Engineers in Society, COEB 422
Group Name: "SMART" Group Member: Chin Jen Loong
Lecturers:
EE081524
Cheang Lai Ann
ME081466
Teh Yee Ching
ME081862
Sarah Chan Tji Yan
EE081953
Wong Menn Yee
ME081866
Mark Arvind a/l Ishak
ME081564
Assoc. Prof. Dr. Norashidah Bte Md. Din. Mr. Mokthar Bin Majid, Haji Prof. Ir. Dr. Mohammed Nor Mohd Desa
Section: 3 Problem Statement:
You are an engineer and it is known that your project activities/plant production had caused an adverse health, safety and/or environmental (HSE) impact. To improve the HSE quality, you have to cease your project activities/plant production for a period, resulting in inability to meet the schedule and targets. How would you handle in a situation where there is a conflict between code of professional conduct and commercial consideration? Discuss the situation. Give examples and critical analysis of the condition.
CONTENTS Acknowledgement Abstract 1.0
Problem and Research Objective 1.1. HSE Management System 1.2. OHS&E Policy (Occupational Health, Safety and Environmental) 1.3. Planning 1.4. Implementation and Operation 1.5. Corrective Action Implementation 1.6. Management Review
2.0
The aim of investigations 2.1. Investigate all Incidents 2.2. Investigation Procedure 2.3. Gather Information 2.4. Determine the root cause/system failure 2.5. Documents and Findings 2.6. Follow Up and Analyze
3.0
Outcomes of an accident
4.0
Hierarchy of Control
5.0
Case Study 1 (Local) 5.1. Introduction 5.2. Action Taken 5.3. Issue Resolved 5.4. Damage 5.5. Analysis 5.6. Recommendation 5.6.1. Process Control 5.6.2. Equipment and machinery 2
CONTENTS Acknowledgement Abstract 1.0
Problem and Research Objective 1.1. HSE Management System 1.2. OHS&E Policy (Occupational Health, Safety and Environmental) 1.3. Planning 1.4. Implementation and Operation 1.5. Corrective Action Implementation 1.6. Management Review
2.0
The aim of investigations 2.1. Investigate all Incidents 2.2. Investigation Procedure 2.3. Gather Information 2.4. Determine the root cause/system failure 2.5. Documents and Findings 2.6. Follow Up and Analyze
3.0
Outcomes of an accident
4.0
Hierarchy of Control
5.0
Case Study 1 (Local) 5.1. Introduction 5.2. Action Taken 5.3. Issue Resolved 5.4. Damage 5.5. Analysis 5.6. Recommendation 5.6.1. Process Control 5.6.2. Equipment and machinery 2
5.6.3. Ventilation 5.7. Commercial Value vs Professional Conduct
6.0
Case study 2 (International) 6.1. Summary 6.2. Introduction 6.2.1. Uranium mining 6.2.2. Contamination of water 6.2.3. Radioactivity in the air 6.2.4. Spreading of radioactive soil 6.2.5. Dumping of radioactive sludge 6.3.
Course of action taken
6.3.1. Radioactive sludge leaked onto environment 6.3.2. Nuclear energy giant monitors workers health in uranium mining regions 6.4.
Commercial consideration vs. professional conduct
6.5.
Recommendations
7.0
Conclusion
8.0
Appendix A 8.1
Articles
8.2
Documents
8.3
Certificates
8.4
Interview Session
8.4.1 Food Industry HSE 8.4.2 Nuclear Industry HSE 8.5
9.0
Meeting Minutes
8.5.1
Meeting Minutes 1
8.5.1
Meeting Minutes 2
8.5.1
Meeting Minutes 3
8.5.1
Meeting Minutes 4
References 3
Acknowledgement
First and foremost, our team would like to express our gratitude to all three lecturers, Mr. Mokthar bin Majid, Haji, Norashidah bte Md. Din, Assoc. Prof. Dr and Mohamed Nor Bin Mohamed Desa, Prof. Ir. Dr. for their endless support and encouragement to attending classes till the end of this project paper. Their selfless devotion behaviour encourages us to pursue this project under their close supervisory. Their help is greatly appreciated. This project would not be a success without their valuable advices and guidance. Not forget, our team wish to thank friends and colleagues for sharing useful information, especially explicit details while writing this full report. Thank you
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Abstract
Project activities have cause adverse health, safety and/or environmental (HSE) impact. To improve the HSE quality, project activities are ceased for a period, resulting in inability to meet the schedule and targets. This problem as thus created a conflict between the code of professional conduct and commercial considerations. Therefore, this reports provides an in depth research to the task at hand by first introducing to the reader with various code of conducts bequeath of an engineer. Also included, are the HSE Management System, OSH &E Policy, Management Review, Planning, Corrective Action Implementation and Operations. Next, this report diverts to the next set of topics which will include the purpose of an investigation, the outcomes of an accident, and hierarchical controls to be considered. Finally, with all the above laid out, incorporating all the data above is done with real time case study to measure its effectiveness in coping with commercial needs. Recommendation is also provided where necessary to facilitate the research to carve out certain flaws in the real time case investigation done. 1.
Problem and Research Objective
The problem drawn from the assignment relates to the project activities/ plant production which have caused severe health, safety and/or environmental (HSE) impact. With that, projects are ceased for a period, resulting in inability to meet schedule and targets since improvement on HSE quality must be undergone. However, the challenge weighted upon the task is to research the conflict between code of professional conduct and commercial consideration.
The objective that is to be highlighted below in this report provide an in depth research pertaining to the issue above. How the situation is tackled and handled is illustrated in real time case studies to further enhance the reader's understanding. Also, assimilation of literature available engineer code of ethics, management review, OSH & E Policy, Corrective Action Implementation, etc with case studies below is performed to witness and comprehend the mechanics whilst handling of a real case scenario.
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1.1.
HSE Management System
Accidents at work happen almost every day. Despite of the many programs and initiatives introduced by both the regulator and professional institution, the accident trend is still quite alarming. In contrast with the traditional approach such as Job Safety Analysis (JSA), Permit to Work (PTW) and Standard Operating Practices (SOP) which emphasized specifically towards the operational and employee levels; HSE (health, safety and environmental) management system is a more systematic and holistic approach which involves the employee and the whole organization in a common business management system. This eventually means that most safety problems and accident are indirectly linked to management problems. The aim of the safety management system is to avoid and control workplace hazards as well as ensuring ongoing initiatives to reduce hazards. It could assist businesses to selfmanage, prevent and to control their workplace-related hazards if the requirements of HSE are fulfilled. In Malaysia, the requirement of a safety management system is defined in OSHA Section 16 and also in the Control of Industrial Major Accident Hazards (CIMAH) regulation 1996 which is a subsidiary Regulation under the OSHA under sub regulation 5(1)(c). [1] Also, employer should inform all employees of their written safety and health, review and revise the policy as appropriate from time to time and inform employees of any revision of the policy as stated in OSHA Section 16. OSHA 1994 is the best approach in promoting a self-regulation concept for management system development. It is f lexible whereby industries are allowed to choose the type of system appropriate to their operations, hazards and work environment. Given the global economy phenomena and the public pressure on the protection to human lives and the environment an integrated approach to HSE management is now a necessity for industries as compared to focus on safety issues alone. Instead, the latest trend is towards having an integrated HSE management system where still three elements are addressed together. Safety is now seen as inseparable from the aspects of occupational health and environment. It was clear that most proactive companies already have the necessary elements in place such as safety practices, procedures and programs. There are formalized into an 6
integrated management system. Most of these companies have incorporated the health, safety and environmental into a coherent HSE Management System. An example of a framework developed by SHELL for managing all aspects of the development in HSE management system is shown below:
Figure 1.1: SHELL Framework [2] This framework facilitates the structured management of HSE hazards and effects associated with the business, and ensure that moderate methods are in place for properly controlling the hazards. In compliance with law, the management system is structured according to ISO standard framework of: plan, do, check and provide feedback. [2]
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Figure 1.2: HSE Management System [2] As mentioned previously, HSE Management System is an integrated management approach. It promotes continual improvement by complying with rules and regulations such as OSH&E policy; do planning on implementation of HSE; implementation and operation of the plan; taking corrective action on implementation and lastly management review. The cycle is then repeated in order to promote ongoing improvement process on HSE management system. 1.2. OHS&E Policy (Occupational Health, Safety and Environmental)
The general policy of OHS&E is:
―The occupational health and safety of all persons employed within the facility, residents and those visiting the facility are considered to be of utmost importance. Resources in line with the importance attached to occupational health and safety will be made available to comply with all relevant Acts and Regulations and to ensure that the workplace is safe and without
risk to health.‖ [3] [4] This is achieved through: Complying with legal laws and regulations, standard and guidelines; Structure objectives and targets with the aim of preventing and controlling work
related incidents in relation to work activities, products and services; Defining roles and responsibilities for occupational health, safety and environment.
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Strategies will include: Providing ongoing education and training to employees; Providing enough resources to ensure occupational health, safety and environment is a
central part of the organisation; Ensuring occupational health, safety and environment management principles are
included in all organisational planning activities; Consulting with employees and other parties to improve decision-making on
occupational health, safety and environment matters; Distributing occupational health, safety and environment information, including this
policy, to all employees and interested parties; Ensuring incidents are investigated and lessons are learnt within the organisation; Ensuring effective injury management and rehabilitation is provided to all employees.
1.3. Planning
Planning is process where what to do and how to do is deciding in advance. It is one of the basic managerial functions. Planning is closely connected with creativity and innovation. It involves setting objectives and developing appropriate courses of action to achieve these
objectives. According to Koontz and O‘Donnel, ―Planning bridges gap from where we are to where we want to go. It makes it possible for things to occur which would not otherwise
happen.‖ Planning function of management consists of the following steps: [5] 1. Establishment of objectives 2. Establishment of planning premises 3. Choice of alternative course of action 4. Formulation of derivative plans 5. Securing co-operation 6. Follow up of plans Wood Group, the leading international energy services company as an example, their aim of HSE planning is to apply a systematic and structured approach to the identification and 9
implementation of improvements to the HSE Management System. Each operating company
will issue an annual HSE plan, based upon management‘s assessment of the current status of HSE performance, objectives and targets set in order to meet the requirements of legislation and company policy, and the overall objective of continuous improvement. Operating company management, in liaison with line management, HSE Advisors and the workforce, will produce an annual HSE plan that should, as a minimum, include the following: [4] Improvements/deficiencies identified by the HSEMS review process. Improvements/deficiencies arising from internal and external audits. Findings of the annual and quarterly HSE performance reviews and target setting
exercises. The application of existing and new legislation. A review of risk control and risk assessments and identification of potentially new or
increased hazards. Responsibilities for achieving goals. Input from client initiatives as appropriate.
1.4. Implementation and Operation
After planning, implementation and operation are the next steps i n putting together an effective management system. This will provide the structure and organisation to into practice the principles and processes HSE management system. There are nine key elements to achieve effective implementation and operation, namely: [4] Leadership and accountability People Communication and involvement Documentation, procedures and records Facilities management Procurement Managing contractors Emergency response Sustainability
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1.5. Corrective Action Implementation
Corrective action is an action designed to correct an undesirable HSE problem or defect in the management system. Examples may include breakdown of controls, accidents, injuries, fire, illness release to the environment or other HSE related loss, undesirable trend in HSE metrics, etc. Management should ensure and be responsible for the conduct and verification of activities and tasks according to relevant procedures. This responsibility and commitment of management to the implementation of policies and plans includes, amongst other duties, ensuring that HSE objectives are met and that performance criteria and control limits are not breached. Management should ensure the continuing adequacy of the HSE performance of the company through monitoring activities. As for monitoring, the company should maintain procedures for monitoring relevant aspects of HSE performance and for establishing and maintaining records of the results. For each relevant activity or area, the company should: [2] [6]
Identify and document the monitoring information to be obtained Specify the accuracy required of results Specify and document monitoring procedures, and locations and frequencies of
measurement Establish, document and maintain measurement quality control procedures Establish and document procedures for data handling and interpretation Establish and document actions to be taken when results breach performance criteria Assess and document the validity of affected data when monitoring Systems are found to be malfunctioning Safeguard measurement systems from unauthorised adjustments or damage
Procedures are required for both active and reactive monitoring. Active monitoring provides information in the absence of any incident, ill-health or damage to the receiving environment. It includes checking that HSE Management System requirements (e.g. procedures) are being complied with, and that objectives and performance criteria are met. Reactive monitoring provides information on incidents (including near-miss incidents, illhealth or environmental damage) that have occurred and provides insights into the means of preventing similar incidents in the future.
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On the other hand, the company should define the responsibility and authority for initiating investigation and corrective action in the event of non-compliance with specified requirements relating to the HSE Management System, its operation or its results. Situations of non-compliance may be identified by the monitoring programme, through communications from employees, contractors, customers, government agencies or the public, or from investigations of incidents, The company should maintain procedures for such investigation and corrective action, by which the management of the individual function or activity concerned, in consultation with the management representative, should act as shown in the figure below:
Figure 1.3: Investigation Procedure [7]
1.6. Management Review
Management review is an extremely critical part in a management system. It can be an informal process, but generally requires a formal structure and r ules of conduct. Management reviews are carried out by, or on behalf of, the management personnel having direct responsibility for the system. Management reviews identify consistency with and deviations from plans, or adequacies and inadequacies of management procedures. [7] As mentioned previously, corrective action and improvement are critical components in verifying that the management system is working and identifying areas for improvement. Hence, The HSE plan should schedule formal audits, regular monitoring and measurement,
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and structured management review to ensure the continuing suitability, adequacy and effectiveness of the management system. These reviews and audits will incorporate any HSE concerns of employees, contractors and external stakeholders. As an example, the management review in Wood Group aims to review the effectiveness of the HSE management system at both Group and Operating company level by measuring compliance with the performance measures defined within their HSE document. The activities included in the Group HSE management system review will be co-ordinated by the Group Head of HSE and completed annually; while operating company HSE management review will be co-ordinated by the HSE advisor and completed annually by the company senior management. Each operating company should conduct an annual review of the suitability and effectiveness of the HSE management system. This should consider the following:- [4]
• Overall performance of the HSE management system by review of proactive and reactive performance measures
• Results of audits and completion of identified corrective actions • Results of accident / incident reviews • Progress made against annual company plan • Pending legislation • Objectives and targets for the following year based on the annual review 2.0
The aim of investigations
Accidents are usually complex, there are possibilities that they are caused by 10 or even more events [10]. Therefore, it is necessary to examine some underlying factors in a chain of events that ends in an accident. Thus, an extensive investigation should be done to
look for the ―root cause‖ as well as determine any deviation resulted in the accident. Even a minor accident that involves no injury or property damages or a near miss reporting and investigation allow you to identify and control hazards before they cause a more serious incident should still be investigated to determine the risks that should be corrected. Accident/incident investigations are a tool for uncovering hazards that either were missed earlier or have managed to slip out of the controls planned for them. It is useful only when done with the aim of discovering every contributing factor to the accident/incident to "foolproof" the condition and/or activity and prevents future occurrences. In other words, your objective is to identify root causes, not to point fingers at each other. 13
2.1
Investigate all Incidents
Trends are a series of similar, minor incidents that may indicate a growing problem. Identifying a trend can help you eliminate potential hazards before they cause a serious accident. By identifying trends early and intervening to correct or eliminate hazards, you can improve employee safety and prevent accidents. To identify trends you need to investigate all incidents, not just those that caused an injury. An incident is an OSHA recordable accident, vehicle accident, incident involving equipment damage, hazardous material spill, fire, and not
forgetting ―near miss‖ that had the potential to cause injury or property damage. We must establish a written policy that all incidents will be investigated. 2.2
Investigation Procedure Control access to the scene, people milling around can destroy physical evidence or
information necessary for an accurate and complete investigation. Rope off or barricade the area or have someone stand guard. If possible, contain the hazard to prevent further damage or injury. Identify witnesses and victims. Have them write down their statements, reporting exactly what they saw and heard. Make sure all witnesses or injured persons understand this is a fact finding, not fault finding procedure . People involved in an incident may be injured and in pain, emotionally upset, or unhurt but defensive and uncooperative. They may fear being blamed for something. Be tactful but firm. They need to accurately report what they saw or heard [16]. 2.3
Gather Information
One of the most critical and complex parts of the investigation is the gathering of evidence. There are some basic rules that may help the process. Interviewing involved employees put the individual at ease – make sure they know the primary purpose of the interview is to prevent a recurrence of the incident and t hat it can only be done with their help. Avoid finger-pointing and applying blame. Treat people with tact and respect. Make them aware that they need to be thorough and truthful in their account of the incident and that you are not there to get anyone into trouble, only to find out what happened and why, so that it
won‘t happen again. Be aware that injured employees and witnesses to injuries may have some emotions involved that affect them. Especially if the incident was severe, there may be some trauma that occurs. Stress fact gathering. Let involved employees tell their story completely. Wait 14
until they have finished their version of events before interrupting or clarifying what was said. Then go over what they stated with them, to assure that you have their account of the story accurately and that you understand what they meant, not just what they said. Do not make assumptions or state opinions during this process. If other people have said something different from what was stated in this interview, ask leading questions to discover more information, but do not contradict what was stated in either interview. Conduct the interviews at the scene, if possible. This may help people to explain and may help the interviewer understand what happened. Make the interviews as private as possible, so that other employees cannot take any offense or contradict what is said. Witnesses may be interviewed at a later time, if privacy is at issue. Ask any necessary questions to determine what happened, what was done, and how it was done. Try to avoid asking WHY questions that may make people defensive. Close the interview on a positive note. Discuss the actions taken, or that will be taken if you know them. That will reaffirm the purpose of the interview. [16] 2.4
Determine the root cause/system failure
Many times it is easy to determine what the work element is that directly caused the incident. It could have been a flying chip, a spill on the floor, or lifting a load that was too heavy. However, discovering the system failure that allowed the deficient work element to occur is sometimes more difficult. This system failure is also known as the root cause. To make it easier to determine, root causes (in general) can be placed into six different categories. [15] Materials
Machine/Equipment
-Defective Raw Materials.
-Incorrect selection of tool or equipment.
-Wrong Material for the Job.
-Poor Tool Maintenance.
-Not Enough Raw Materials.
-Poor Tool Placement. -Defective equipment of tool.
Environment
Man
-Orderly workplace.
-No or Poor Management Involvement.
-Job Design or Layout of Work.
-Inattention to Task.
-Surfaces poorly maintained.
-Task Hazardous not Guarded Properly.
-Physical Demands of the Task.
-Other (Horseplay, inattention, etc.) -Stress Demands
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Methods
Management Systems
-No Or Poor Procedures.
-Training or Educational Lacking.
-Practice
does
not
mesh
with
written
-Poor Employee Involvement.
procedures.
-Poor Recognition of Hazards.
-Poor Communication.
-Previously Identified Hazardous Were Not Eliminated.
2.5
Documents and Findings
A well conducted investigation identifies the work element(s) that caused the incident and helps to eliminate the root cause(s). After the investigation is completed, the investigator then begins to document the incident and their findings. The incident documentation should contain specific elements. When the incident happened, date and time may be crucial because of work load or shift change. Who or what was affected or hurt by the incident, if an employee was involved, or a piece of equipment damaged, be specific about which piece of equipment and the extent of damage or injury. Where it happened, again, specific details may be critical to the investigation analysis or trends that may be present. What object, if any, caused the incident. What work element was deficient and most directly caused the incident. If there was a specific condition (i.e. lifting, twisting, spills, poor maintenance, falling object, defective equipment, lack of procedure, poor lighting, etc.). What system failure (or root cause), if any, was evident that needs to be corrected that will prevent a recurrence (i.e. lack of a maintenance schedule, lack of training, lack of procedures, etc.). [16] 2.6
Follow Up and Analyze
Once the documentation phase is complete, corrective actions should be implemented. Employees in the work area should be notified of any equipment, procedures or additional training that has resulted from the investigation process. These corrective actions should be followed up to assure they are effective, and that employees are following any new processes. If more than one incident has occurred that may be related, management should review these incidents and look for similarities that may need to be addressed. Individual incidents and near misses may show one or two items that need addressing, however when taken all together, there may be a greater issue that can address the overall problem. Frequently the answer to individual incidents is as simple as wearing/using protective equipment/guards or proper lifting procedures. But sometimes a manager needs to take a step back and look at a 16
group of incidents that may be less obviously related. A lifting/lowering training program, or hand protection awareness program, a written procedure for locking out all types of machinery prior to servicing, or a preventive maintenance schedule for fork lift trucks, may address several needs at one time. [16]
3.0
Outcomes of an accident
An unplanned event that may (or may not) results in mishap such as personal injury or property damage is defined as an accident. Accidents are the result of the failure of people, equipment, materials, or even the environment to behave or react as expected [11]. All types of accident will have its own consequences or outcomes. Without doubt, accidents will always lead to the negative outcomes such as injury or even fatality. But at the same time, accidents do bring several positive aspects such as investigation will be made and more attention will be given by various parties to help to prevent recurrence of the same accident. Accidents will lead to both minor and major negative impacts. Examples such as failure
of machines or equipments that don‘t lead to any injuries, personal injury that requires little or no treatment and minor property damages are considered as the minor impacts. These consequences do require attention but it will not cause a permanent effect to everyone. While accidents that result in a fatality or in a permanent total, permanent partial, temporary total (lost-time) disability as well as serious property damages are some of the examples of major negative outcomes. These are the serious consequences that may lead to various issues such as life time physical or mental disability, bankruptcy or even involvement in legal actions. The examples that have mentioned are all categorized as the direct consequences where the impacts can be seen almost immediately. Other than the direct consequences, accidents will lead to indirect consequences such as decreased employee moral that will affect the efficiency of the entire company, wastage of time to retain another person or lost of income due to temporary shutdown. Indirect consequences cannot be seen immediately after the accident, but it should be given plenty of attention and effort to overcome it so that it will not cause a permanent impact. Whenever an accident occurs, the company will investigate the accident according to the guidance as mentioned before. After identifying the causes, proper steps will be taken such as educating the employees and supervisors in a particular risk and to direct attention to 17
accident prevention within the work place as well as changing the previous safety programs and equipment design to a safer set of programs and design. These steps will not only improve the working environment, but it will also increase the productivity of the company. Besides that, there will also be improvement of operational and safety procedures as well as higher safety awareness level among the employees after the investigation. This will definitely lower down the chances or even better, prevent the similar or perhaps more disastrous accidents occur. Besides the company itself, government has always been playing an important role in reducing the possibilities of accidents from happening. Department of Occupational Safety and Health (DOSH) has been the main agency that has been contributing a significant amount in reducing the chances of accidents from happening. As an example for construction industries, proactive actions are required to overcome the safety issue in construction sector. Thus, DOSH has initiated and drawn out a comprehensive master Plan for Occupational Safety and Health in Construction Industry 2005-2010. This master plan focuses on six areas identified by the National Occupational Safety and Health Committee for Construction Industry. The six areas consist of Safety & Health Enforcement & Legislation, Training & Education, Promotions, Incentive & Disincentive, Standards as well as R&D and Technology [14]. These implementations enforced by authorities and governmental bodies must be fully supported by the other parties such as private sectors to minimize the accident rates at construction sites.
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4.0
Hierarchy of Control
Figure 4.1: Hierarchy of Control to be considered [9] The hierarchy of control has been commonly used as guidance in many cases to control risks or hazards. Hierarchy of control is a control program that consists of several strategies to approach the risk control processes. The hierarchy consists of five levels. Each level has a level of effectiveness that is related to the failure modes associated with the control measure and the relative effectiveness in reducing risk in that later. Figure 1 showed that as the level gets lower, the reliability and effectiveness decreases. The sequence of options in the hierarchy of control is the elimination which is the most effective, substitute, engineering, admin training and PPE (Personal Protective Equipment) which is the least effective. Each method has its own individual characteristic to be implemented in different situation [9]. There is no way to measure or specifically quantify the ability or effectiveness of each layer even after it is implemented, the important thing is to understand that concepts of each layer. Thus, it is crucial to select a suitable strategy and implement the best measure possible for the particular situation. The solutions need to be adopted from the top of the hierarchy before considering those lower down. The ideal strategy needs to reduce the risk or hazards as much as possible, in compliance with legal requirements and acceptability to the users as well as the workers. The most effective strategy in the hierarchy of control is the elimination process by removing the risk from the workplace while taking care not to introduce new hazards. One of the examples for the elimination process is removing risky electrical plant from the workplace, for the simple reason that once that hazard has been eliminated there is no 19
remaining risk. Existence of hazard will affect both severity and probability of the risk, thus risks can be reduced by eliminating the hazard completely. This is the best way because the risk is no longer present. It is the preferred way of controlling a risk and should be used whenever possible. This method is suitable in most of the industries such as process, services and workplaces. Unfortunately, this method does not suitable for all cases such as in a research environment or design purpose so other controls alternatives must be considered. [10] Substitution is a process to replace the activity, process or substance with a less hazardous material or process once the risk has been identified. As an example, beryllium is a highly toxic metal that is used in some high tech applications. Inhalation or skin contact with beryllium dust will be harmful, causing acute beryllium disease. While long term exposure will cause chronic beryllium disease. Thus, substituting beryllium with a less toxic material that has the similar properties with it in the process could reduce or eliminate the possibility of the disease, depending on the exact content of the substitute material. If the substitute material contains lesser amount of beryllium, then the risk is only reduced. If it does not contain any beryllium, then the risk will be eliminated. The goal obviously is to reduce the risk level, not trading one risk to another risk when substituting. Thus, before deciding to replace the previous material or process with another new material or process, carefully consider all the implications and potential risks of the new alternative. [10] Engineering controls are methods that are built into the design of a plant, process or equipments such as mechanical guards, interlocking systems and safe guarding devices like light curtains or fences, area scanners, safety mats, two-hand controls barriers, machine guarding, ventilation or insulation to either minimize or isolate the risk from employees. These systems are proactive in nature, acting automatically to prevent access to a hazard and therefore preventing injury. These systems are designed to act before a person can reach the
―hazardous zone‖ and be exposed to be hazard. The degree of reliability is based on the amount of risk reduction that is being required of the safeguarding device and the degree of risk present in the unguarded state [12]. As long as these machinery are placed correctly in the first place and properly designed to contain the hazards they are protecting, then nothing more is required. It is a very reliable way to control as long as the controls are designed, used and maintained properly. One of the engineering controls examples is to use guards on compression testing machines. [10]
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Admin controls in the hierarchy includes admin training, Standard Operating
Procedures (SOP‘s), safe working procedures e.g. hazardous energy control, etc., authorization and supervision. It establishes appropriate policies, procedures and work
practices to reduce an employee‘s exposure to risk. This can be provided by various parties such as manufacturer, by a third party or self-taught by the user or worker. While the SOP can be included in any kind of procedure in a workplace to reduce risk. Safe working procedures can be strongly influenced by the manufacturer through the information for use provided such as maintenance procedures. Besides that, authorization plays a main role in admin control. It is a procedure that an employer uses to authorize a worker to carry out a particular task. Lastly supervision is one of the most critical of the controls. Sound supervision can make all of the above work. But failure to properly supervise work can cause all of these measures to fail [10]. These control measures have many limitations because the risk itself is not actually removed or reduced. Administrative controls are not generally favored because they are difficult to implement, maintain and are not an effective way to reduce the exposure of risks. There are many methods of administrative control can be used such as job rotation to reduce exposure or boredom and training on risks to educate the employee on how to conduct their work safely helps to minimize the risk of exposure and is a critical element of any complete workplace health and safety program. Lastly, the least effective way in the hierarchy control is the PPE (Personal Protective Equipment). PPE includes items such as respirators, gloves, face shields, eye protection and foot wear to cover and protect an employee from contact or inhalation of the chemical or material. This should only be used as a last resort as it is the least reliable form of protection
and should never be the only method used because PPE may ―fail‖ (stop protecting the worker) with little or no warning [2]. The problem with PPE is hard to deal with. It is always the last resort because it is often incorrectly specified, poorly fitted, poorly maintained and is often improperly used. Besides that, if workers are not properly trained and adequately informed about the hazards they face and the reasons behind the use of PPE, they will not be aware about the danger and make a safer choices even though is to refuse to work. Thus, where PPE is provided, it should be made available free of charge, suitable for all individual and need to be kept, clean and regularly checked to make sure it is always in good condition.
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5.0
Case Study 1 (Local)
5.1
Introduction th
On the September 6 , 2006, a food manufacturing plant in Nilai, Negeri Sembilan, was raided by the authorities from the Health Ministry, Domestic Trade and Consumer Affairs Ministry, the police, Department of Islamic Development, Negeri Sembilan Immigration Department, State Religious Affairs Department, Nilai Municipal Council and Malaysian Muslim Consumers Association. The factory that later was found out to be Silver
Bird‘s factory, which produces the High 5 bread, was raided due to suspicions that the production plant was purportedly unhygienic, employing illegal workers and used cooking oil that had no halal certification [16].
Some reports go as far as saying that the factory‘s floor was dirty and that some of the workers were found working without gloves or aprons. Furthermore, it was reported that the factory was badly-lit and had poor air circulation and ventilation [17]. The articles and documents related to this incident can be found in Appendix A. The unacceptable condition in the factory can be illustrated in Figure 5.1, Figure 5.2, Figure 5.3 and Figure 5.4.
Figure 5.1: Improper handling of unwanted breads. (Source: http://muslimlifemalaysia.blogspot.com/2006/09/high-5-gets-low-marks-forhygiene-by.html [18]) 22
Figure 5.2: Some workers were also found working without gloves (Source: http://pjlighthouse.com/high-5-bread-factory-controversy/ [19])
Figure 5.3: The factory was found very messy and dirty (Source: http://pjlighthouse.com/high-5-bread-factory-controversy/ [19])
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Figure 5.4: Rundown and unhygienic equipments, machines (Source: http://pjlighthouse.com/high-5-bread-factory-controversy/ [19])
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5.2
Action Taken
Following the incident, the factory‘s management decided to make the decision to voluntarily cease plant operations at Nilai for two weeks and immediately started to take steps to control and rectify the issue. A week after the raid, Breadmaker Silver Bird Group Bhd group managing director Jackson Tan, which manufactures the High 5 brand, took reporters on a media tour of its Shah Alam plant. Tan said that the company adopts strict quality control measures. If the quality of the loaves of bread produced were found to questionable, it will never leave the plant to be sold or distributed to customers. He also further explained that since the incident, all the products under the High 5 brand were produced at the Shah Alam plant. He also further r eassured that remedial works at the Nilai bakery were under way, and the plant would be ready for inspection by the authorities at the end of the week, adding that the plant would pass the inspection with flying colours. Additionally, the plant in Shah Alam was extensively automated, which serves to minimize human contact for better hygiene and to maintain consistent quality control. All products manufactured from the Shah Alam plant had valid halal certificates from Jakim, which assures Malaysian consumers that all of the High 5 products distributed through wholesalers and retailers are of halal status. The oil which halal status is ambiguous is the ―Trennaktiv PR100‖ from Germany and consists of 100% vegetable oil. Making a proactive decision to remedy the situation, Tan said that they would temporarily replace the Trennaktiv PR100 vegetable oil with a locally sourced release agent. The releasing agent Trennaktiv PR100, which is imported from Germany, will be substituted with a locally sourced one called Tin Grease, which is a 100% vegetable-based oil certified halal by Jakim. 5.3
Issue Resolved
In October 2006, Jakim reissued a halal certification for the Nilai plant and production resumed. Referring to Appendix A, Figure A-4, the Chemistry Department of Petaling Jaya issued a statement saying that the alleged oil was collected for testing on th
September 7 , 2006. The results from the analysis on September 15
th
showed that the oil
contained no animal substances and any alcohol content.
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5.4
Damage
However, since the incident, messages spread via SMS and emails have claimed that the Nilai palnt had been using lard instead of vegetable oil. Besides that, photographs of the
conditions of the plant taken by ―unauthorized‖ parties were also widely circulated thr ough ough the web. This situation has lead l ead to serious reputational damage to the management and Sil ver Bird. The article (Refer to Figure 5.5) below reported the l osses of Silver Bird due to this incident.
Figure 5.5: Article that reported the losses of Silver Bird (Source: http://www.silverbird.com.my/whatpop.php?preid=pre254273 [20]) 26
5.5
Analysis
The company suffered serious reputational damage due to this incident. Overall, they handled the situation very well, by immediately closing down the plant and take immediate remedial action that was required by the authorities. Additionally, they were also proactive in making the decision to replace the allegedly non- halal oil used with a locally sourced release agent which was certified by Jakim. These actions were recommendable.
However, the company‘s claim that the quality control was strict proved to be unnecessary as it had already proven to be ineffective. Denying the reality of the situation is damaging. The company and its engineers should be able to take up the responsibility of the lack of quality and control and work towards improving it rather than pushing the buck away. The main issue of the plant actually lied in the cleanliness of the bakery, especially after photographs of the Nilai plant was widely circulated across the net, and not just the nonhalal ingredient. The quality control, supply chain management and the environmental, health
and safety department at the Nilai plant was needed to be taken into serious consideration. Engineers in the company should work to implement process control in the plant, and in this particular case, process control should have been practiced in health, safety and environment management. The hygiene issue is a serious issue that needs to be addressed. Unhygienic situations not only affect the product manufactured by the plant but can also cause adverse effects to its workers and staff who are working in the harsh environment, more so when this situation occurs in the food industry. Industrial hygiene is a major concern in the food industry. Everybody involved in the manufacturing process is responsible for ensuring that the food manufactured in the facility is free from any contamination and meets the hygiene, sanitation and safety aspects outlined in the Food Act 1983 and the t he Food Regulations 1985, which are developed and amended by the Food Safety and Quality Division (FSQD) of the Malaysian Ministry of Health (MoH).
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5.6
Recommendation
With the analysis performed, several recommendations are provided in this report based on theoretical approaches above. When the company suffered setbacks where their factory was alleged to be non hygienic, immediate remedial work to upkeep the compound was not performed. The company instead denied the true conditions of the factory compound which led to further company brand image damage. Next is where engineers need to perform responsible professional ethics to report a case when the OSH & E rules were not adhered to. Seen above in photographs obtained from the web, the factory compound was hazardous to work conduct. Proper personal protective equipment should be handed out to ensure work conduct is safe to the wellbeing of employees. Also, to ensure hygienic food products, factory employees should be provided training when handling products in factory. Furthermore, the handling of media is also fundamental to uphold the commercial value of the brand imaging. Since this effects majority of the public, the media should be kept informed on the status of the factory whilst the temporary shut down for clean up purposes. By distinguishing the importance of the media today to convey messages to the public, company public relation officer are to be tasked to project honest company integrity. 5.6.1
Process Control
Food hygiene is important to provide foods that are safe and suitable for consumption. Hygiene, sanitation and safety are important factors in manufacturing and preparing food. Safe food is food that does not cause harm to the consumers when it is prepared and/or eaten according to its intended use. Food hygiene practices should apply throughout the food supply chain from primary production to the final stage of consumption. Hence, engineers in the company should work to outline the personal hygiene, attire, equipment and working environment of the plant to ensure that key hygiene controls and conditions are set at each stage of production. The Codex General Principles of Food Hygiene and the Malaysian Standard MS 1514 on General Principles of Food Hygiene provides a firm foundation ensure the practice of food hygiene in the industry. Internationally recognised, these principles and the guidelines can be used collectively with other codes of hygienic practice to assure the safety of food produced. 28
In order to assure the quality of the food manufactured, the food industry should take necessary steps to comply with Good Manufacturing Practice (GMP) and Good Hygiene Practice (GHP). GMP is where the producers apply the combination of manufacturing and quality control procedures to ensure the products are consistently manufactured to their specifications. On the other hand, GHP concerns all practices regarding the conditions and measures necessary to ensure the safety and sustainability of food at all stages of the food chain. Listed below are a few guidelines for process control that can be practiced by engineers to assure food hygiene in plant productions [21]: 1. Engineers should ensure that the food production area be free of the presence of any potential harmful substances that might contaminate food. The key here is to reduce any possible chances of contact with hazards, for example, pesticides, chemicals etc., which may result in endangering the safety of the foods produced. Therefore, equipment and facilities should be located, designed and constructed to avoid any form of contamination as well as easy maintenance and cleaning. Overall, the layout of the plant should be designed in such a way as to reduce contamination and promote hygienic practices during production. One of the examples of accomplishing this is by providing adequate personnel hygiene facilities such as sinks and soap for frequent hand washing along with hand dryers.
2. Engineers should also develop process control in the operation of the plant to prevent any risks of food hazards at appropriate stages of the production. The implementation of the Hazard Analysis and Critical Control Point (HACCP) can help to control food hazards and assure food safety.
Some of the process control methods that can be implemented include: a. Controlling cooking time and temperature. This is done to prevent food spoilage and bacterial contamination. b. Controlling packaging methods and materials. This is done to ensure there is no physical and environmental contamination. c. Appropriate documentation and records for each control process. This is done to ensure that the operators can check the control processes at appropriate intervals to
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highlight any irregularities. These irregularities when spotted can then be referred to the engineer-in-charge for further remedial action.
3. Proper training and education on the knowledge of food hygiene principles appropriate to the level of operations performed should be provided to all employees of the plant, regardless of whether they have direct or indirect contact with the food. This way, operators will know how to handle the food appropriately. Engineers will also be able to judge potential risks and take appropriate preventive and corrective actions. They will also be able to effectively monitor the operations of the plant.
4. Engineers should also work towards providing an adequate and appropriate maintenance and cleaning program to deal with issues such as waste disposal and stor age as well as the sanitation systems of the plant. This will help to minimize contamination and ensure the highest level of hygiene in the plant.
5. Engineers need to outline a suitable working environment for all employees and ensure
that this clean environment is maintained in the plant‘s daily operations. For example, the personal hygiene of personnel in direct contact with the food manufacturing process should be verified. Sick or injured employees should not be allowed to enter any food handling area. These personnel also need to maintain a high level of personal cleanliness by wearing protective clothing such as a bouffant cap, face masks and appropriate footwear. Actions such as smoking, spitting and eating should not be allowed at the food handling area to prevent contamination.
6. Engineers should also ensure that process control methods are implemented during the transportation of the food products to prevent contamination due to dust, fumes or changes in temperature and humidity.
7. Engineers should also come up with a proper labelling system in line with the requirements outlined in the Food Regulation 1985 act. Products need to be labelled with lot identification and product information. If there are any issues related to the product, lot identification will make it easier for the lots affected to be identified and recalled if necessary.
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5.6.2
Equipment and machinery
In a plant, proper storage, maintenance of machinery and equipment as well as the purchase of new and the replacing of rundown equipment is very important. Proper storage of equipment and machinery used in a plant is crucial. If equipment and machinery are not returned to their designated places after use, this will lead to unnecessary accidents. For example, equipment such as screw drivers and sharp knives, if not returned to the tool box after use and left on the lying around can cause injuries when employees accidently come into direct contact with it while working. These surroundings are not conducive for the employees to work in. Maintenance on equipment and machinery in a plant is also crucial. Maintenance has been proven to increase the lifespan of the equipment, hence, leading to cost savings and smooth production runs. A rundown or unhygienic plant is the res ult of the company‘s inability to consistently provide maintenance for the smooth running of the plant. As an engineer, it is our responsibility to take into account the operating costs, including the cost of plant maintenance and upkeep of equipment and machinery. All these important calculations should be in place well before the plant begins production. For example, analysis has to be done on the life span of the operating equipment. By selecting equipment based on its price tag alone, without taking into account its life span and other important criteria, the company is only looking to induce more losses when the machine starts to give problems and in the worst case, break down. Run down equipment will only create bills and not meet production targets due to the incessant repairs needed to be done on the equipment. On a related note, in any industry, especially the food industry, rundown and unhygienic equipment will cause many problems and have an adverse impact on the health of the user. Therefore, it is very important to keep the equipment and plant clean, especially in a food manufacturing facility. Rundown and old machines provide a bad impression to the end user and consumer. This indirectly causes more losses as the consumer loses confidence in the quality of the food product. Hence, the proper selection of equipment based on the criteria specified is very important. The company should do proper research to select the proper equipment needed. Likewise, worn out equipment should also be replaced as necessary. The purchase of new 31
machinery should depend on the continuing economic viability of the plant. Other advantages of replacing old equipment also relates to building a good reputation in front of their customers. Also, new economics can be brought by the purchase of new technologically advanced equipment due to the increase of productivity, improved efficiency, less defects and better quality products. Of course, the size of equipment to be used in the plant will depend on the scale of operation as well as the degree of productivity and nature of t he end product. In the food industry, usually the equipment used is not meant specifically for the business using it. Sometimes, extra labour is required to perform extra tasks that to compensate. Therefore, it is crucial to understand the different capabilities of the machinery so that redundant labour, rework time and mechanical downtime can be reduced. When purchasing new machinery, it is important for the engineer-in-charge to select work equipment which is suitable for its intended use in respect of health and safety, specify clearly the health, safety and hygienic design requirements for the supplier to meet (including noise levels) and also check that the equipment supplied meets your specification and the supplier has met their legal duties [22]. Waste of overproduction, waste of waiting, waste of transport, waste of overprocessing, waste of inventory, waste of movement, and waste of defect and rework can be reduced by considering the 3Rs which are reduce, reuse and recycle. Equipment and containers (other than once-only use containers and packaging) coming into contact with food should be designed and constructed to ensure that, where necessary, they can be adequately cleaned, disinfected and maintained to avoid the contamination of food. Equipment and containers should be made of materials with no toxic effect in intended use. Where necessary, equipment should be durable and movable or capable of being disassembled to allow for maintenance, cleaning, disinfection, monitoring and, for example, to facilitate inspection for pests [23]. Another thing to consider is the calibration of equipment and preventive maintenance. It has been found that the measurement systems can cause up to 25% of the problems and defects in the production. Therefore, the calibration of equipment, operators checklist and also preventive maintenance are some of the process control methods that can be implemented to rectify this problem.
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Vendors that supply the source of raw materials are also important in the control process. They are actually accountable for a crucial part of the production development. The consumer will blame the manufacturer for a faulty product even if the problem actually originated from the vendor itself. Therefore, training suppliers and vendors to provide the materials of certain standards and quality is important to ensure that the manufacturing outcome will adhere to the highest possible superiority. 5.6.3
Ventilation
There are comments that the factory had poor air circulation and ventilation. Ventilation systems should be designed and constructed so that air does not flow from contaminated areas to clean areas and, where necessary, they can be adequately maintained and cleaned. As a designer or engineer of the plant, the ventilation system is a very important element to be considered especially in food industry. Specified quality of air (temperature, humidity) to control the possibility of contamination on food and quantity of fresh air supply is required for the comfort and safety of workers. The controlled of temperature and humidity of air might used to suppress the growth rate of some micro-organism in manufacturing as well as storage areas. Other than that, the air circulation is very important. The heat induced by the processes and people must be removed and sufficient fresh air should be provided. The figure below shows a general flow of air in food manufacturing.
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Figure 5.6: Standardised terminology for environmental air at different stages (Source: ―Guidelines on air handling in the food industry‖ by European Hygienic Engineering & Design Group (EHEDG) [24])
From the figure above, the recirculation of air is very important. Other than that, certain amount of leakage is taken into account. The fresh air supply should cover the leakage and
the amount of air to support people‘s need. Designing a proper ventilation system is not the end of the story. Providing the proper maintenance of ventilation systems is important to plant operations in three basic ways [25]. 1. First, it helps to ensure lower housekeeping costs by not pumping dirty air into the operating area being ventilated. 2. Second, it saves on energy cost because when air moves unobstructed by dirt and grimes the blowers and fans do not cycle as long or as often, and if motors and drives do not work as hard, less energy is consumed by the system. 3. Last, well maintained and cleaned ventilation systems impact product quality by limiting contaminants in the production area and improving employee productivity by providing clean work areas and fewer lost man-hours due to sickness. Overall, engineers need to work on supply chain management, whereby the design, planning,
execution, control and monitoring of the entire plant‘s activities need to be taken into serious 34
account. This means that from the infrastructure to how the food product is transported to the customers, all these aspects require the planning and supervision of the engineers to ensure a safe product lands in the hands of the customers. 5.7
Commercial Value vs Professional Conduct
In the face of situations where the plant activity is ceased due to health, safety and environmental issues, engineers face a great problem in answering to the commercial consideration and the code of professional conduct. By shutting down the plant, targets and schedules have to be pushed back while remedial action is taken to solve the problem. This will incur huge losses to the company due to the halt in production. Besides that, workers who rely on daily pay will suffer significantly, especially those involved in semi-professional and direct labour sectors. Furthermore, the ceasing of the operations might lead to unwanted media attention. This in turn might result in media turmoil where the whole case is blown out of proportion. The reputation of the company will suffer due to negative publicity; more so when the issues at hand involve the health and safety of its customers. Customer bases might be lost if the situation drags on pending investigation and has no near sign of resolution. In the worst case scenario, this might even lead to legal implications where clients sue the company due to the inability of the company to deliver the goods on time (contractual issues). However, morally, this is the right thing to do. Under the code of ethics, the engineer should cease operations of the plant while undergoing investigation to find out the root cause of the problem that led to the adverse impact in the first place. As in the case study conducted on the High 5 Nilai plant, the decision of the management to voluntarily shutdown the plant for two weeks to take remedial action following the raid by authorities proved to be a very responsible move. By taking full responsibility for their actions, they were able to show the public that they were placing the needs of the customers first before anything else. This reflects well with the consumers. After investigation, if the allegations are found to be false and there are no legal implications, the customers will eventually regain their t rust in the product. However, in most cases, the damage has already been done. But if the company continues to consistently produce quality products, loyal customers will in due course return.
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6.0
Case study 2 (International) Mining of uranium in Niger by Nuclear energy giant
6.1
Summary
Nuclear energy giant is attempting a new nuclear revolution. The company has activities in over 100 countries throughout the world and aggressively pushes nuclear energy in new markets. Its public relations teams have been working overtime to convince governments, investors and the general public - hungry for clean energy - that nuclear energy
is now a safe, clean, and ‘green‘ technology. The devastating effects caused by this alarming misconception are already being felt. Generating nuclear energy requires f uel that is acquired through the destructive and deadly activity of uranium mining. Uranium mining can have catastrophic effects on nearby communities and the environment for thousands of years to come. There are few places where these harmful effects are felt more distinctly than Niger, Africa. A landlocked-Saharan country in West Africa, Niger has the lowest human development index on the planet. Arid desert, scarce arable land and intense poverty are hugely problematic - unemployment, minimal education, illiteracy, poor infrastructure and political instability are rife. However, Niger is rich in mineral resources - like uranium. Nuclear energy giant established its mining efforts in northern Niger 40 years ago, creating what should have been an economic rescue for a depressed nation. Yet, nuclear energy
giant‘s operations have been largely destructive. There are great clouds of dust, caused by detonations and drilling in the mines; mountains of industrial waste and sludge sit in huge piles, exposed to the open air; and the shifting of millions of tones of earth and rock could corrupt the groundwater source, which is quickly disappearing due to industrial overuse. Nuclear energy giant ‘s negligent mismanagement of the extraction process can cause radioactive substances to be released into the air, seep into the groundwater and contaminate the soil around the mining towns of Arlit and Akokan, all of which permanently damages the environmental ecosystem and can create a multitude of health problems for the local population. Exposure to radioactivity can cause respiratory problems, birth defects, leukemia and cancer, to name just a few health impacts. Disease and poor health abound in this region, and death rates linked to respiratory problems are twice that of the rest of the country. Yet nuclear energy giant has failed to take responsibility for any impacts. In fact, its companycontrolled hospitals have been accused of misdiagnosing cases of cancer as HIV. It claims there has never been a case of cancer attributable to mining in 40 years —what it doesn‘t say 36
is that the local hospitals do not staff any occupational doctors, making it impossible for someone to be diagnosed with a work-related illness. The governmental agency in place to
monitor or control nuclear energy giant‘s actions is understaffed and underfunded. For years, NGOs and international agencies have attempted to test and assess the dangerous levels of radiation that Niger is being exposed to. A comprehensive, independent assessment of the uranium mining impacts has never taken place. The people of Arlit and Akokan continue to be surrounded by poisoned air, contaminated soil and polluted water. With each day that passes, Nigeriens are exposed to radiation, illness and poverty – while nuclear energy giant makes billions from their natural resources. The Nigerien people deserve to live in a safe, clean and healthy environment, and to share in the profits from the exploitation of their land. Nuclear energy giant, with its attempt to create a nuclear renaissance, brings to these communities the threat of losing the most basic elements necessary for life - poisoning their air, water and earth. This shows that nuclear power gambles with our lives, health and environment from the very beginning of the nuclear chain - mining for uranium. Dangerous and dirty nuclear power has no role in our sustainable energy future. This calls for an energy revolution based on sustainable, cheap and safe renewable energies and energy efficiency.
Figure 6.1: Location of Arlit in Niger
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6.2
Introduction
Nuclear energy giant - whose majority shareholder is the French government and its local subsidiaries have been mining uranium in Niger for over 40 years. In 1968, a holding company and the first mine, SOMAIR, were created. Excavation began at SOMAIR in 1971. The open-pit mine, which varies from 50 to 70 meters deep, is located seven kilometers northwest of the mining town of Arlit. A second nuclear energy giant holding company and mine, COMINAK, were created in 1974. Production at COMINAK, located a few kilometers from the town of Akokan, commenced in 1978. Unlike SOMAIR, COMINAK is an underground mine. With a depth of 250 meters and over 250 kilometers of galleries, COMINAK is the largest underground mine in the world. Since the beginning of production, SOMAIR and COMINAK have excavated over 52 million tons of ore, from which over 100,000 tons of uranium has been extracted. On average, the mines produce over 3,000 tons
of uranium and net €200 million in sales each year. A third mine, Imouraren, is planned to start production in 2013 and is projected to be the largest uranium mine in Africa and the second largest in the world, with an annual production capacity of 5,000 tonnes of uranium.
Figure 6.2: Location of Arlit and Akokan in Niger
Nuclear energy giant is one of the world‘s largest nuclear energy companies. Headquartered in Paris, it is the only company in the world involved in all parts of the nuclear energy chain: uranium mining, chemistry, enrichment, fuel production, engineering, nuclear 38
propulsion, reactors, reprocessing and decommissioning, as well as several other sub-sectors. This expansion outside of Europe is caused in part by disappointments in its desired nuclear revival in western countries, such as delays and cost overruns in the construction of new reactors in Finland and France; nuclear energy giant is now focusing its energies on selling reactors and services in other parts of the world. The company even considers selling older and cheaper reactors to countries that are new to nuclear power, even though safety standards in western countries would not allow these old designs to be built .
Furthermore, nuclear energy giant is aggressively exploring uranium mining possibilities in a range of other African and Asian countries.
France‘s uranium mining activities started during the race for uranium shortly after World War II. Domestic uranium resources were already being mined, but in the 1960s new public awareness of the dangers of nuclear power and the harmful effects of uranium mining, in combination with rising costs and decreasing resources, forced France to further explore its colonies. A devastating activity like uranium mining is much easier and cheaper in poor, underdeveloped countries: no bureaucratic red tape (thanks to the political connections of colonial times); hardly any interference by health and environment watchdogs; and remote
locations where activities happen ‗under the radar‘. As one commentator stated about the nuclear boom, ―Getting a mine going in Texas takes two book shelves full of authorizations… In Niger you give a shovel to a guy on $2 a day and you‘re mining uranium.‖Before nuclear energy giant began prospecting for uranium in Niger, this area of West Africa, known as the Agadez region, was home to many nomadic tribes and cultures, predominately the Tuareg and Peulh. The Tuareg, estimated at 1.5 mi llion, are a tribe without a country: they have wandered the deserts of the Sahara since the 7th century, across the borders of present-day nation states. Both the French colonists and the modern-day governments that have followed have continued to marginalize the Tuareg and dismiss their claims to land rights and autonomy. The Tuareg repeatedly lose the land and resources they need to survive. A lack of clean water and fertile soil, in particular, threatens to destroy these nomadic herders. Angry and desperate, a Tuareg rebellion arose two decades ago, causing instability and security problems in the region, which have continued on and off for many years despite negotiations.
In order to facilitate the creation of a workforce in northern Niger‘s uranium belt, nuclear energy giant created the towns of Arlit and Akokan to house its 2,000 plus employees in the 39
middle of the barren Sahara. A two-day journey through the desert from the capitol Niamey (800 kilometers), this region of northern Niger is extremely desolate and remote. After 40 years of existence, the two towns, which are only a few kilometers apart, make up an urban area with a population of approximately 80,000 inhabitants. According to nuclear energy giant, nearly all the inhabitants are in some way connected to the nuclear energy giant mines: workers, their families (the average household has eight children), as well as the social systems and businesses that support local life. Town officials and a majority of the 2,400 miners and their families have company-maintained family homes with nice roads, running water, electricity, schools, nuclear energy giant-run hospitals, and a sports complex. However,
there is also ‗another‘ district - a shanty town of dusty dirt roads littered with garbage around a collection of haphazard huts built out of mud, corrugated iron, scrap metal and plastic sheets.
Figure 6.3: Cominak underground uranium mine in Akokan
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6.2.1
Uranium mining
Uranium is a naturally occurring resource. Uranium and its natural decay products are
both radioactive and toxic. While uranium is buried underground, the Earth‘s layers protect populations and the environment from its dangerous radiation. However, when the earth around uranium ore is disturbed, as is the case during mining excavation, the waste rock and tailings emit high concentrations of radon into the air, particularly when left exposed in the open air. The wind can cause radioactive dust from the mine to travel great distances around the radius of the disturbance. The mining disturbance, which happens deep within the Earth‘s layers, can also affect the groundwater, as radioactive material can contaminate drinking water supplies. Because of the long lifetime of these contaminants, hazardous impacts from uranium mining can be expected to last tens of thousands of years after mining operation has stopped. Exposure to radioactivity has been linked to genetic mutations, birth defects, cancer, leukemia and disorders of the reproductive, immune, cardiovascular and endocrine systems38. Internal contamination39 with radioactive materials often results in significant radiation exposure because the substances can stay trapped in the body for long periods of time and continue to emit radiation. Inhalation and ingestion of alpha-emitting40 particles is especially dangerous. The toxic effects of contaminants (including non-radioactive) also have serious health impacts, such as kidney and liver diseases, hypotension, etc. The dose from external exposure to radiation for local population around uranium mines is limited when mine materials do not spread. The typical dose rate close to uranium ore containing 0.1% uranium is about 5 microSieverts an hour, between 25 and 50 times more than normal background radiation. The dose rate is further elevated close to waste rocks and tailings. This mainly poses a risk to miners, who possibly spend a lot of time close to the ore, waste rocks and tailings. Note that this risk is in addition to the dose from exposure caused by internal contamination.
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Figure 6.4: How uranium is mined 6.2.2
Contamination of water
One of the harmful effects of uranium mining in Niger is its impact on water resources. Millions of liters of water are used daily in the mining operations, particularly in the leaching process to separate the uranium from the ore. The water is pumped from a groundwater table the Tarat aquifer - which is 150 meters deep. This is a fossil aquifer, meaning the water is not easily renewed: it will take millions of years for it to fill up again. Consequently, the water use in the mines and the mining towns causes a long- term depletion of the region‘s water resources. In 40 years of operation, a total of 270 billion liters of water have been used in Arlit and Akokan. Based on an old preliminary study from 1968, nuclear energy giant claims that this represents about 20% of the Tarat aquifer. About 35% of the water is said to be used for industrial use, while the other 65% is for drinking water production. Though nuclear energy giant claims the use of water has declined in the last decade, there was an increase in water use in the SOMAIR mine in the past years. When asked for an explanation, nuclear energy giant said that more water is used in the new ore leaching process. Also, the water use is proportional to the increase in production: the more uranium produced, the more water used. A hydro geological study from 2004 establishes the significance of the water use in the
mines. ―In the section of the CK [COMINAK] mine, the water has been completely drained and its level has dropped to the wall of Tarat [aquifer] (decrease of 150 meters); this has sometimes led to an inability to operate the water wells dug near the mine, namely Comi_10, Comi_11 and Arli_987. The SOMAIR open pit mine and the COMINAK underground mine 42
cut through the Tarat aquifer. Radioactive materials previously caught and immobilized in the ore are disturbed by the mining operations. The aquifer is opened up to the contaminants, which can spread throughout the water table. At those places the groundwater is removed
from the mines in order to mine the ore. The removed ‗industrial‘ water becomes contaminated by the uranium and other radio nuclides and can no longer be used as drinking water, which decreases the supply of clean, potable water. The decreasing water supply also has huge social and economic impacts, and particularly threatens nomadic herders. The emptying of aquifers increases the rate of desertification, the drastic decline of land into an arid and dry state. Desertification is caused by overgrazing, over-drafting of groundwater and diversion of water from rivers for human consumption and industrial use.
The Earth‘s layers protect people and the environment from naturally occurring radiation buried deep underground. However, mining operations cause radioactive materials and chemicals in the ore to be more readily mobilized, which increases the risk of groundwater contamination. When the earth, rocks and groundwater are exposed to air, chemical and physical processes can change, which can result in an increased transfer of certain chemicals. Water contamination was discovered by L’Institut de Radioprotection et de Sûreté Nucléaire (IRSN) in 2004 in local wells around the Niger uranium mines. Analyses of
water distributed by nuclear energy giant in Arlit in the period from 2003 to 2005 showed total alpha activity of between 10 and 100 times above the WHO guidance value. The strong alpha activity was due to high concentrations of uranium. Following these reports, nuclear energy giant closed several of the identified wells, but has never admitted this was due to uranium in the water. However, internal nuclear energy giant documents make clear that SOMAIR had known for several years about the uranium levels in the drinking water they supply. The uranium concentration in the sample from the Imouraren area (the new mine that
has not been operational) was 4 μg/l (micrograms per liter) and the tota l alpha concentration was 0.1 Bq/l (Becquerel per liter). Both values are within World Health Organization (WHO) recommended limits. In contrast, the total alpha activity concentration in four of the five samples from the Arlit region was up to six times higher than the WHO recommendation for further checks of 0.5 Bq/litre66. In four of the five water samples from the Arlit region, the uranium concentration was above the WHO recommended limit for drinking water of 15
μg/litre. High uranium and total alpha concentrations have been measured by nuclear energy giant in some of the wells for drinking water over the past years. In January 2010, a few water wells near a uranium mine in Brazil were closed because of raised levels of alpha 43
activity, even though the levels of total alpha activity were lower than in the Niger water samples. Nuclear energy giant has so far not closed the contaminated wells in Arlit. The historical data from the wells in the Arlit region that were closed in 2005 indicate a gradual increase in uranium concentration over the last 20 years, which point to the influence of the mining operation. The analysis reveals that some of the water samples contain dissolved radioactive gas, radon-222 (20 Bq/l to 30 Bq/l). The potential radiation dose from radon dissolved in the water for people who could drink it can be very significant. Therefore, these preliminary measurements indicate that it is vital that the presence of radon-222 in water is monitored. This is currently not done by nuclear energy giant. A broad chemical analysis was performed on the water samples, showing significantly increased levels of metals and chemicals like sulphates, nitrates, etc. For a number of chemicals, the concentrations exceed the values recommended by the WHO. This is the case, for example, for nitrates (50 mg/l),
molybdenum (70 μg/l), and selenium (10 μg/l). Many of the chemicals found, such as nitrites, molybdenum and tungsten, are not monitored by nuclear energy giant, even though the industrial activities of SOMAIR and COMINAK utilize large quantities of chemical products. Whether the increased presence of these substances in the drinking water at Arlit and Akokan is caused by industrial pollution, domestic pollution or natural causes, needs further study. NUCLEAR ENERGY GIANT has been supplying water to the towns of Arlit and Akokan for over 30 years. The people of Arlit and Akokan presume the water is clean. Still they are exposed to health risks by drinking water containing high levels of uranium and other contaminants.
6.2.3
Radioactivity in the air
The activities of uranium mining cause the spread of radioactive materials in the air, both by the diffusion of radioactive dust and the release of radon gas. In cases where the local population does not drink local water or eat local food, radon (Rn-222) gas is the leading cause of exposure to radiation from mining operations. Inhalation is the dominant route of exposure. The total exposure depends on the amount of radon that is released from the minin g operations and the distance from the mine. Even though the physical half-life of radon is relatively short (3.8 days), this radioactive gas can cover dozens or even hundreds of kilometers before it totally decays. Radon is an emitter of alpha particles, and its decay results in the creation of short half-life heavy metals (polonium-214 and polonium-218) which also emit alpha particles. Although the radioactivity of radon lasts only 38 days, the 44
half-life of some of its decay products is longer: 138.5 days for polonium-210 and 22.3 years for lead-210. These elements will pose a radioactive risk for many years to come. Inhalation of radon gas and its decay products leads to irradiation of the respiratory passages. In the vicinity of the uranium extraction zones, significant quantities of radon are emitted into the atmosphere. This can lead to an accumulation of lead-210 and polonium-210 on soil and vegetation surfaces. This increases the risk of internal contamination of the local population via ingestion of contaminated foodstuffs. Indeed, polonium-210 and lead-210 are among the most radiotoxic of these radio nuclides by ingestion. It is clear that the dispersion of radon around uranium mines leaves the inhabitants of the region exposed to serious and potentially fatal health risks. The increased incidence of lung cancer among uranium miners has been known for decades. Recent epidemiological studies have moreover confirmed that inhalation of radon, even in very low doses, increases the risk of lung cancer. Lung cancer, respiratory system illnesses, pulmonary hypertension, and a variety of non-malignant respiratory diseases — such as pneumonia — are the most common health risks linked to radon exposure. After inhalation, other radioactive isotopes can also enter the bloodstream and other organs and put them at risk for more diseases.
According to an environmental impact study done in 2000 by COMINAK, the death rates due to respiratory infection in the town of Arlit (16.19%) are twice that of the national average (8.54%). However, in public documents nuclear energy giant continues to minimize
and ignore the risks. ―Allergies (pulmonary, ophthalmologic), are some of the most common illnesses. They are found everywhere in the Sahara region and have long been recorded by the WHO as typical of desert areas. They are caused by sand irritating eyes and lungs and are
unrelated to mining activities,‖ its report of 2009 states. While it is true that respiratory ailments are common in desert regions, the COMINAK figures could indicate a pattern heightened by some other cause. Radon measurement done at the gendarmerie (police station) in Akokan showed a radon-222 concentration in the air three to seven times higher than normal levels in the area. The National Centre for Radioprotection is not able to measure radon and relies on information supplied by nuclear energy giant. The gendarmerie is less than 2.5 km from the entrance of the COMINAK mine. The raised levels of radon-222 in the air can be caused by open air storage of mining waste (including tailings) or the atmospheric emissions from the underground mine. Nuclear energy giant has been aware of raised levels of radon-222 at the gendarmerie, as can be found in nuclear energy giant‘s figures from the COMINAK 2008 environmental report, but has not acted on it. This report acknowledges that 45
the added annual dose received by the population at the gendarmerie of Akokan is 1.36 mSv, higher than the annual allowable dose for members of the public (1mSv). About 90% of this dose is due to radon emissions. A network of air-monitoring equipment was installed in the region in the past for measurement of radiation, radioactive dust and radon gas. When asked
what would be done if increased levels of radiation were measured, nuclear energy giant‘s Sustainable Development Director Moussa Souley seemed to think that high readings would
indicate a problem with the machinery, and not a true risk. Nuclear energy giant‘s 2009 report claims that ―Inspections are carried out by agents of the Mining Department and the National Centre for Radiological Protection. The CNRP conducts periodic on-site inspections
and issues inspection reports.‖. When asked about CNRP inspection of radon impacts, Hamadou Kando, inspector and chief of technical services at CNRP answered: ―For the time being, we, competent authority, are not able to measure [it]. We do not have the equipment to
measure radon. But, as I‘ve said, we plan to acquire two detectors for reading potential alpha energy in the budget for 2010.‖ By 2011, Kando hopes they will ha ve all the equipment, as well as a staff of three physicists that he can train to conduct the necessary tests. Despite the best efforts by the CNRP, however, they are currently unable to monitor all safety risks to the public around the mines. When the CNRP was asked if it was felt that nuclear energy giant
was hiding things, Kando responded, ―We have virtually no such impression. We work with many technicians for radiation protection. They know what radiation protection is. We have confidence. It is true that we make great efforts to have independent means of control. But for
now, we really trust… I do not see why a scientist will begin to turn facts. True, it could happen.‖ More detailed information on radon emission data from the mines, which has not been provided so far by nuclear energy giant despite repetitive requests, is essential in order to be able to estimate the radiation impact on the population. Fine (dust) fractions showed an increased radioactivity concentration reaching two or three times higher than the coarse fraction. Increased levels of uranium and decay products in small particles that easily spread as dust would point at increased risks of inhalation or ingestion. The CNRP warns that radioactive materials in water used to wet the roads can accumulate on the road surface reaching unacceptable levels in the long term.
46
6.2.4
Spreading of radioactive soil
At various locations around the mine, five soil samples were taken, mainly in the villages. One sample was taken in a zone a few meters from an air vent from the underground mine. Another sample, collected in a garden in Akokan where materials had been stored on the ground for years (collecting dust), showed a radiation level around 50% above the background level when measuring close to the surface. The other three soil samples were taken in order to establish a baseline characterization: soil close to the gendarmerie at Akokan, garden soil from Akokan, and soil from the road from Akokan to Arlit. The samples were analyzed by CRIIRAD using gamma spectrometry. The concentration of uranium and other radioactive materials in a soil sample collected near the underground mine was found to be about 100 times higher than natural levels in the region, and higher than the international exemption limits. The sample from close to a COMINAK outtake vent was taken at a location where the radiation levels were about seven times higher than normal background levels (1.44 microSv/hr). Gamma spectrometric analysis showed that the levels of uranium238 and its decay products (thorium-234, radium-226, lead-210), were about 100 times higher than normal levels in the region (activity concentrations 6,000-7,000 Bq/kg). This is higher than the international exemption limits. It is important to note that the fraction of small particles (dust, smaller than 63 micrometers) contains even higher concentrations of uranium and decay products, up to 26,500 Bq/kg. This radioactive dust can pose serious risks in case of inhalation or ingestion. In view of the location where the sample was collected, it can be assumed the radioactive material was brought up from the subsoil when the air vent was excavated. This confirms that with their activities the mining companies leave behind solid radioactive matter in the environment, within reach of the local population. Two samples of undisturbed soil indicate an excess of lead-210 in comparison to radium-226, especially in the fine (dust) fraction. This is typical of the top layer of soils, as a result of the deposition of lead-210, a decay product from radon-222 present in the atmosphere. Radon emitted from the mining operations can bring about an abnormal accumulation of lead-210 and polonium-210 on the surface of soil and vegetation. This signals the need to check vegetation for contamination. The results of these samples demonstrate that radioactive materials with sometimes levels of radio nuclides above international exemption limits are found in publicly accessible areas and pose a direct risk to the local population, especially through inhalation or ingestion.
47
6.2.5
Dumping of radioactive sludge
In the process of separating uranium from the ore, large volumes of radioactive sludge are left over – the tailings. Due to the vast quantities of rock that are manipulated, there are literally mountains of industrial waste, containing 85% of the original radioactivity of the ore. Due to the long half-lives of some of the radioactive elements, tailings remain radioactive for hundreds of thousands of years. Worldwide, the uranium mining industry has not found a solution for long term storage of these wastes. The release of toxic elements and the amount of radiation exposure around uranium mines largely depends on the waste management practices. In the short term, the storage of tailings poses a significant health risk to the workers and local population, because of the dispersion of radon gas and radioactive dust. This risk is multiplied when the tailings are stored in the open air without any protective layers. Radon and dust can be carried by the wind and affect the population in a wide area around the mine. Thirty-five million tones of tailings, accumulated over the past forty years of operation, are stored in open air. These tailings, containing 85% of the original radioactivity of the ore, will remain radioactive for hundreds of thousands of year. Nuclear energy giant representatives try to justify the ongoing bad practice by referring to low standards at the start of the operation 40 years ago. In the nuclear energy giant mines in Niger, the tailings have been and are still dumped in the open air, forming a mountain of radioactive elements and chemicals. A total of 35 million tones of tailings have been accumulating over the past 40 years in the mines of SOMAIR and COMINAK. Note that the production of uranium in the same period was 104,000 tones – for each kilogram of uranium produced, 335 kilograms of tailings were left behind. Nuclear energy giant knows that the current tailings storage is far below international best practice standards. The company representatives justify the bad practice by referring to different standards at the start of operation 40 years ago, while simultaneously playing down the risk of the used methods. Nuclear energy giant claims the crust that forms on top of the tailings after the sludge has dried prevents radioactive materials from escaping, but it offers no supporting data to confirm this. It has been known for many years that long-term coverage of waste rock and tailings can reduce the spread of radon, one of the main routes of radiation exposure for people living around a mine. The radon dispersion from tailings stored in the open air is higher than dispersion from tailings that were covered with a protective layer. Nuclear energy giant has ignored these risks and so far continues to dump the tailings in large piles in the open air. There is insufficient control of radon dispersion around the tailings. As illustrated previously, the CNRP in Niamey, the 48
national regulator, is unable to carry out radon measurements, meaning there is no independent control [31].
Figure 6.5: Collapsed Dam caused Leaking of Effluents 6.3
Course of action taken
The government that is supposed to be monitoring and regulating the nuclear energy giant are incapable of doing so alas they are unable to stop the nuclear energy giant from continuing the operations of the mines although it has clearly been proven that the operations do not adhere to the stringent standards set by the WHO and IAEA. A hint of corruption is also in the air as is the norm in almost all African countries where the politicians and policy makers are being paid handsomely to turn a blind eye to what is happening to the people of their own country. All the remedial actions taken by the nuclear energy giant have been mentioned above but it barely even scratches the surface of what actually has to be done. The regulatory body of the African country that is suppose to monitor and regulate the actions of
the nuclear energy giant‘s activity in the country are instead believing every word and 49
agreeing with every action that the nuclear energy giant says or do. In reality, the nuclear energy giant is self regulating and self monitoring itself and in doing so the nuclear energy giant will only do it to an extent that would not hurt its profit margin. Rules and regulations concerning HSE (health, safety and environment) that are being followed by the nuclear
energy giant are 40 years outdated and would not be approved by WHO or IAEA if today‘s modern and stringent standards were to used. The government body that is supposed to be
making the new rules and monitoring the safety standards just don‘t have enough knowledge, resources and manpower to do their jobs properly thus letting the nuclear energy giants to set their own rules and regulations which again would only benefit them .
6.3.1
Radioactive sludge leaked onto environment
Since December 11th, more than 200,000 liters of radioactive sludge from three cracked waste pools has leaked into the environment at the SOMAIR uranium mine in Niger,
operated by nuclear energy giant. ―This new leakage shows that the bad practices at the nuclear energy giant uranium mines in Niger continue to threaten the health and safety of
people and the environment‖, said Rianne Teule, energy campaigner for Greenpeace Africa. ―In contrast to nuclear energy giant‘s statements claiming their operations comply with international health, safety and environmental standards, this new information shows that
nuclear energy giant has not sufficiently acted to protect the Nigerien population‖ (refer to figure 6.5) [32].
6.3.2
Nuclear energy giant monitors workers health in uranium mining regions
Nuclear energy giant announced on December 6 2011 the creation of OSRA (Health Observatory for the region of Agadez). One year after setting up the Health Observatory of Mounana, Gabon, the new Agadez facility marks a forward stride in the process initiated in 2007 by nuclear energy giant and its partners. Just like the Mounana observatory for the mines operated in Gabon, OSRA is to monitor the health of former workers exposed to uranium at the nuclear energy giant mines in Niger, as well as monitoring the health of the local population. It will be devoted to delivering transparent information to the Niger authorities, former employees and surrounding communities, with the results of health monitoring carried out around the mining sites operated by nuclear energy giant.
50
In Gabon, where more than 40 consultation sessions have been held since the Observatory started its work in October 2010, nearly 400 former workers of nuclear energy giant subsidiary COMUF have had a physical examination, a blood test and chest X-ray. The process continues with the examination of all workers identified and will be renewed every two years. The process will be exactly the same in Niger and for subsequent observatories set to be deployed around the other mining sites of the group. If cases of illness attributable to occupational factors are identified, the cost of the corresponding healthcare would be borne by nuclear energy giant in the same way as for French medical coverage [33].
6.4
Commercial consideration vs. professional conduct
In this case it is very clear as to whether commercial consideration or professional conduct has taken priority. It is very clear from the actions and data above that commercial consideration has taken precedence over professional conduct in this case. The managers, engineers and general staff that run the company demonstrate a lack of regard for the safety of the workers and the public in general. They are only concerned about the safety of themselves and their immediate families. This also show s that they don‘t practice
conscientiousness behavior in their daily life and don‘t uphold themselves to the high standards of moral that one has to adhere to when they are involved in the nuclear industry in order to maintain the health and safety of the workers and their families and also the minimize the hazardous effects of uranium mining on the environment. The code of ethics that is practiced by not only engineers but by those involved in the nuclear industry has clearly been disregarded for monetary gains. If this course of action by the nuclear energy giant were to continue it would leave a socio-economic system that would ultimately collapse when the uranium runs out as the model of running the mines currently being used is not sustainable and also leave the population of Nigeriens that worked in those uranium mines crippled with diseases caused by radiation for generations to come.
51
6.5
Recommendations
The air, water and soil, along with all buildings, roads and surfaces must be decontaminated. Radioactive scrap metal must be retrieved, and replaced with clean and safe alternatives. Actions must be taken to address the loss of land and resources for the nomadic populations, and ensure their way of life is not further threatened. An independent health care and monitoring system must be available for all, free of charge, and no one should be turned away. Screenings for cancer and other occupational diseases must be set up; any discoveries must be honestly diagnosed and swiftly treated. Further, in view of the anticipated expansion of the uranium mining sector in Niger, the government and the leaders of Niger must step in and ensure the environmental and health agencies that are in place are properly funded, educated, and equipped so that they can fairly - and independently - assess the local situation. The government must also ensure that the people of Niger, and not the politicians, are adequately comp ensated for the exploitation of their land‘s resources. The people of this region need to be treated with the dignity and the humanity that they deserve. The workers, their families, and the community as a whole have paid too high a price to supply France and the world uranium for nuclear energy. Nuclear energy giant must change its behaviors and practices in Niger and in other mining endeavors so that populations will be safeguarded from these problems.
7.0
Conclusion
To conclude the research conducted, the entire objective previously set based on the problem statement above is meet through thorough and meticulous research performed. Both literature and life case studies are reviewed in manner which correlates with the HSE code of conduct. Also as mentioned above, weighted inputs are research based on the fundamental statement of this report where the code of professional conduct is contrasted with commercial considerations. Therefore, the latter of this discussion promotes both since neither is not to be neglected in a life case study scenario. Certain tradeoffs are identified and thus engineer must have both in mind first to solve a case, if any. Since HSE implements stringent rules to be adhered to, it is best that this report is able to highlight its importance in promoting a safe and healthy work environment for all to benefit from ranging from work employees to product consumers.
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8.0
Appendix A
8.1
Article
Article #1
Figure A-1: First Article that reported the condition of t he factory for Case Study (Source: http://www.jeffooi.com/High_Five_MM060907.jpg.pdf [16])
53
Article #2
Figure A-2: Action taken by the plant (Source: http://www.silverbird.com.my/whatpop.php?preid=pre842957 [26])
54
Article #3
Figure A-3 The plant was proved Halal and legal (Source: http://www.silverbird.com.my/whatpop.php?preid=pre295960 [27])
55
8.2
Documents
Document #1
Figure A-4: Analysis Results from Department of Chemistry (Source: http://www.silverbird.com.my/whatpop.php?preid=pre858338 [28])
56
Document #2
Figure A-5: Letter from the plant to the customers
(Source: http://www.silverbird.com.my/whatpop.php?preid=pre826752 [29])
57
8.3
Certificates
Certificate #1
Figure A-6: Halal Certificate
(Source: http://www.silverbird.com.my/whatpop.php?preid=pre446442 [30])
58
8.4
Interview Session
8.41.
Food Industry HSE Interview Session, Interviewee- Anonymous, Safety and Health Officer
Us: Do you regard the food industry in Malaysia to be hygienic and with par with the MoH standards? Please give your opinion Int: It depends on the location, type of food produced and category in the industry. First there is factories that produce food, grocery stores that sells food, wet market that sell raw food or food outlet that sell you cooked food. Therefore it depends on which category you are exactly referring to. Us: What if it was a factory that produces food? Examples are biscuits, breads, etc? Int: The factories in Malaysia can be quoted to be at par with MoH standards with the HSE rules. There may be some isolated cases where these rules are breached but does not necessary relate to all. Us: What are the HSE standards in enforcing their rules? Int: There is a complete flow which is to be followed which is inspection, investigation, enforcement, notice, prosecution, penalties and work related deaths if any. Us: If a company is involved in the food industry process that is found to breach the stringent rules and regulation set by the MoH in regards to the HSE, what actions would be taken? Int: The first step is prosecution where punitive action is taken against the duty holder. A litigation officer with appropriate training is to administer the prosecution and an approval office is to approve the prosecution made. If the prosecution is successful, the court will decide what penalty to impose based on the severity of the incident. The normal penalties are imposing fines and severe cases are result to imprisonment due to health and safety offences.
Us: Are you aware of the Silver Bird‘s factory incident, which produces High 5 bread is raided due to complain for breaching several OSH & E rules? Int: Yes, in fact this was an eye opener to the public where such a high profile company can be charged in court for it ignorance towards the OSH& E rules. It shows the empowerment of these rules to ensure safety at work must be adhered to and food hygiene must be upkeep. Us: How would they prepare their company, clean up, media handling, implementation of rules, etc? 59
Their first response is media handling in admitting the truth, no point denying something with proof at hand. Next is to divert immediate attention in temporary shut down and cleanup of the factory in compliance with OSH&E rules. 8.4.2
Nuclear Industry HSE This interview was conducted with a DR.XXX who wishes to remain anonymous due to the sensitive nature of the questions being asked and his position the government.
Us: Do you regard nuclear energy as a source of green and clean energy? Please give your opinion. Int: It can be called clean energy in the sense that it does not pollute the environment with carbon dioxide and etc. while being produced but it is definitely not green. Why I am saying this is because the nuclear waste produced from creating nuclear energy is radioactive and harmful to humans so nuclear energy cannot be called a green source of energy. Us: What are the HSE standards for nuclear energy generation be it the fuel
procurement or the power plant operation and etc… in the nuclear energy chain? Int: The standards that are set are strictly regulated and are constantly being reviewed. You just have to take a look at the recent Fukushima disaster. Even though there were many fail-safe‘s in place to prevent such a disaster from happening it still happened. This is also one of the reasons why a lot of developed countries in the world are turning away from nuclear energy. The standards set are so high that if they were to abide by those standards, a lot of money and manpower would be needed which is not economically sound. Us: If a company that is involved in the process of nuclear power generation is found to have breached the stringent rules and regulation set by the WHO and IAEA in regards to HSE what are the actions that would be taken? Int: First of all the WHO or IAEA would send a delegation to inspect the breaches that have taken place with regards to HSE and then they would come up with a report that specifies the action that the company or country has to undertake in order to rectify the situation. If the said company or country still does not do
60
anything to rectify the HSE issue, probably their licenses would be revoked or in the worst case scenario they can be charged in an international court of law and have sanctions imposed on them. Us: Are you aware of the uranium mining of nuclear energy giant in Niger and what is
your opinion on the issue?(if he doesn‘t know about Niger, explain to him before asking his opinion) Int: I have heard of it but I am not really sure of the exact situation going on there. (After giving him a brief explanation).In that case I am definitely going to say that what they are doing there is wrong but you also have to look at the other side of the coin. If they did not go there and invest their money in the uranium mines
there would that country still be there today? I don‘t think so. Maybe there have been HSE mismanagements and maybe there have not been any, we cannot say for sure until a comprehensive study has been carried out but I certainly think that they deserve a chance to be able to take actions to improve the situation there because as like you mentioned earlier, since uranium mining is the only the
country‘s main source of economic income I am afraid without uranium mining the country will suffer and not the company. They can always mine uranium somewhere else. Us: Nuclear energy giant is one of the companies that are being considered to build the first ever nuclear power plant in Malaysia. Do you think they are going to be a suitable company for the project after knowing what they did in Niger? Int: Like I said earlier, I believe everyone deserves a second chance. If they were to build the nuclear power plant here I believe that they would not jeopardize their investment by following the strict rules and regulations that are set by the government and also IAEA. If you are going to invest billions of dollars in building something would you risk losing it all by not following a few rules and
standards? That‘s the argument I am trying to use here.
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8.5
Meeting Minutes
8.5.1
Meeting 1
Date:
[December 5 2011]
Time:
[4:00-5.30pm]
Location:
[COE BM-0-11]
Purpose:
[First meeting, to outline, open discussion on project and rough sketch on project heading]
Attendees/Invitees Name
Chin Jen Loong
Contact
[email protected]
Capacity
Meeting Host
Cheang Lai Ann
[email protected]
-
Teh Yee Ching
[email protected]
-
Sarah Chan
[email protected]
-
Wong Menn Yee
[email protected]
-
Mark Arvind
0132509432
-
Agenda
1. Primary focus is towards HSE, please read the question. 2. Preparation by individual for the meeting Items for Discussion
Introduction – Case study of scenario, understand root cause, elaborate situation Highlight necessary code of conduct of engineer, code of professional conduct pertaining to the case study Describe weight of professional conduct vs commercial consideration- how will the situation persist if either one is chosen Suggest methods to improve situation- give real scenario examples, Conclusion- choose the best decision based and conclude the advantages of the decision made
62
Meeting minutes Appendix- documents, newspaper cutting, anything related to the case study is to be compiled
Action Items Action Item
Date Added
Assigned To
Date Due
Create a Meeting Minutes Template
5/12/2011
Chin Jen Loong
7/12/2011
Preparation by individual for the meeting for the discussion above, require rough idea to proceed
5/12/2011
All members
7/12/2011
63
8.5.2
Meeting 2
Date:
[December 10 2011]
Time:
[2:00-3.30pm]
Location:
[COE BM-0-11]
Purpose:
[Outline required criteria pertaining to problem and research objective]
Attendees/Invitees Name
Chin Jen Loong
Contact
[email protected]
Capacity
Meeting Host
Cheang Lai Ann
[email protected]
-
Teh Yee Ching
[email protected]
-
Sarah Chan
[email protected]
-
Wong Menn Yee
[email protected]
-
Mark Arvind
0132509432
-
Agenda
1. Introduction- Problem and Research Objective Items for Discussion 1.0 HSE Management system (All of the elaboration can be searched online) 1.1. OSH & E Policy 1.2. Management Review 1.3. Planning 1.4. Corrective Action Implementation 1.5. Implementation and Operations
2.0 What is the aim of investigation?
Incident Investigation Purpose (why our case study is relevant to the research objective) Highlight some key facts and figures required of an investigation (ie: what, where, why)
3.0 Outcomes of an accident (try to squeeze in further elaboration)
Elaborate of the negative and positive aspects - ie: Negative- injury, death, damage, lost of productivity
64
Positive- prevent recurrence, change of procedure, prop an investigation
4.0 Hierarchical Control to be considered (elaboration on the inverted pyramid)
Action Items Action Item
Date Added
Assigned To
Date Due
Problem and Research Objective Elaboration, Compilation
10/12/2011
Chin, Ann, Mark, Menn
12/12/2011
Research and Material Compilation
10/12/2011
Teh, Sarah
12/12/2011
65
8.5.3
Meeting 3
Date:
[December 14, 2011]
Time:
[2:00-3.30pm]
Location:
[COE BM-0-11]
Purpose:
[Outline required criteria pertaining to case study motion]
Attendees/Invitees Name
Chin Jen Loong
Contact
Capacity
[email protected]
Meeting Host
Cheang Lai Ann
[email protected]
-
Teh Yee Ching
[email protected]
-
Sarah Chan
[email protected]
-
Wong Menn Yee
[email protected] m
-
Mark Arvind
0132509432
-
Agenda
1. Case Study Format. How to proceed? Which topics are relevant? Discussion Case study format 1.0 Data Interpretation
Where did the event occur? (maps, coordinates, name of places, etc) Describe what transpired there, (summarize the information f ound to provide an abstract idea) How did it happen? (use methodical approach) Who were involved? (victims and the company that,do not use company names but categorize them based on business type:i.e: Shell- oil and gas, Dell- network/IT provider, Toyota- carmaker etc., think of something) Was there any course of action taken? (nuclear waste management, cleanup, fog masks in semicond industry, etc) Any new rules introduced prior to the event? if yes, did it work? If no, please elaborate 66
2.0 Decision Making (based on data above)
Commercial value Vs professional conduct (correlate with HSE) Picture out what will persist if either one decision is undertaken (highlight what are might the pros and cons be) Include your recommendation based on the Malaysia HSE rules highlighted in the literature part (do this part only after the literature review is done) If the company has taken a course of action, how does it relate to Malaysia HSE rules? Try to find a relation if possible (do this part only after the literature review is done)
Action Items Action Item
Date Added
Assigned To
Date Due
Case study Elaboration, Compilation
14/12/2011
Teh, Sarah
16/12/2011
Research and Material Compilation
14/12/2011
Chin, Ann, Mark, Menn
16/12/2011
67
8.5.4
Meeting 4
Date:
[December 21 2011]
Time:
[2:00-3.30pm]
Location:
[COE BM-0-11]
Purpose:
[Outline required criteria pertaining to professional interview in industry]
Attendees/Invitees Name
Chin Jen Loong
Contact
Capacity
[email protected]
Meeting Host
Cheang Lai Ann
[email protected]
-
Teh Yee Ching
[email protected]
-
Sarah Chan
0195770377
-
Wong Menn Yee
[email protected] m
-
Mark Arvind
0132509432
-
Agenda
1. Professional interview questionnaire suggestion and compilation Discussion
Nuclear Interview Questions
Do you regard nuclear energy as a source of green and clean energy? Please give your opinion.
What are the HSE standards for nuclear energy generation be it the fuel procurement or
the power plant operation and etc… in the nuclear energy chain?
If a company that is involved in the process of nuclear power generation is found to have breached the stringent rules and regulation set by the WHO and IAEA in regards to HSE what are the actions that would be taken?
Are you aware of the uranium mining of Areva in Niger and what is your opinion on the
issue?(if he doesn‘t know about Niger, explain to him before asking his opinion) 68
Areva is one of the companies that are being considered to build the first ever nuclear power plant in Malaysia. Do you think they are going to be a suitable company for the project after knowing what they did in Niger?
Action Item Action Item
Date Added
Assigned To
Date Due
Interview questionnaire compilation
21/12/2011
Teh, Sarah
22/12/2011
Setting up meeting with respective person
22/12/2011
Chin, Ann
22/12/2011
Review and justification of answers gathered
22/12/2011
Mark, Menn
22/12/2011
69
9.0
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