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 2010
Comments on individual questions
2010 NEBOSH, Dominus Way, Meridian Business Park, Leicester LE19 1QW tel: 0116 263 4700
fax: 0116 282 4000
email: [email protected]
The National Examination Board in Occupational Safety and Health is a registered charity, number 1010444 T(s):exrpts/J/J-A 1007
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 The Scottish Qualifications Authority (SQA) in Scotland
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 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 2010
Any enquiries about this report publication should be addressed to: NEBOSH Dominus Way Meridian Business Park Leicester LE10 1QW Tel: 0116 263 4700 Fax: 0116 282 4000 Email: [email protected]
Many candidates are well prepared for this unit assessment and provide comprehensive and relevant answers in response to the demands of the question paper. This includes the ability to demonstrate understanding of knowledge by applying it to workplace situations. There are always some candidates, however, who appear to be unprepared for the unit assessment and who show both a lack of knowledge of the syllabus content and a lack of understanding of how key concepts should be applied to workplace situations. In order to meet the pass standard for this assessment, acquisition of knowledge and understanding across the syllabus are prerequisites. However, candidates need to demonstrate their knowledge and understanding in answering the questions set. Referral of candidates in this unit is invariably because they are unable to write a full, well-informed answer to the question asked. Some candidates find it difficult to relate their learning to the questions and as a result offer responses reliant on recalled knowledge and conjecture and fail to demonstrate any degree of understanding. Candidates should prepare themselves for this vocational examination by ensuring their understanding, not rote-learning pre-prepared answers. 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.
The International Diploma in Health and Safety is taught and examined in English. Candidates are therefore expected to have a good command of both written and spoken English including technical and scientific vocabulary. The recommended standard expected of candidates is equivalent to the International English Language Testing System (IELTS) level 7 (very good user). It is evident from a number of scripts that there are candidates attempting the examination without the necessary English language skills. More information on the IELTS standards can be found at www.ielts.org
UNIT IA – International management of health and safety
Section A – all questions compulsory
Outline the concept of the organisation as a system.
Identify suitable risk controls at EACH point within the system AND give an example in EACH case.
Just as a system is comprised of a number of interlinked components so might an organisation, and candidates were expected to outline these components which could be identified as inputs, such as design, procurement, recruitment of personnel, and information; processes for example operations both routine and non-routine, plant and maintenance and outputs such as products, packaging and transport. The system as a whole – the organisation – would need to interact with the environment in responding to matters such as the current markets and client needs and would need to be subjected to monitoring procedures and react to any changes found to be necessary. For part (b), an identification of the risk controls for each component was necessary. For inputs, this would involve controlling the quality of physical resources such as managing the supply chain and ensuring conformance with set standards; human resources by adopting strict recruitment standards designed to ensure competence in those who were invited to join the organisation and information by ensuring it is always up to date, relevant and comprehensible. Control of the process and work activities would be concerned with the premises, plant, procedures and people and would, by the use of risk assessment, involve the application of hierarchical measures such as risk avoidance, risk reduction, risk transfer, risk retention and behaviour safety. The control of outputs would be concerned with products and services and would address matters such as waste management, product liability insurance, contractual obligations and customer aftercare. Very few candidates seemed to know what was required in answer to this question and seemed to be confused by the term ‘system’. Some referred to the HSG65 model and described the roles of senior management in the setting of objectives and targets. For part (b), some answers referred to risk avoidance, reduction and transfer.
A maintenance worker was asphyxiated when working in an empty fuel tank. A subsequent investigation found that the worker had been operating without a permit-to-work. (a)
Outline why a permit-to-work would be considered necessary in these circumstances.
Outline the possible reasons why the permit-to-work procedure was not followed on this occasion.
In answer to part (a) of the question, candidates were expected to outline that a risk assessment of the work to be done would have identified the need for a permit to work since the activity involved was a non-routine high risk task in a confined space where the precautions to be taken were complex particularly since additional hazards might be introduced as the work progressed and it was, therefore an activity requiring a structural and systematic approach. For part (b), one possible reason might have been that no, or an inadequate risk assessment had been carried out and consequently the potential hazards had not been identified. There could also have been a poor health and safety culture within the organisation where violations were routine and where a permit to work system was considered to be too bureaucratic and where complying with the terms of a permit prevents a task being finished quickly particularly when there is pressure to complete. Candidates could also have outlined other reasons such as the difficulty in organising the required control measures before starting work, particularly if a competent person was not at hand to authorise the permit; the failure on the part of management to stress the importance of using a permit in such circumstances and ultimately the possibility that the organisation had failed to introduce and operate a permit to work system. The question, particularly part (a), produced some reasonable answers which showed a good understanding of the permit to work system and the problems involved in its use. For part (b), however, the difficulty in organising the permit and individual complacency, were not often mentioned.
In relation to a binding contractual agreement give the meaning of: (i)
In relation to a new contract outline the health and safety information which should be stated in the contract terms.
‘Express terms’ are those specifically mentioned and agreed by all parties at the time the contract is made. They may take account of unusual circumstances but should not include unfair terms. ‘Implied terms’ were not so well understood by candidates. They are neither written in the contract nor specifically agreed, are open to interpretation and include terms such as matters of fact, matters of law and matters of custom and practice. In cases of dispute they may ultimately have to be determined by a court of law.
In relation to a new contract, one might expect to find in the contract terms, reference to the provision of a safe working environment with safe means of access and egress and the provision of safe plant and equipment. Reference should also be made to the need to draw up procedures to deal with any emergency that might occur, to provide information, training and supervision for the workforce and to ensure adequate welfare facilities were in place. A few candidates seemed to be influenced by the United Kingdom’s Construction (Design and Management) Regulations and wrote of the information that should be supplied by the client and the principal contractor.
Outline a range of factors relating to the individual which influence behaviour in the workplace AND give an example in EACH case.
In answering this question, candidates were expected to outline a range of factors relating to an individual that might influence his/her behaviour in the workplace. These could have included amongst others, motivation; personality involving individual traits and preferences; aptitude perhaps involving innate skills such as the possession of special awareness; experience, education and intelligence; training involving the development of cognitive and physical skills; perception of risk and disability. As well as identifying the particular factors, to obtain the marks available, candidates were also expected to give an example of how each factor might influence the individual’s behaviour in the workplace. Some candidates were often unable to produce the expected examples while others referred to organisational factors such as lack of policy, pressure of work and peer pressure which were not relevant to the question that had been asked.
Identify the objectives of Failure Mode and Effects Analysis (FMEA).
Outline the methodology of FMEA AND give an example of a typical safety application.
A good answer to part (a) of this question, and on this occasion there were few produced, would have stated that the objective of FMEA is to analyse each component of a system in order to identify the possible causes of its failure and the effects of the failure on the system as a whole. For part (b), the methodology of FMEA includes breaking a system down into its component parts and identifying all possible causes of failure of the component; assessing the probability of failure and its effects on the system as a whole; identifying how the failures might be detected for example by a sensor; assessing the probability of failure; allocating a risk priority code to each component based on severity, the probability of failure and the effectiveness of detection; devising actions to reduce the risk to a tolerable level and documenting the results of the exercise in the conventional tabular format. Candidates were generally unable to produce an acceptable outline of the methodology and showed a poor understanding of the technique. They also had difficulty in giving an example of typical safety application with many referring only to a “chemical plant”.
Outline the reasons for establishing effective consultation arrangements with workers concerning health and safety matters in the workplace.
Outline the range of formal and informal arrangements that may contribute to effective consultation on health and safety matters in the workplace.
Few candidates produced good answers for part (a) of the question and seemed to have little understanding of what consultation might involve. Apart from referring to the legal requirements for consultation, they were expected to outline other reasons such as providing a demonstration of management commitment to health and safety; developing ownership of safety measures amongst workers; improving perception about the value and importance of health and safety; and obtaining the input of workers’ knowledge to ensure more workable improvements and solutions. Part (b) required candidates to outline a range of formal and informal arrangements that could contribute to effective consultation. There were a number of arrangements that could have been outlined such as those involving safety committees and safety representatives; opportunities that could arise at normal departmental or team meetings; tool box talks; discussion as part of safety circles or improvement groups; and the use of staff appraisals, questionnaires and suggestion schemes. Again many were unable to suggest how effective consultation might be achieved in the workplace either formally or informally apart from the formation of committees and discussions with members of Trade Unions. There were even suggestions made that visits to the workplace by a member of an enforcement authority was an effective form of consultation.
Section B – three from five questions to be attempted
Outline the possible functions of a health and safety practitioner within an organisation AND give an example in EACH case.
In answering this question, Examiners were looking to candidates to outline the possible functions of a health and safety practitioner in an organisation. These would include helping in the development, implementation and revision of health and safety policies; promoting a positive health and safety culture within the organisation; advising management on the requirements of health and safety legislation and giving advice on risks in the workplace and the appropriate control measures to be adopted; assisting management in setting performance standards and carrying out proactive and reactive monitoring of the standards when they had been introduced; investigating accidents and cases of ill-health; drawing up procedures for vetting the design and commissioning of new plant and machinery; carrying out or assisting in the audit and review of health and safety management systems; liaising with enforcement authorities and maintaining health and safety information systems. Answers were generally to a reasonable standard though examples were not provided for each case as required. Functions that were seldom mentioned included assisting in the setting of performance standards, maintaining information systems and vetting the design and commissioning of new plant.
The manufacturing process of a planned new chemical plant will involve toxic and flammable substances. The plant is near to a residential area. Outline the issues to be considered in the development of an emergency plan to minimise the consequences of any major incident.
The initial issues to be considered in the development of an emergency plan would be to consider the quantity of toxic and flammable substances involved, the possible causes of a major incident, the likely extent of the damage and the area of the plant and the surrounding area which is vulnerable. Consideration will then have to be given to the availability of resources to deal with the incident should it occur and what action would be taken to minimise its extent by for example shutting off services and controlling spillage and pollution. There will need to be a clear allocation of responsibilities on site to deal with the incident, to establish a control centre and to make arrangements for staff and equipment call out. A decision will have to be made on how the alarm will be raised on site and in the neighbourhood and this will require liaison with the community and particularly with representatives of the local authority, the police and the emergency services since while the on site plan will be prepared by the plant operator, a second off site plan, which may have to consider amongst other things the provision of information to nearby residents and the possibility of their evacuation if an incident were to occur, will be very much the responsibility of the local authority. The on site plan will also need to address the arrangements for clean up and decontamination after the event and for dealing with the media. It will of course be imperative for the plan once it has been developed to be tested and assessed in a ‘mock incident’ involving both workers and residents. Most candidates coped well with this question and particularly with the on site plan. If there were deficiencies, it was that references to controlling initial spillage and pollution and cleaning up and decontamination after the event were not often made.
The employer should set up appropriate arrangements to notify occupational accidents, occupational diseases, dangerous occurrences and commuting accidents to the competent authority in accordance with national laws. (a)
Outline appropriate arrangements which the employer should have in place for notifying such events.
The following information is from a company’s annual report : The company has done much better at health and safety in the last year compared to previous years. The significant reduction in accidents and fatalities shown in the table below is due to our new health and safety advisor and a reduction in staff numbers. The management team are confident of further reductions in 2010.
2006 2007 2008 2009
240 185 180 170
1500 1400 1300 900
? ? 11 4
Calculate the accident incidence rates AND comment on the findings.
Assess the company’s management of health and safety from the information in the annual report.
The employer should first identify a competent person who will be responsible for reporting accidents and other reportable events to the competent authority. If the workplace is shared, an agreement will need to be reached on who accepts the responsibility for reporting. All reported incidents should be investigated again by a competent person and information on all accidents provided to the workers. Workers will have to be informed of the system that is adopted and what is expected of them and their cooperation ensured. Records should be kept of any incident that occurs and these should be easily retrievable though the medical confidentiality of individuals will have to be respected. Answers to this part of the question were generally lacking in detail with reference being made only to the appointment of a competent person and the keeping of records. For part (b)(i), in calculating the accident incidence rates from the information given, candidates should have divided the number of accidents that occurred by the number of persons employed and then multiplied the answers by a common and appropriate multiplier (in this case 1000 workers). The rates would thus appear as follows: 2006: 2007 2008 2009
(240/1500) x 1000 = 160 (185/1400) x 1000 = 132 (180/1300) x 1000 = 138 (170/900) x 1000 = 188
Whilst the number of accidents decreased between 2006 and 2009 so did the number of workers but in 2009 there was a rise in the incidence rate. This part of the question was in general well answered, though a few candidates did err in their calculations while others appeared not to notice the rise in the incidence rate for 2009. In contrast, part (b)(ii) was poorly answered. In their assessments candidates were expected to comment that the annual report was expressed in very general terms, gave no commitment to the management of health and safety and lacked detail both on the causes of the accidents and on the safety management systems in place. The fatality rate seemed to be tolerated and accepted and the company expressed no remorse about their accident performance. Whilst the directors might be confident that further reductions in the number of accidents would occur, apparently ignoring the rise in the incidence rate, they gave no indication of how this would occur. Most candidates seemed to have little understanding of how to analyse the given data and were generally able to comment only that no mention had been made in the report of the fatal accidents.
Outline the role of health and safety legislation in the workplace.
Outline the limitations of health and safety legislation in the workplace.
This question was not popular and few of those who attempted it produced answers to a reasonable standard. For part (a), candidates were expected to outline that the role of health and safety legislation in the workplace is to provide workers with the minimum standards of health and safety which through employer compliance, prevents injuries and occupational illness. It ensures the appointment of competent workplace inspectors and allows for penalties against those who are found to be breaking the law. Prescriptive legislation provides specific advice and rules to follow while the role of goal setting legislation is to provide general advice and localised interpretation and ownership. Legislation can address any specific regional needs, may harmonise standards amongst countries, provides a civil route for obtaining compensation even if no fault liability exists in certain countries and is a demonstration of compliance with ILO conventions. In the answers provided, there was little reference to the role of legislation in preventing injury through compliance, in penalising employers who broke the law and in giving the opportunity for the injured to obtain recompense for their injuries. For part (b), the limitations of health and safety legislation are that in the case of prescriptive legislation, it quickly becomes outdated, does not address social, technological or economic changes and often lacks detailed regulations to supplement its requirements while the interpretation of goal setting legislation is variable and inconsistent. Much of the legislation addresses industrial safety and not occupational health. There are often insufficient resources available for inspecting workplaces and enforcing the legislation and often the limited penalties awarded are not a sufficient deterrent for employers caught breaking the law. Additionally, many employers and workers are unfamiliar with the content of the legislation and this is not helped by the lack of involvement of employers, trade unions and workers in the process of standard setting. Again, the main and often sole limitation that came to mind and was mentioned was the variety and inconsistency in the interpretation of goal setting legislation.
As the Health and Safety Adviser to a large organisation, you have decided to develop and introduce an in-house auditing programme to assess the effectiveness of the organisation’s health and safety management system. Describe the organisational and planning issues to be addressed in the development of the audit programme. You do not need to consider the specific factors to be audited.
This question was designed to assess candidates’ understanding of the organisational and planning issues to be addressed in the development and implementation of an audit programme. Some of the issues that needed to be addressed included a consideration of the logistics and resources required and obtaining the support and commitment of senior managers and other key stakeholders since if this was not obtained, much required information might not be forthcoming and the value of the audit would be diminished. Other matters for consideration were the nature, scale and frequency of the auditing relative to the level of risk involved, the standards against which the management arrangements were to be audited, the identification of the key elements of the audit process such as the planning, interviews and verification, feedback routes and the preparation and presentation of the final report, the use of a single auditor or audit teams whether internal or external, and the training they would need. This was a popular question, but many were not able to obtain all the marks available because their answers lacked the required detail. There were few who considered the form the audit was to take, the feedback routes and the preparation and presentation of the final report. The lack of detail resulted in answers which were more at Certificate rather than Diploma level.
The National Examination Board in Occupational Safety and Health Dominus Way Meridian Business Park Leicester LE19 1QW telephone +44 (0)116 2634700 fax +44 (0)116 2824000 email [email protected]