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Task 1: Actions of a labour inspector 1. It is common for the labour inspectorate to ask labour inspectors to visit a workplace following notification of a workplace injury. (a) What are the functions of labour inspection?
(5)
Answer: Functions of labour inspection as per ILO - C081 - Labour Inspection Convention, 1947 are:
to secure the enforcement of the legal provisions relating to conditions of work.
the protection of workers while engaged in their work, such as provisions relating to hours, wages, safety, health and welfare.
Investigating complaints about non-compliant employers.
to supply technical information and advice to employers and workers concerning the most effective means of complying with the legal provisions
Issuing compliance orders in any acceptable forms.
to bring to the notice of the competent authority defects or abuses not specifically covered by existing legal provisions.
(b) What are the actions the labour inspector could take following a visit?
(5)
Answer: The actions that can be taken by the labour inspector following the visit are:
To give warnings and advices to the workers and employer of the organization.
To submit inspection reports to enforcement authorities.
To give alteration orders to make modification to the workplace.
To make immediate executor orders in case of imminent danger at site.
To take legal proceedings and actions in case of violation of local or national laws.
--------------------------------------------------------------------------------------------------------------------------------------------------------Task 2: Indicators of health and safety culture What are the positive indicators of health and safety culture in the organisation?
(15)
Note: You should support your answer, where applicable, using relevant information from the scenario. Answer: Most of the positive indicators of the health and safety culture in the cheese manufacturing company are intangible, while some are directly noticeable. Both are mentioned below:
The organisation operates two-shifts: 05.00 – 13.00, and 13.00 – 21.00. (approx 8 hrs) - Proper set-up of working hours demonstrate they care for the welfare of their employees and enable a work-life balance.
There is great reliance on the knowledge held by many long-serving workers, all of whom are highly proficient in their roles. – Trained and skilled workers are competent workers who are aware of the safe and unsafe conditions and are an asset to the organization.
In the production and storage areas, experienced workers are paired up with temporary workers in a ‘buddy system’. This enables them to learn correct working methods ‘on the job’ and be able to ask any questions. enables job satisfaction and easy learning of the work methods.
There is great reliance on the knowledge held by many long-serving workers, all of whom are highly proficient in their roles. – Low staff turnover rates and skilled workers are always positive indicators of safety culture.
The site’s manager regularly walks around the factories and is very approachable and often talks to workers and listens to their concerns. – Visible leadership through tours, visits, employee engagement conversations help to monitor the adherence to established safe methods of work (SOPs) and employee behaviour in the workplace.
Risk assessments are completed by management with input from workers. – Worker consultation is taken into account and their feedbacks are processed as inputs in risk assessments.
Risk assessments documents are reviewed regularly and are stored in the office. – Lesson learning through the past incidents helps in continual improvement and strengthens the safety culture.
Accident and incident rates are low – indicates that the organization adheres to safety standards go above and beyond legal compliance.
Incidents like accidents or near misses have been recorded and are documented. – helps in lesson learning from the past events and empowers the continual improvement.
During their induction, temporary workers are given a tour of the site and are provided with written information on emergency procedures, first-aid arrangements and a copy of the health and safety policy (signed by the manager). Effective communication, even to new & temporary workers is a very good indicator of a positive safety culture.
Temporary workers are given basic practical training on the correct use of mobile platform steps that are used in both the production and storage areas. – Appropriate practical training of the risk-related activities (working at height), enables the temporary workers to be aware of the associated potential hazards during work.
Management recognises the importance of manual handling training for permanent workers. – Since storage of cheese on wooden shelves involves lot of use of the human body to lift, lower, carry or transfer loads, appropriate training is a must. (Cheese handling is fragile)
The shift supervisor immediately reported the manager about the incident. - One of the strongest indicators of an effective safety culture indicates that employees believe in the safety system in place and trusts that the management will take appropriate corrective actions.
At the time of significant loss of the stock, the manager boosts the workers across both shifts a bonus payment if the production target is reached along with the clean-up of the collapsed shelves. -
By working together as a team, everyone (including the manager) clears up the mess in the storage room quickly and efficiently. –Teamwork worked as a game-changer to get back to normal production at the earliest. Co-worker support is a good indicator of safety culture.
The manager thanks everyone for all their (workers’) hard work. – Apart from financial rewards, verbal praises and gratitude helps in maintaining the employee morale, even at the critical and stressful situations.
The workers are proud of what they have achieved and are keen to get production going again.- Employee motivation and productivity are always directly proportional, and a best indicator of safety culture.
When a young worker had suffered a workplace accident and was off work due to hand injury. The organization contacted the worker to ask about the welfare and show support. – Employee concern boosts the morality through care and moral support (irrespective of the mistake) and thus ensured fair worker environment by avoiding blame culture.
The organisation carried out an investigation immediately after the accident, and the corrective actions were considered for immediate action. – Demonstrates a consistent approach to investigating incidents with a hunger for continual improvement.
--------------------------------------------------------------------------------------------------------------------------------------------------------Task 3: Actions following the collapse of the storage racking (a) Why is it important to secure the scene of this near miss?
(6)
Note: You should support your answer, where applicable, using relevant information from the scenario. Answer: It is very important to secure this near miss scene.
Since the storage racking has collapsed, there might be potential harm if workers enter the scene. Thus securing the area can prevent unnecessary harm to the workers.
As this near miss incident is up for investigation, the evidences, debris or anything related to the scene must not be tampered to carry out a thorough investigation to find the root cause of the accident. So the scene must be secured from being altered.
The incident investigation is a vigilant activity carried out by competent person to find the immediate and underlying causes; unauthorized access to the to-be-investigated incident scene must be prevented.
Securing the scene makes sure that it is safe for the investigators to carry out the investigation. Thus, enabling the investigation to start and safely proceed in the accident scene.
Securing the scene will help in preventing the removal of critical evidences that helps in an intense and clearsighted investigation.
Even though there is no injury or harm, this near miss should be inspected to find the causes of the accident and also prevent similar incidents in the future. Securing the scene enables accurate inspection.
--------------------------------------------------------------------------------------------------------------------------------------------------------(b) Why should this near miss have been investigated?
(15)
Note: You should support your answer, where applicable, using relevant information from the scenario. Answer: Instead of just cleaning up the mess caused due to the collapse of the storage racking, the site Manager should have initiated an investigation for the following reasons:
Near miss investigation is a part of active monitoring, i.e. the outcome of this investigation could have helped in identifying the exact root cause for the collapse.
Near-miss investigation is a pro-active approach of safety monitoring, i.e. even before the potential hazard could cause any harm, injury or further damage, it could be kept under check with proper corrective actions.
The near-miss investigation must have been initiated to show that organization cares about the workers’ safety than just for legal compliances.
With near-miss investigation, the weakness in the organization’s health and safety management system could have been identified.
Also the near-miss investigation could have helped in identifying the weakness in the current control measures in the storage area.
Near-miss investigation could have helped in identifying the unsafe conditions and unsafe acts in the storage area.
With the near-miss investigation, the root cause for the collapse of the storage racking could be found and this finding could have helped to prevent the re-occurrences in future.
With near-miss investigation, the necessary improvements and appropriate changes could be implemented in the refurbishment work of the storage racks.
Even though the storage racks were regularly inspected, it collapsed. With near-miss investigation, the weaknesses or loopholes of the inspection process and reports could be identified.
Near-miss investigation could also help in analysing the young workers’ storage rack handling pattern and over storage trends in the storage area.
Investigating the collapse of wooden rack could have boosted the safety awareness amongst the long-serving workers as well as the temporary workers.
The investigation would have further helped in encouraging the hazards reporting, no matter how big or small they seem.
Thus, near-miss investigation would have helped in polishing the workers’ safety responsibility towards their safety and organization’s safety too.
Near-miss investigation could help to avoid future liability claims.
Near-miss investigation could help in providing information about the accidents and incidents for insurance companies.
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Task 4: Human factors contributing to the accident with the milling machine 4. What individual human factors could have influenced the behaviour of the young worker injured while cleaning the electric milling machine? (15) Note: You should support your answer, where applicable, using relevant information from the scenario. Answer: The individual human factors that could have negatively influenced the behaviour of the young worker are listed below:
The new temporary worker is 17 years old, apparently a young worker with not much maturity (teenager).
Since this is their first full-time job, has no experience, nor competent enough.
The young worker has been with the organisation for just over a week. – Normally would be very keen to work and impressive.
The worker is keen to get the job done – shows over enthusiasm.
The young worker decided to dismantle and clean one of the electric milling machines without the assistance of their ‘buddy’- low hazard awareness.
The young worker knew that cleaning the equipment is something they are not supposed to do – due to lack of knowledge about the safety, risk perception is also low.
Not considered the importance of Supervision and started to clean the milling machine alone.
The new worker had never done this task before – lack of hands-on experience on different tasks at the workplace.
The young worker never had the chance to watch anyone else do it either. – Lack of observational work experience as the worker was new to the workplace.
The young thought that cleaning the milling machine is an easy task. – shows poor hazard analysis.
The young worker believed that showing initiative would be impressive and took up the cleaning task.
The temporary young worker thought to help the fellow workers to get home quicker by independently working on the machine.
The worker stood on a chair to gain access, and leaned over the side of the large funnel structure – this shows lack of awareness on safe working procedures.
Without isolating the power, the young worker started the task of cleaning. – proves that the worker is unaware of different types of hazards in the workplace that can harm him and others in the vicinity.
The worker reached inside the machinery with both hands to remove the spiked drum. – highlights the poor knowledge about the usage of safety equipments (PPE).
The younger accidently press the ‘on’ button with their knee when trying to regain the balance while standing on a chair – poor knowledge about the importance of safe acts (behaviour) at the workplace.
--------------------------------------------------------------------------------------------------------------------------------------------------------Task 5: Knowledge of emergency procedures 5. What are the possible reasons for a general lack of knowledge about emergency procedures across the organisation? (10) Note: You should support your answer, where applicable, using relevant information from the scenario. Answer: Following are the reasons for emergency procedure unawareness:
No efficient process for implementing lessons learned – The accident and incident rates are low; records of these events are just kept at the office.
Many of the workers are highly skilled and long-served staff, thus basic emergency response training and firstaid training must have been provided.
Temporary workers were provided with written information on emergency procedures and first-aid arrangements. - Procedures are communicated but no Emergency response training to any staff.
The several workers rush across to help the young worker who had impaled his right hand while cleaning the milling machine and they had no idea about what to do. Lack of detailed response procedures to potential emergency scenarios. No nominated incident controller for better emergency responses. Workers weren’t trained on individual roles and responsibilities before an incident occurs. No emergency plan or procedures to handle casualties.
Luckily, one of the workers managed to press the ‘emergency stop’ to stop further movement of the milling machine. – No display of ‘Emergency stop’ Signages. No plan of procedures and essential actions during an emergency shutdown.
Workers ran to the office to call help from the management. – No onsite emergency response system to notify the organization management.
One of the office workers immediately calls for an ambulance. – No accurate contact information of the external emergency resources through signage.
No first-aid and medical assistance were provided as a part of emergency procedure.
No specific procedures to provide additional assistance to vulnerable people like young workers during emergencies. --------------------------------------------------------------------------------------------------------------------------------------------------------Task 6: Workers’ responsibilities in the workplace 6. The injured worker may have contravened some of their responsibilities as a worker within International Labour Organisation Convention C155 – Occupational Safety and Health Convention, 1981 (No.155) Article 19 and associated Recommendation R164 – Occupational Safety and Health Recommendation, 1981 (No.164) recommendation 16.
Comment on the extent to which Article 19 of C155 and recommendation 16 of R164 may have been contravened. Note: You should support your answer, where applicable, using relevant information from the scenario.
(9)
Answer:
The young worker decided to dismantle and started cleaning one of the electric milling machines without the assistance of their ‘buddy’. ► Violation of Article 19(a) Of C155 – Occupational Safety and Health Convention, 1981 as the young worker did not co-operate in the fulfilment of the employer obligations (violated the buddy system).
The young worker knew that they were not supposed to do the cleaning task as all equipment cleaning tasks should be supervised. ► Violation of Article 19(b) Of C155 – Occupational Safety and Health Convention, 1981 as the young worker did not co-operate with the employer in the field of occupational safety and health.
►
Violation of Recommendation 16(a) Of R164 – OSH convention as the young worker was found not taking reasonable care for their own safety at work.
►
Violation of Recommendation 16(b) Of R164 – OSH convention as the young worker did not comply with instructions given for their own safety and health.
The young worker thought the cleaning task to be easy and believed that it would show initiative and would help them all to get home quicker. ► Violation of Article 19(b) Of C155 – Occupational Safety and Health Convention, 1981 as the young worker did not co-operate with the employer in the field of occupational safety and health. ►
Without isolating the power, and standing on a chair to gain access, they lean over the side of the large funnel structure and reach inside with both hands to remove the spiked drum. ► Violation of Recommendation 16(a) Of R164 – OSH convention as the young worker was found not taking reasonable care for their own safety and other fellow workers at work. ►
Violation of Recommendation 16(b) Of R164 – OSH convention as the young worker did not comply with instructions given for their own safety and health.
Violation of Recommendation 16(b) Of R164 – OSH convention as the young worker was found not using any safety devices and protective equipment.
The chair moves under their weight of the young worker and while trying to balance, the ‘on’ button was pressed accidently with their knee. ► Violation of Recommendation 16(a) Of R164 – OSH convention as the young worker was found not taking reasonable care for their own safety and other fellow workers at work. (Unsafe act).
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Task 7: How a permit-to-work system works in practice 7. Some of the essential features that need to be in place, for a permit-to-work system to work in practice, were agreed at the emergency meeting. Suggest TEN additional essential features.
(10)
Answer: The other essential features that are necessary for permit-to-work systems are:
PTWs’ must issued by an assigned authorized person only and must be received by a competent person who would carry out that task at the site.
Before issuing the PTW’s, they must be duly signed by the authorizing person and the receiving person.
The scope of work and associated risks must be clearly detailed on the PTW.
The PTW must have the date and time of the work commencement and completion must be clearly mentioned.
Issued PTWs’ must have validity (time period) for the work to be done at the site, and provisions of extensions must be made with permission of the authorized person.
Formal procedures of PTW handover and PTW cancellation must be followed. i.e., the authorizing person must physically inspect the site before PTW handover and cancellation.
There must be trained and competent workers in the team for the PTW described task.
Monitoring and supervision of all the tasks described in the PTW should be carried out by appropriate people at the site.
Since PTW system is for high-risk activities, emergency and first-aid facilities must be made available.
Auditing and risk assessments must be carried out for the permitted tasks.
PTW system must clearly establish a protocol for Simultaneous Operations, i.e. SOP for multiple independent operations that are carried out on the same location at the same time (on milling machine and storage) that may impact the safety of personnel or equipment of another operation.
--------------------------------------------------------------------------------------------------------------------------------------------------------Task 8: Review of the health and safety management system 8. Why does this organisation need to urgently review its health and safety management system?
(10)
Note: You should support your answer, where applicable, using relevant information from the scenario. Answer: Need for reviewing HSMS at cheese manufacturing company with operations involving production, storing, packaging and on-site selling are listed: 1. Production rate is being increased to ensure fulfilment of all orders. With varying business strategies, new risks and hazards will follow, thus review of the overall HSMS becomes essential for balancing productivity and safety concerns. 2. Since there are plans to refurbish the worker rest facilities due to increase in workforce, reviewing the current utility management and identifying necessary improvements helps in betterment of safety performance.
3. As the organization plans to update the storage areas and to build an extension to the production building to increase storage capacity, reviewing the storage facility area and its risk assessments will help in better upgradation and comply with safety standards. 4. Risk assessments are completed by management with input from workers. Even though these documents are reviewed periodically, with additional workforce and business expansion (demands) these assessments must be updated and then reviewed. 5. Even though accident and incident rates are low, periodic reviewing these rates will help in monitoring the effectiveness of the existing safety measures and identify the loopholes (if any). 6. When the young worker impaled their palm with spiked drum, the fellow workers had no idea of emergency procedures, but fortunately one worker does manage to press the emergency stop. This brings in a strong urge to review the emergency response procedures and training. 7. With the milling machine accident, reviewing of the first-aid arrangements and training is necessary for a better HSMS. 8. Following the accident on storage area, reviewing the organization’s health and safety policy is mandatory to redefine the safety objectives and standards. 9. Renewing the parking utility management will help in identifying the possible corrective actions necessary for the betterment poor car parking and poor signs or road markings to help customers and the milk van delivery drivers. 10. With the collapse wooden shelving rack, damaging over 170 cheeses resulting on property and product damage. Thus reviewing of the storage management is a must to examine risk assessment and risk control processes in the storage. 11. The new temporary worker knew that they weren’t supposed to take up equipment cleaning task individually as supervision is necessary. So their training and disciplinary procedures must be reviewed for the effective safety behaviour and review of supervision procedures is needed. 12. Review of the HSMS will assure the workers that organization’s concern for their safety and boosts worker morality post accident. 13. Reviewing the HSMS will probe in for organization’s safety objectives, legal standards and compliances. --------------------------------------------------------------------------------------------------------------------------------------------------------
Funnel shaped milling machine
Spiked rotating drum
Mobile platform used at production and storage areas.
https://youtu.be/vSRA9rI4TW0
May 2022 Feedback 1a- Refer C-081 convention. Valid points are to protect workers, to advise and guide workers, for checking effective compliance with HS laws, to enforce HS law, to check and guide on workers working conditions 1b- Valid points are to give advice and warning, to take action to remedy any defects, to prepare and submit reports to main inspection authority, to give alteration orders, to give immediate orders in urgent cases with fast executory force, to take legal proceedings, to take action in case of violation of national and local laws. Again C-81 is the reference. 2- There are more than 25 points available for this. Valid points include mgmt. commitment, policy signed, manager always seen at site, low incident rate, RA completed, RA made using worker inputs, good worker attitude and behaviour, manager is approachable, money/resource is given for rest and storage improvement, workers clean up with pride to work, low staff turnover, many long term employees, new worker attracted to join, worker are competent, manager talks and listen to workers, active monitoring happens, inspection are done, record of all accident and incident kept, first aid arrangement in place, emergency arrangement in place, supervision of worker happens, information is given to temporary workers, training is given, induction is given, buddy system is done, etc. 3a- Reasons are to prevent more harm to someone else, to allow investigation to start, to allow third party external investigation to start, to prevent more hazard and risk to others, to avoid tampering of evidence, to avoid removal of evidence, to prevent unauthorized access to the site, to avoid modification or alternation to scene, to allow inspection of the site etc 3b- Valid points are to find causes, find root and immediate causes, to prevent reoccurrence, best practise, since injury severity was high, as a pro-active approach, for demonstrating compliance, for better worker morale, to show the Org cares about HS, to find trends and patterns, to collect statistics, to find issues in RA, to find issues in HSMS, to find issues in current control measures, issues like storage of too much cheese, issues like overloading the rack, to avoid future insurance claims, to provide info for insurance company, to collect as leading indicator, as part of active monitoring approach, to identify unsafe acts, to identify unsafe conditions etc. GRAMMAR ISSUE (refer to class discussion on 29th june) 4- Valid points are lack of experience, poor competency, poor skills, don’t know how to use machine safely, never done this job before, not good personality type, poor risk perception, he thought it was easy job, did not isolate power, poor diligence, complacency (taking for granted), over enthusiasm, using chair instead of proper access platform, young age taking more risk, fatigue and tiredness, busy and long shift causing fatigue, poor alertness, poor hazard awareness, low maturity, etc. 5- Valid point here are ony written format was used, workers may not be able to read due to illiteracy, they forgot fast after one time reading, may not have read at all, may be visually challenged some of them so couldn’t read, written language may not be known to all workers, lack of clarity and jargons used in written format, instructions got lost or damaged, only during induction this was given, no other refresher given, no training, no drills and practise, no updating done, worker not knowing where to look for emergency instructions etc. The trick is this question was that one had to focus on limitation of using only written format of communication and that can restrict many workers from not following it fully. 6- Common mistake many make for this is mixing worker rights with responsibilities. Avoid this mistake by not writing points about training, consultation etc. Be clear what is responsibility and what is right. Valid points for this are no co-operating with employer, not following instructions, not done this before anytime still doing it without
help, cleaning the machine alone, using chair to work at height, not using mobile platform to work at height, not using the buddy to do the work, not taking care of own safety, trying to clean and open machine by himself, getting affected by his acts and omissions at work, not complying with procedures, not isolating power supply etc. 7- Valid points are permit signatures of issuer, sign of receiver, displaying 3 copies, supporting arrangements for safety, supporting equipment for safe working, monitoring and auditing, cancellation procedures, handover procedures, work suspension procedures, time duration specified, date and time specified, clear details of hazards identified, details of task and job specified, only trained workers used for the job, emergency and first aid process identified, related RA accessed and kept ready, related SSW used, having safe PIC in charge of all operations, using correct type of permit, etc. 8- Here valid points are CHANGES that happened, changes to production line, changed to number of workers, vulnerable workers being there, temporary workers being recruited, change in premises, unwanted evens like accident and near miss, collapse of rack, young worker accident, worker not knowing how to react in emergency, ineffective communication, no SSW noted, no PTW recorded, higher number of customers, higher number of vehicles, higher traffic movement in site, changes in working practise, 50% more cheese being made etc. Remember, CHANGES and UNWANTED EVENTS are two major reasons that trigger a review for HSMS, RA, SSW etc.
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