NEBOSH IGC 28 October 2020 SCENARIO
You have a dual role as an experienced and respected Process Operator and a representative of workers at a large, high hazard site, run by an international chemical manufacturing organization.
The organization has a reputation for having a world-class health and safety culture, with many other industries using them as a benchmark. It is a legally compliant organization that sets clear objectives and checks that they are met. It employs and retains motivated workers who are aware of their clearly defined and documented responsibilities and want to continuously improve in their roles.
Absence and sickness rates are low. The organization listens to workers when they raise concerns and responds professionally to external customer complaints. The organization also takes pride in recording low accident and incident rates and investigating any near misses to learn lessons and prevent more serious outcomes. Across the organization, there are clear lines of internal and external communication. This allows effective resolution of complaints. The organization is fully insured even though the premium is high. The organization conducts frequent internal audits and is also externally audited.
The process you operate is running at a reduced production rate, due to a technical problem with a large storage tank containing a highly toxic product. You have an idea what the problem is, but knowing the limits of your authority, you feel the issue should be escalated to someone more senior. Local site managers, engineers, supervisors, and operators meet to discuss the situation. They conclude that the tank has an internal blockage, that would normally require a complete process shutdown to clear. However, the planned maintenance shutdown is 12-months away. They decide to seek advice from the corporate management team to explore whether there is a different solution that would resolve the blockage problem, but keep production going.
The local site and corporate management teams meet by video conference. The corporate management team includes a very experienced senior engineer with 25-years’ company service. This engineer has overseen process plant modifications, at many international sites, with zero lost-time incidents. They all agreed that modifications could safely be made to the tank, without the need to shut it down, and that the necessary resources would be made available for this work.
The senior engineer is sent to the site to advise on, and manage, the changes that are needed to the tank; and on the day of arrival presents a solution to you. You are unfamiliar with the technology to be used for the modification and your reaction is one of disbelief, and you politely ask if the engineer is serious. The engineer invites you to a meeting to conduct a systematic and detailed risk assessment of the tank modification task. The Health and Safety Adviser, worker representatives, and Plant Manager will also be at the meeting.
At the meeting, the engineer introduces the proposed tank modification and leads the risk assessment exercise. The risk assessment includes consideration of the highly toxic chemical, the release of which would be catastrophic for workers, as well as people in adjacent businesses, residential houses, and schools. The engineer confirms that this proposed modification method is a safe and widely used solution where the safety improvements are worth the cost. The risk assessment then continues with discussion and agreement on risk evaluation, existing control measures, and any additional control measures necessary. Some of these control measures include safe systems of work, a permit-to-work system, supplementary emergency arrangements, and suitable induction training for all contractors. Collectively, these precautions and control measures reduce high risk to low risk.
A summary of the risk assessment is circulated to all workers likely to be affected by the proposed modification. The full version of the risk assessment will be made available on request.
Prior to commencing the work, a permit-to-work is issued to the contractors carrying out the tank modification. The permit-to-work includes an explanation about the associated risk assessment and how the plant has been safely prepared for this non-routine modification. The contract workers accept the permit-to-work with the necessary precautions, including wearing of specified personal protective equipment. Precautions listed on the permit-to-work are also communicated to all
contractors and other plant workers who may be affected. The permit-to-work explains that precautions will be enforced, along with any other site rules, by active monitoring. This will be done while you carry out routine plant checks and simultaneously check on the progress of the modification.
To confirm safe working and clarify overall expectations, you, along with an independent site contact have been nominated to monitor and liaise with the contractors. The independent site contact will also actively monitor and check additional expectations, such as contractor site entry and exit control, resolution of any queries, and the supervision standard. You and the independent site contact will check to see whether the modification work is being controlled and is progressing as planned. This is consistent with the organization’s safe system of work based on the findings of the risk assessment and the method statement provided by the contractor, the aim is to complete the job safely without incident.
Findings from inspections form part of the overall health and safety performance review. The performance review enables an overall assessment of opportunities for continuous improvement within the site and reveals any need for change.
Task 1: Discussing moral reasons for managing health and safety
1 | Comment on the organization’s health and safety morals. | (10) |
Note: You should support your answer, where applicable, using relevant information from the scenario. |
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Task 2: Roles and responsibilities
2 | For a health and safety management system to work properly, you need to have clear roles and responsibilities. | |
Comment on the evidence from the scenario that would contribute to the effectiveness of the roles and responsibilities. | (10) |
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Task 3: Influencing health and safety culture
3 | Based on the scenario only, what are the indicators of health and safety culture in the organization? | (20) |
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Task 4: Why lessons should be learnt from incidents
4 | Other than a general improvement of health and safety, what specific reasons are there for this organization to learn lessons from incidents? | (10) |
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Task 5: Risk assessment
5 | The risk assessment for the proposed storage tank modification has been completed. | |
Based on the scenario only, comment on whether the risk assessment is ‘suitable and sufficient in the following areas | ||
(a) who might be affected. | (4) | |
(b) the precautions are reasonable, and the remaining risk is low. | (6) | |
Note: The HSE Document ‘Managing for Health and Safety’ (HSG65) states that a risk assessment must be ‘suitable and sufficient. |
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Task 6: Permit-to-work system
6 | The organization has an effective permit-to-work (PTW) system. | |
Why should a PTW be used to help manage this storage tank modification? | (10) | |
Note: You should support your answer, where applicable, using relevant information from the scenario. |
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Task 7: Managing contractors
7 | The contractors, who specialize in the tank modification method, are ready to start work having been issued with a permit-to-work. | |
Based on the scenario only, discuss how effectively the contractors will be managed by the organization during the modification. | (10) |
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Task 8: Health and safety performance (management) review
8 | The organization’s world-class reputation is partly due to carrying out an annual health and safety performance review. | |
What types of information should this review consider? | (20) | |
Note: You should support your answer, where applicable, using relevant information from the scenario. |
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