July 2009
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 2009
CONTENTS
Introduction
2
General comments
3
Comments on individual questions
4
© 2009 NEBOSH, Dominus Way, Meridian Business Park, Leicester LE19 1QW tel: 0116 263 4700
fax: 0116 282 4000
email:
[email protected]
website: www.nebosh.org.uk
The National Examination Board in Occupational Safety and Health is a registered charity, number 1010444 T(s):exrpts/J/J-A0907
EXTERNAL
DW/DA/SJ/REW
Introduction
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 2009
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]
2
EXTERNAL
General comments
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. Common pitfalls 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.
3
EXTERNAL
UNIT IA – International management of health and safety
Section A – all questions compulsory Question 1
An organisation is proposing to move from a health and safety management system based on the International Labour Organisation ILO OSH 2001 model to one that aligns itself with BS OHSAS 18001. Outline the possible advantages AND disadvantages of such a change.
(10)
Candidates were expected to apply their knowledge of the management models ILO OSH 2001 and BS OHSAS 18001 to the scenario given. Those candidates who structured their answers in two parts, advantages and disadvantages, did best. As advantages, they realised that a move to OHSAS 18001 would facilitate easier integration with BS EN ISO 14001 and ISO 9001:2000 to produce an integrated management system and outlined further advantages such as publicity value; improved customer perception; international recognition; a clearer standard for benchmarking and commitment to continual improvement. Marks were also available for recognising that external registration and independent external assessment would be available and that a more prescriptive system is easier to assess. Examples of possible disadvantages could have included the fact that models like ILO OSH 2001 is the system recognised and used by the regulator and they are likely to audit an organisation against this standard, as much of the published guidance is often directly linked to the model. Other marks were available for referring to the direct on-costs of changing a system; how time consuming the model can be; the cost of external registration; the likelihood of increased paper work to satisfy assessors and the fact that the model may be too sophisticated for small to medium sized enterprises. Additionally, since the 18001 system is often used alongside the other ISO standards of 9001 and 14001, there is a possibility that those auditing it may not be health and safety specialists. Answers to this question varied in quality with a number lacking in structure and depth.
Question 2
For a range of internal and external information sources outline how each source contributes to hazard identification or risk assessment.
(10)
In answering this question ,candidates could have referred to internal sources such as investigation reports on accidents and near miss incidents and ill-health data all of which help to identify workplace hazards and contribute to the understanding and estimation of the degree of risk involved; proactive monitoring data such as those arising from inspections and audits which involve observation of the workplace and working practices, can provide information on worker knowledge of working practices and hazards, and on the use and reliability of existing risk control measures, as can maintenance and inspection records of plant, equipment or personal protective equipment.
4
EXTERNAL
As for external sources, candidates could have referred to guidance from the regulator which identifies hazards and sets risk control standards to meet legal and good practice requirements; regulator accident and ill-health data which again assist with the identification of hazards and the probability of their associated risk; statistics and guidance from other authoritative sources such as professional bodies, trade associations and insurers; guidance from international bodies such as WHO, ILO and the European Agency for Safety and Health (EU OSHA) on specific hazards and risk control standards; and manufacturers’ information and safety data sheets which again provide useful hazard information. This question was poorly answered with many candidates failing to outline how their chosen sources of information could contribute to hazard identification and risk assessment, which was required in order to earn marks.
Question 3
(a)
(b)
Outline the site operator requirements for emergency planning and procedures within the International Labour Organisation Convention C174 ‘Prevention of Major Industrial Accidents’ 1993.
(6)
As part of the on-site emergency planning process a large manufacturing site intends to provide information to the external emergency services. Outline the types of information that the site should consider providing to the ambulance service.
(4)
Under the ILO’s convention C174 on the subject of the Prevention of Major Industrial Accidents, the site operator is required to: identify major hazards and assess their potential outcomes; prepare written site emergency plans and procedures; draw up emergency medical procedures; carry out periodic testing and evaluation of the effectiveness of the emergency plans and introduce any revisions to the plans shown by the evaluation to be necessary; include reference in the plan to the protection of the public and the environment outside the site following consultation with the authorities and communities concerned and submit the emergency plans to the responsible authorities. In answering part (b), candidates were expected to outline types of information such as the location of the site and its various access points; details of the main hazards on site such as fire, explosion or toxic release; details of any hazardous chemicals used and stored; the number of personnel on site both in daytime and at night; plans showing the layout of the site; the location of any emergency control centre; the identity and contact details of key personnel; details of the establishment’s medical personnel and facilities; details of any specific medical conditions of workers and particularly information relating to those known to be vulnerable; and any other information necessary to enable the ambulance service to carry out a risk assessment for its own personnel. There were some reasonable answers produced for this question though some candidates included in their answers for part (a) information more relevant to part (b) and were thus at a loss when they came to answer the second part.
5
EXTERNAL
Question 4
(a)
(b)
Outline the benefits of establishing effective consultation arrangements with workers concerning health and safety matters in the workplace.
(6)
Outline the range of formal and informal arrangements that may contribute to effective consultation on health and safety matters in the workplace.
(4)
This question was designed to test candidates’ knowledge of the reasons for and the arrangements that might be made for ensuring effective consultation in the workplace on health and safety matters and was generally well answered. In answer to part (a) candidates were initially expected to outline the requirement for consultation in accordance with the principles laid down in Article 20 of the ILO convention, C155 and then to expand on this to include the development of ownership of safety measures amongst workers and promoting their commitment and motivation; improving their perception of the value and importance of health and safety so that they might play an active part in developing the culture of the organisation; gaining the input of worker knowledge to ensure more workable improvements and solutions; and encouraging the submission of improvement ideas by workers. Part (b) required candidates to outline arrangements that might contribute to effective consultation. Marks were available for referring to arrangements such as: the establishment of safety committees; consultation with safety representatives; planned direct consultation at departmental meetings, team briefings or similar; consultation as part of accident/incident investigation or as part of the completion of risk assessments; day to day informal consultation by supervisors with workers at the workplace; tool box talks; the use of departmental/team meetings for ad-hoc consultation on safety issues; discussion as part of safety circles or improvement groups; raising the subject of health and safety at staff appraisals, and the use of questionnaires and suggestion schemes.
Question 5
Outline the issues that should be considered when planning a health and safety inspection programme.
(10)
Information on the specific workplace conditions or behaviours that might be covered in an inspection is not required. The focus of this question was the planning of a health and safety inspection programme and not the specific workplace conditions that should be covered in an inspection. Candidates could have had structured their responses around the four key words of who, what, where and when. This should have led them to outline factors such as the composition and competence of the inspection team; the specific areas of the workplace to be inspected; the frequency and timings of the inspections which may have to be more frequent in higher risk areas with a decision being made as to whether the inspections would take place at peak working times or during slow periods; the method of carrying out the inspections and whether check lists should be prepared and if so by whom; the possible need to provide personal protective equipment for the inspection team; the involvement of the workforce in consultation on the proposed programme; the need to obtain senior management support and commitment for the inspection programme; consulting previous inspection reports and researching applicable legislation and standards; and deciding on procedures to be followed after the inspection to ensure appropriate remedial action is taken.
6
EXTERNAL
There were some candidates that gained a few marks by adopting a broad approach to the answer rather than using a logical structure to their answer, whilst others lost marks by producing lists rather than the additional detail required for an for an answer to an “outline” question.
Question 6
(a)
(b)
Outline what is meant by punitive damages in relation to a compensation award clearly stating their purpose AND to whom the damages are paid.
(5)
In relation to a claim for compensation outline the meaning of the terms: (i)
no fault liability;
(2)
(ii)
breach of duty of care.
(3)
For part (a) of the question, in outlining the meaning of “punitive damages”, candidates should have included 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 or other compensation awarded. A good outline of the meaning of “no fault liability” would have been that it 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 from a central or 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 the worker; 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. There were a number of weak answers to this question especially for part (a) and there were some candidates who decided not to attempt it. In contrast there were also good answers to this question that were awarded high marks.
7
EXTERNAL
Section B – three from five questions to be attempted Question 7
(a)
An organisation has decided to introduce a permit-to-work system for maintenance and engineering work at a manufacturing plant which operates continuously over three shifts. Outline the issues that will need to be addressed in introducing and maintaining an effective permit-to-work system in these circumstances.
(b)
(10)
A year after the introduction of the permit-to-work system an audit shows that many permits-to-work have not been completed correctly or have not been signed back. Outline possible reasons why the system is not being properly adhered to.
(10)
In answering part (a) of the question, key issues that could have been outlined include: arriving at a clear definition of the jobs and areas for which permits will be required; consideration of the operation of the system where contractors are involved; developing a permit to work procedure that defines how the system will operate; developing the permit format and multi-copy documentation system to encompass issues such as job description, hazard identification, specification of risk control measures, time limits and authorising, and receiving and cancellation signatures and the allocation of a unique reference number; arrangements for the return of permits and record keeping; arrangements for the display of multiple live permits; arrangements for communication between shifts; identification of the training needs for, and the delivery of training to, persons authorising or receiving permits and those working in areas where permits may be required; provision of supporting arrangements and equipment for safe working such as lock-off, isolation or gas testing facilities; and arrangements for routine monitoring and auditing the effectiveness of the system. For part (b), possible reasons for the fact that there is not strict adherence to the permit to work system include: permit issuers and receivers are not competent and have not been adequately trained; there is no routine monitoring or auditing of the system and the level of supervision is poor; there is a lack of perceived importance of the system with production seen as having the greater importance and violations have become routine; the permit system is seen as too complex and cumbersome and difficult to understand; the potential hazards of maintenance and engineering work are not fully identified or understood and the required controls are not fully understood by the permit issuer; the difficulties that arise in organising controls before the start of the work to be carried out; a lack of effective communication between shifts and the person responsible for issuing permits is not always available. This was a popular question and most answers produced were to a reasonable standard though others lacked context in relation to the points made leaving examiners unable to award all the marks available.
8
EXTERNAL
Question 8
Below is an extract from a record of an accident and investigation report. XYZ Ltd. INCIDENT INVESTIGATION Details of Incident Date June 2008
Ref No 2008/01
Time
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. She said it hurt a lot but didn’t cry, much.
Details of any injury or property damage Surname Jones
First Name Lyn
Age N/A
Extent of injury/property damage Bruising and nausea.
Witness name and contact number L Jones IT Manager XYZ Ltd. Returned to Work: YES Referred to Hospital: YES (not immediately) Referred to Medical Practitioner: 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.
Actions required.
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
Signature ……………………….
Actions complete: Date ………………
(a)
(b)
Name …………………………
Signature …………………….
Evaluate the record in terms of its suitability to provide adequate information for record keeping purposes and for subsequent statistical analysis.
(10)
With reference to a suitable model (eg HSG 245, Investigating Accidents and Incidents) outline the key stages in health and safety incident investigations.
(10)
9
EXTERNAL
In evaluating the suitability of the record, 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 first 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. Answers to part (b) were not to the same standard as those for the first part of the question and were often lacking in both context and detail. Some candidates provided a list rather than an outline of 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.
Question 9
A large warehousing and distribution facility uses contractors for many of its maintenance activities. Contractors make up approximately 5% of the total workforce but an analysis of the accident statistics for the previous two years has shown that accidents to contractor personnel, or arising from work undertaken by contractors, account for 20% of the lost-time accidents on site. (a)
(b)
Assuming that the accident statistics are correctly recorded, outline possible reasons for the disproportionate number of accidents involving contract work.
(6)
Describe the organisational and procedural measures that should be in place to provide effective control of the risks from contract work.
(14)
The first part of the question sought some possible reasons why there might be a disproportionate number of accidents associated with work by contractors. Issues that could have been covered include those related to the nature of the work – for instance, maintenance work might be more complex, higher risk, harder to control satisfactorily and with fewer well-established work methods than other warehousing and distribution activities; a lack of established procedures and training for the management of third parties including inadequate contractor selection and the provision of information from the client to contract workers; poor planning and risk assessment and poor communication and coordination between the parties affected by the contract work; inadequate supervision of contractor workers either by the client or by the contractor; staff turnover and a lack of contract worker competence and the effect of contractual or financial pressures on the contractor.
10
EXTERNAL
The second part of the question required a description of the key organisational and procedural measures required to minimise the risks associated with contract work. Measures that could have been described include: the selection of a competent contractor by obtaining evidence of past performance, safety management arrangements, the adequacy of resources and risk control proposals; the provision of adequate information to the contractor prior to the work starting, on the nature of the work to be carried out and the known hazards and site safety rules with an induction briefing to be given to all contract personnel before admittance to site; the preparation of job specific risk assessments and method statements; the appointment of a client representative with contractor management responsibility including communication arrangements; and the introduction of arrangements for coordinating and reviewing risk assessments and method statements, for active and reactive monitoring of performance and for job completion and hand over including a safety performance review. Candidates who chose to answer this question were able to demonstrate a reasonable understanding of the issues of contract work although there were a few omissions including reference to the procedural measure in relation to handover and the completion of a safety performance review.
Question 10
A train driver has passed a stop signal resulting in a collision with another train. Investigation of the incident concluded that the driver had seen the overhead signal but had not perceived the overhead signal correctly. There had been a number of previous similar incidents at the signal, although the driver was not aware of this. The driver concerned was inexperienced and had not received information and training associated with that route. The signal was hard to see being partly obscured by a bridge and affected by strong sunlight. In addition, the arrangement of the lights on the signal was a non-typical formation. The driver had approached the signal with no expectation from previous signals that it would be on ‘stop’. (a)
(b)
Give practical reasons why the driver may not have perceived the signal correctly.
(7)
Outline the steps that could be taken to reduce the likelihood of a recurrence of this incident.
(13)
In giving reasons why the driver may not have perceived the signal correctly, candidates were expected to identify that perception may be affected by sensory input and expectation. This should have led them to give practical reasons for the error such as the colour of the signal being mistaken either because it was affected by strong sunlight or the driver’s colour vision was defective; the signal itself could have been defective; the driver may have read the wrong signal because of its unusual formation; the signal was visible for a short time only and its perception would have needed the full attention of the driver; the driver’s expectation from previous signal positions may have influenced his perception; and finally his perception may have been dulled by the effects of alcohol, drugs or fatigue.
11
EXTERNAL
For part (b), the initial steps that could be taken to reduce the likelihood of a recurrence of this incident would be to re-design and re-locate the signal and replacing unusual signal formations, consulting with drivers during this process. Long term actions would centre on driver recruitment and selection processes involving preemployment screening for example for vision and physical capability and the provision of training to include local route information, unusual signal formations, information on signals which have been passed on danger on previous occasions with a final assessment being made of the driver’s competence before he is allowed to become operational. Other measures would include ongoing supervision and competence assessment together with a programme of health surveillance; the avoidance of driver fatigue by the provision of breaks and the organisation of shift work; the introduction of an alcohol and substance policy; modifying the design of cab glazing to minimise the effect of glare or reflections; the use of automatic train protection or warning systems and the introduction of procedures to encourage the reporting of similar incidents and to ensure prompt action is taken by management following the receipt of such a report. Many candidates did well in answering both parts of this question. Many of those who did not do well did not recognise that part (a) was concerned with perception and made no reference to this in their answers.
Question 11
Companies are subjected to many influences in health and safety. (a)
In contract law state what is meant by express terms.
(2)
(b)
Outline how influential parties can affect health and safety performance in a company.
(8)
(c)
Outline how non-conformity to an accredited health and safety standard such as BS OHSAS 18001 can be used as a form of enforcement in a self-regulatory model.
(10)
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. For part (b), there are a number of parties who can affect health and safety performance in a company such as employer bodies who may set professional and performance standards for member organisations; trade associations who set performance standards for members and can require self regulation and compliance with accredited management systems; trade unions whose representatives check workplace conditions and provide advice and guidance; professional groups such as IOSH who set professional standards of performance and provide advice and guidance; pressure groups who can organise campaigns to obtain bad publicity for non-performing organisations; the public who as customers can influence the success of an organisation by boycotting goods and services; the ILO who publish advice and guidance and enforce standards in conventions and recommendations; insurance companies who can require specific performance standards for insurance cover and may remove statutory cover for non-compliance and the media who are always willing to provide publicity and coverage of incidents affecting the health and safety of workers and others.
12
EXTERNAL
In outlining how non-conformity with an accredited health and safety standard may be used as a form of enforcement in a self-regulatory model candidates were expected to outline examples such as: stakeholders who require conformity with an accredited health and safety standard and may seek retribution against the management team for failing to maintain the standard while clients and business partners will not engage with the organisation unless the accreditation is maintained; insurance companies may require a demonstration of a standard of performance in line with the requirements of the standard and withdraw cover of statutory insurance if there is noncompliance; third party audits will identify failing compliance and require solutions to be put in place to maintain accreditation; the threat of removal of accreditation and that of loss of business may help to improve standards; the loss of reputation as a result of non-compliance may damage the image of the organisation; the possibility of expulsion from associations or trade bodies as a result of the loss of accreditation will motivate compliance; the lack of credibility in not complying with a recognised system may motivate compliance as business is affected; and the various levels of action open to the accrediting body such as informal notification of failures, formal notification of non-conformance and finally the withdrawal of accreditation can provide a strong inducement to comply with the standard. This was the least popular of the questions in the second half of the paper with some candidates possibly deciding to avoid it because of the reference to enforcement, and it was not well answered by those who attempted it with many seeming not to understand what a self regulatory model is in the context of health and safety management.
13
EXTERNAL
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
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