January 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 JANUARY 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-A0901
EXTERNAL
DW/DA/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 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 one or more of the questions 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 a sufficient 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.
3
EXTERNAL
UNIT IA – International management of health and safety
Section A – all questions compulsory
Question 1
Outline ways in which a health and safety practitioner could evaluate and develop their own competence whilst working in an advisory role.
(10)
Health and safety practitioners might evaluate their own practice in a number of ways including measuring the effects of changes and developments they have introduced and implemented in their organisations; by setting personal objectives and targets and assessing their performance against them; by reviewing failures or unsuccessful attempts to produce change; by benchmarking their practice against that of other practitioners and against good practice case studies or information; by seeking advice from other competent professionals; by seeking feedback from others such as clients of the organisation and as part of the annual appraisal of their performance by senior management. They may develop their practice by augmenting their core knowledge and competence in obtaining a recognised professional qualification; by keeping up to date by undertaking training in relevant areas; by participating in CPD schemes; by ensuring they have access to suitable information sources; by networking with their peers at safety groups and conferences; by seeking advice from other competent practitioners and consultants and by initiating and following a personal development plan. Answers to this question were to a reasonable standard though some candidates did not appear to have given sufficient attention to its wording and outlined the role of a safety practitioner.
Question 2
Describe the requirements of an interview process that would help to obtain from witnesses the best quality of information relating to a workplace accident.
(10)
Answers to this question were to a good standard. Candidates who did well approached the question in a methodical way starting with the need to interview as soon as possible after the event though it may be necessary to postpone the interview if the witness is injured or in shock; providing a suitable environment for the interview; interviewing one witness at a time; putting the witness at ease, establishing a good rapport, taking care to stress the preventive purpose of the investigation rather than the apportioning of blame; explaining the purpose of the interview and the need to record it; using an appropriate questioning technique to establish key facts and avoiding leading questions or implied conclusions; using appropriate sketches or photographs to help with the interview; listening to the witness without interruptions and allowing sufficient time to give their answers; and summarising and checking agreement at the end of the interview. Better answers also included the need to adjust language to suit the witness; clarifying what was actually witnessed as opposed to deduced; inviting the witnesses to have someone accompany them if they so wish and showing appreciation at the end of the interview.
4
EXTERNAL
Question 3
A health and safety management programme encompasses the following concepts: (a)
risk avoidance;
(2)
(b)
risk reduction;
(2)
(c)
risk transfer;
(3)
(d)
risk retention.
(3)
Identify the key features of EACH of these concepts AND give an appropriate example in EACH case. Risk avoidance involves taking active steps to avoid or eliminate risk for example by discontinuing the process, avoiding the activity or eliminating a hazardous substance. Risk reduction involves evaluating the risks and developing risk reduction strategies. It requires the organisation to define an acceptable level of risk control to be achieved which could be by the use of safety/risk management systems or the use of a hierarchy of control measures. Risk transfer involves transferring risk to other parties but paying a premium for this for example by the use of insurance; the use of contractors to undertake certain works; the use of third parties for business interruption recovery planning or outsourcing a process or processes. Risk retention involves accepting a level of risk within the organisation along with a decision to fund losses internally; it could involve risk retention with knowledge where the risk has been recognised and evaluated or risk retention without knowledge where the risk has not been identified - obviously an unfavourable position for the organisation to be in. There were again some good answers offered for this question though some candidates did not provide the required examples.
Question 4
Train drivers may spend long periods of time in the cab of a train and may experience loss of alertness. This can increase the risk of human error. Outline a range of measures that could reduce loss of alertness in train drivers.
(10)
In answering this question it should not have proved too difficult to outline a range of control measures even though candidates may not have possessed knowledge of the rail industry. These would include the introduction of a shift system to minimise the risk of fatigue with controls being introduced on shift length, the provision of regular breaks and sufficient recovery time particularly during and after the potentially high risk period between midnight and 06.00 hrs and the assessment of risks from unplanned call-out. It would also be necessary to introduce a pre-employment medical examination followed by regular in service health screening including measures to manage stress, and to put in place an alcohol and substance use policy with arrangements for its enforcement including random testing. Attention would also have to be given both to the design of the cabin and the driver’s activity including the provision of air conditioning, controls for illumination and sun shading, adjustable seating and the introduction of noise control measures. The variation of route allocation may help to maintain alertness and other measures could have included the fitting of hold to run or other audible warning devices and the need for the driver to engage in frequent communication with the guard or control centre.
5
EXTERNAL
Those candidates who did not do so well either wrote at length on the subject of human error or concentrated only on ergonomic issues.
Question 5
Outline how safety tours could contribute to improving health and safety performance and to improving health and safety culture within a company. Discussion of the specific health and safety requirements, problems or standards that such tours may address, is not required.
(10)
There are a number of contributions that safety tours could make in improving health and safety performance in a company including helping to identify compliance or noncompliance with performance standards and, by repetition in the same area, indicating an improving or worsening trend and checking the implementation and effectiveness of agreed courses of action. Additionally, when carried out in different areas, they can point up common organisational health and safety problems and may identify opportunities for improved performance through the observations of the tour members or by their conversations with employees during the tour. When tours are carried out on an unscheduled basis, there is the additional benefit of observing normal standards of behaviour rather than those specifically adopted for the event. Tours may also help to improve the health and safety culture of an organisation particularly if they are led on a regular basis by members of management indicating their commitment to the cause. Additionally, prompt remedial action for deficiencies noted enhances the perception of the priority given to health and safety matters whilst the involvement of employees in the tours will again encourage ownership and improve their perception of the importance of the subject, particularly if the findings of the tours are shared with the workforce on a regular basis. Candidates who structured their answers to deal first with performance and then culture normally did best though on the whole the standard was little more than average. Some candidates did nothing more than describe a number of health and safety requirements.
Question 6
An organisation has decided to adopt a self regulatory model for its health and safety management system. Explain: (a)
the benefits; and
(b)
the limitations,
(6)
of self regulation in connection to the management of health and safety.
(4)
One of the more important benefits of self regulation is that it is developed by those directly involved in the management of health and safety and this can generate a sense of ownership. Other benefits include the fact that it may be quicker to achieve than statutory regulation; can result in higher levels of compliance; can easily be adapted or updated; can often offer a cheaper and quicker means of addressing issues; and may often result in a closer relationship between industry and its clients.
6
EXTERNAL
The limitations of the model are that all those involved may not operate within the selfregulatory rules and that there is a danger of self interest being put ahead of employee or public interest. Additionally, self regulation can result in lower levels of compliance; there is no third party or independent auditing and it is not valued as highly by stakeholders. Answers were disappointing. Some candidates did not understand the concept of self regulation while others were content to offer only an explanation of OHSAS 18001.
Section B – three from five questions to be attempted
Question 7
An employer wishes to build a new gas compression installation to provide energy for its manufacturing processes. An explosion in the installation could affect the public and a nearby railway line. In view of this the employer has been told that a qualitative risk assessment for the new installation may not be adequate and that some aspects of the risk require a quantitative risk assessment. (a)
(b)
(c)
Explain the terms ‘qualitative risk assessment’ AND ‘quantitative risk assessment’.
(5)
Identify the external sources of information and advice that the employer could refer to when deciding whether the risk from the new installation is acceptable.
(5)
A preliminary part of the risk assessment process is to be a hazard and operability study. Describe the principles and methodology of a hazard and operability (HAZOP) study.
(10)
Qualitative risk assessment involves the use of broad categories to arrive at a broad measure of risk. Following a comprehensive identification of hazards, broad categories are used to classify the likelihood of the hazards being realised and the severity of their consequences. The categories may be descriptors or numbers. Most everyday risk assessment is qualitative and such assessments tend to be subjective. Quantitative risk assessment on the other hand is a numerical representation of the actual frequency and/or probability of an event and its consequences. It often involves comparison with specific criteria and is objective. In identifying external sources of information and advice for part (b), candidates could have referred to the acceptability or tolerability criteria for risk for example as set down in the Prevention of Major Industrial Hazards; guidance from the enforcing authority which identifies hazards and sets risk control standards to meet legal and good practice requirements; statistics and guidance from other authoritative sources such as professional bodies, trade associations and insurers; instructions from the plant manufacturers and guidance from other organisations with similar installations.
7
EXTERNAL
Part (c) sought to test candidates understanding of HAZOP studies. The purpose of a HAZOP is to identify deviations from intended normal operation and is best used at the design stage or when modifications are proposed for an existing installation. They were expected to explain the need for a team approach with specialists from relevant disciplines, a team leader and the need to define the scope of the study, breaking down the process into elements, collecting data and information to support the study and adopting a brainstorming approach. Candidates should also have described that deviations are prompted by the use of guide words which are applied to relevant process parameters such as temperature or flow, and marks were available for giving examples with application to process variables such as “no” (negation of the design intent), “more” (quantitative increase), “as well as” (qualitative increase) and “other than” (complete substitution). Better answers added that the study examines the possible causes and consequences of each deviation, identifies possible corrective actions and is documented and recorded. This was a popular question and answers were generally to a reasonable standard though many candidates did have difficulty in identifying external sources of information and advice for part (b).
Question 8
(a)
(b)
(c)
Organisations are said to have both formal and informal structures and groups. Outline the difference between ‘formal’ AND ‘informal’ in this context.
(6)
Internationally recognised health and safety management models, including OHSAS 18001 and HSG65, include an ‘organising’ element which requires control, co-operation, communication and competence. Outline, using practical examples, what ‘co-operation’ means in this context.
(6)
Organisational change can, if not properly managed, promote a negative health and safety culture. Outline the reasons for this.
(8)
A formal structure or group is hierarchical, generally shown in an organisational chart and characterised by defined responsibilities and agreed reporting lines, while an informal structure is characterised by social and personal relationships, habitual and related contacts and the presence of strong characters with personality and communication skills that may exert personal influence. In outlining the meaning of “co-operation” for part (b) of the question, candidates should have referred to formal consultation arrangements such as those with safety representatives, direct consultation with employees at team meetings and participation in safety committee meetings and also to informal consultation on safety issues during day to day discussions with employees. “Co-operation” would also include the involvement of employees in safety processes such as carrying out risk assessments and developing systems of work; playing their part in incident investigations, inspections, audits and other monitoring processes; being encouraged to report hazards and “near miss” incidents; and being invited to become members of safety circles for problem solving. Finally the provision of training and development would be an important factor in maximising the involvement of employees in health and safety matters.
8
EXTERNAL
Organisational change can, if not properly managed, promote a negative health and safety culture for a number of reasons such as: the profile of safety may not be maintained during the change and new job responsibilities may not have fully covered safety issues; normal consultation mechanisms and routes may be disrupted; training in safety issues for new job-holders or for new responsibilities may not have been completed; the lack of adequate means of communication during the change may compromise trust and poor consultation on change issues may have a negative effect on cooperation and on other issues including safety; there may be concern about job security which could encourage risk taking; redundancy processes or cost reduction measures may produce a perception that the organisation is not concerned with personal well-being; experience or knowledge of risk controls may be lost with changes of personnel; the safety implications of changes in personnel or numbers may not have been properly assessed; extensive movement of personnel makes it harder to establish shared perceptions and values; a greater use of outsourcing without good control may result in lower safety standards by contractors which may affect the perception of priorities; and last but not least the effects of natural resistance to change. Not many candidates attempted this question and answers that were submitted were not to a good standard. There seemed to be little understanding either of the concept of formal and informal structures or of the term “co-operation”.
Question 9
As part of its health and safety management system an organisation monitors its health and safety performance. (a)
Excluding safety techniques.
tours,
outline FOUR
active
monitoring (4)
(b)
Outline FOUR reactive monitoring techniques.
(c)
Explain the benefits of:
(4)
(i)
active monitoring;
(6)
(ii)
reactive monitoring.
(6)
In answering part (a), candidates could have outlined active monitoring techniques such as physical inspections of the workplace to identify hazards and unsafe conditions; safety audits where the systematic critical examination of all aspects of an organisation’s health and safety performance against stated objectives is carried out; safety sampling of a specific area or particular items of plant with repeat sampling to observe trends; safety surveys involving in depth examinations of specific issues or procedures such as changes in working practices; environmental monitoring and/or health surveillance; safety climate measures such as the use of employee questionnaires; behavioural observation and measuring health and safety performance against set targets and benchmarking where performance in certain areas is compared with that of other organisations with similar processes and risks. For (b), reactive monitoring techniques would include accident investigation to determine root causes and reasons for substandard performance; ill-health reports which provide information about work-related conditions and issues that affect health; near miss and dangerous occurrence reports which provide details of events that point to root causes common to accidents and point to failures in control measures; enforcement action which relate to specific breaches of the law and the need for improvements in health and safety; the number of civil claims again pointing to areas where improvement is necessary; the analysis and comparison of costs associated with accidents and employee complaints which provide an indication of workplace health and safety shortcomings that give concern.
9
EXTERNAL
In answering part (c), candidates could have explained that the benefits of active monitoring are that it is not reliant on the reporting of hazards and gives a picture of current performance; it identifies hazards before the event and allows corrective measures to be implemented thus reducing loss; it allows measurement of compliance and non-compliance; it identifies reasons for non-adherence to procedures; it enables more effective decision making and finally enables employee involvement and communication. As for reactive monitoring, its benefits are that it measures historic performance; it relies on accurate reporting; it identifies the consequences of hazards and importantly the causes of failure; it identifies legal compliance and noncompliance; it demonstrates commitment and improves morale; it allows data to be used to compare trends over time; and provides an opportunity to learn. This was a very popular question and most candidates who answered it did well.
Question 10
(a)
(b)
(c)
In relation to the improvement of health and safety within companies, describe what is meant by: (i)
corporate probation;
(2)
(ii)
adverse publicity orders;
(2)
(iii)
punitive damages.
(3)
Outline a mechanism by which the International Labour Organisation can influence health and safety standards in different countries.
(7)
Explain the role of legislation in improving workplace health and safety.
(6)
In answering part (a) of the question, candidates could have described corporate probation as a supervision order imposed by a court on a company that has committed a criminal offence. When applied to a health and safety offence, the order might require the company to review its safety policy or its health and safety procedures, initiate a training programme for its directors and senior management or reduce the number of its accidents. Its aim is to instigate a change in the organisation’s culture under the supervision of the court. The intention of an adverse publicity order would be to publicise the failings of an organisation and seek to change its conduct through public perception. It requires the company to make a public statement and to change its approach to the management of health and safety. “Punitive damages”, is a financial or monetary award which, whilst paid to a claimant, is not awarded to compensate them, 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.
10
EXTERNAL
In answering part (b) on the mechanisms by which the International Labour Organisation (ILO) can influence health and safety standards in different countries, candidates were expected to refer to matters such as the development of international labour standards through conventions supplemented by recommendations containing additional or more detailed provisions; the ratification of the conventions by member states which commits them to apply the terms of the convention in national law and practice; the requirement for member states to submit reports to the ILO detailing their compliance with the obligations of the conventions they have ratified; the initiation of representation and complaint procedures against countries for violation of a convention they have ratified; the provision of technical assistance to member states where this is seen to be necessary and, indirectly, through the pressure applied internationally on non participating countries to adopt ILO standards. For (c), legislation has a role in improving workplace health and safety by setting minimum standards which are enforced by a regulator and allowing for punishment of the offender if compliance with the standards is not achieved. It is updated by national or federal government when required, applies to all workplaces thus creating a level playing field and may be prescriptive or goal setting, the latter often supported with interpretation in the form of approved codes of practice or guidance. Candidates provided good answers for parts (a) and (b) however, when an explanation was required in the last part of the question, they did not do as well.
Question 11
Explain the benefits of: (a) (b)
an integrated health and safety, environmental, and quality management system;
(10)
separate health and management systems.
(10)
safety,
environmental,
and
quality
The arguments for and against the use of an integrated management system for safety, quality and environmental issues will need to be considered by many practitioners at some stage during their careers. The question invited candidates to outline their understanding of the key benefits of both an integrated and separate systems. The benefits of an integrated management system could have included: consistency of format and a lower overall cost through the avoidance of duplication in procedural, record-keeping, compliance auditing and software areas; avoiding narrow decision making that solves a problem in one area but creates a problem in another; encouraging priorities and resource utilisation that reflect the overall needs of the organisation rather than an individual discipline; applying the benefits from good initiatives in one area to other areas; encouraging closer working and equal influence amongst specialists; encouraging the spread of a positive culture across all three disciplines; and providing scope for the integration of other risk areas such as security or product safety. Benefits from retaining separate systems could have included: providing a more flexible approach tailored to business needs in terms of system complexity and operating philosophy (for example, safety standards must meet minimum legal requirements whereas quality standards can be set internally – therefore, the need for a more complex system in one element may not be mirrored by a similar need in the other two elements); separate systems might be clearer for external stakeholders or regulators to understand and work with; and finally they may encourage a more detailed and focused approach to auditing and standards. A generally acceptable standard of response from those candidates who attempted this question though some did become a little confused between the two systems.
11
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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