliability of a system by redundancy. Measures that could be taken to help minimise the probability of this type of failure include functional diversity where reliance is placed on safety components designed to act by different mechanisms, for example one detector for pressure and another for temperature, and one hydraulic interlock and one electrical interlock; equipment diversity where components are sourced from different manufacturers or from different manufacturing processes to avoid common manufacturing defects and vulnerabilities; isolating components from each other and from the environment so that they do not fail from common causes such as high temperature or vibration; routing cables by multiple routes so that local physical damage does not affect all components and using well known and established equipment designs where most of the failure modes will have been understood.
Below is an extract from an incident investigation report form. XYZ Ltd. INCIDENT INVESTIGATION Details of Incident Date June 2007
Ref No 2007/01
Description of how incident occurred Whilst accessing a filing cabinet within the general office area a paper hole punch fell, from a box located on top of the cabinet, striking Lynne on the head. Lynne visited the hospital emergency department some hours after the incident after advice from her line manager.
Details of any injury or property damage Surname Jones
First Name Lyn
Extent of injury/property damage Bruising and nausea.
Witness name and contact No L Jones IT Manager XYZ Ltd. Returned to Work: YES Referred to Hospital: YES (not immediately) Referred to Company Doctor: NO Causes of the Incident Paper hole punch fell and landed on head
Details of Investigation and Actions to prevent recurrence Actions taken as a result of the incident Accident recorded. All storage areas checked. Workplace inspection carried out to identify other hazards. Materials unnecessarily stored at high level removed to lower locations and filing cabinets.
By whom and by when.
1. Formal 3 monthly workplace inspection regime to be implemented.
Safety Manager. Ongoing – Time to be planned into work schedule to carry out inspections.
Investigated by: Name: D. Briefing
Actions complete: Date ………………
Evaluate the report in terms of its suitability to provide adequate information for record keeping purposes and for subsequent statistical analysis.
With reference to a suitable model (eg HSG 245, Investigating Accidents and Incidents) outline the key stages in health and safety incident investigations.
In evaluating the suitability of the report, it was expected that candidates would recognise its deficiencies in that it was incomplete, at times vague and other times inconsistent. It was incomplete in that it provided no information on the time of the accident, the type of first aid that was given or the precise action taken to prevent a recurrence. It was vague in its description of the injury actually received, of the treatment given at the hospital, of the actual circumstances which caused the punch to fall and thus of the immediate and underlying causes of the accident. Its inconsistencies lay in a failure to provide information on the details and findings of the investigation, in the inappropriate nature of the solutions given the likely cause of the accident and in the identification of the injured person with different names being used. Additionally, it was perhaps unnecessary to name the injured person as a witness of the accident in the absence of any other witnesses. For part (b), candidates were expected to outline the key stages involved in the investigation of health and safety incidents. The first stage would involve gathering all relevant information to establish exactly what had happened including the location and time of the incident and the persons who might have been affected. This would involve a visual inspection of the location, interviewing witnesses and reviewing relevant documentation. Once all the information had been gathered, it would be necessary to analyse it, perhaps making use of FTA or a similar tool, to establish the immediate and underlying causes of the incident. This would then enable the investigators to identify the appropriate risk control measures to prevent a recurrence of a similar incident. The final stage would be to produce an action plan, setting out objectives to be achieved, clearly identifying responsibilities for their completion and maintaining a record of the progress being made.
A financial review within your organisation has resulted in a proposal to the Board of Directors to cut its health and safety budget and to cancel a project that was designed to lead to significant improvements in the working environment. Write a report to the Board giving reasons why the proposal should be rejected.
This question required a balanced review of the issues surrounding the resourcing of health and safety which recognised the overlapping nature of the legal, moral and economic benefits of maintaining good standards. The benefits of investing in health and safety would result in compliance with legal requirements and the avoidance of legal action particularly in view of the possible liability of directors and /or managers. The investment in improving the working environment would also indicate the organisation’s commitment to health and safety and would have a beneficial effect on the morale of the workforce which could lead to an improvement in productivity, efficiency, quality and employment relations. On the other hand, the potential costs to the organisation of a decision to reduce the health and safety budget would include those normally associated with an accident involving injury and/or plant failure or fire such as the interruption to normal production and product damage; the cost of replacement labour and equipment; the costs associated with a criminal prosecution and those following civil litigation including uninsured costs and a likely increase in insurance premiums; and the damage that such events might cause to the organisation’s image and to public confidence which in turn could affect the demand for its products. The question required the answer to be given in the form of a report to the Board and marks were accordingly available for the format, structure and language used in answers.
Outline the desirable design features of controls AND displays on a control panel for a complex industrial process aimed at reducing the likelihood of human error.
This question addressed a specific aspect of ergonomics – namely the design features of controls and displays that would influence the rate of human error. The more successful candidates made a clear distinction in their answers between controls and displays. Desirable design features of controls include keeping their number to a minimum whilst ensuring a sufficient number to control the state of operation. A change of system state should only occur after operating a control and should require a positive action of the control with immediate feedback to the user. A system restart should again only occur after operating a control after a deliberate or non-intentional stop. A stop function should be easy to activate and override start and adjust controls. All controls should be visible, positioned and ordered logically so as to follow the process and be within easy reach of the operator while labelling, shape or colour can be put to effective use to ensure controls are easily identified. The type of control should be appropriate to the degree of control required, for example a lever may be more appropriate than a knob. Recognised conventions should be followed such as up for off, green for on and clockwise to increase. Controls positioned next to their respective displays are also desirable. Displays should be clearly visible and labelled and show steady state. They should also clearly indicate change, match expectations and attract the appropriate sense such as flashing to draw visual attention. It is important to use the appropriate type of display for the reading, ie analogue or digital, and ensure that all dials are in a similar position for “normal” operation. Markings on dials and the application of different colours can be used to indicate abnormal situations. Additional design features include shielding bulbs from strong ambient light; shielding glass dials from glare and placing displays against a panel of neutral colour. Displays should be kept to a minimum and safety critical displays should be separated from other displays.
The National Examination Board in Occupational Safety and Health Dominus Way Meridian Business Park Leicester LE19 1QW telephone +44 (0)116 2634700 fax +44 (0)116 2824000 email [email protected]