SHE Audit & Legislative Update Friday 27 February 2015

Weightmans LLP

Welcome and introductions

Dave Parr Head of Technical Services, British Safety Council Howard Dawes Environmental Consultant, British Safety Council Roni Kotecha Business Development Director, British Safety Council Chris Green Weightmans James Muller Weightmans

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Agenda: SHE Audit and Legislative Update Welcome and introductions Legislative Update and SHE trends Business benefits of SHE auditing ISO 14001 Environmental Standard Update ISO 45001 Update: Beyond OHSAS 18001 Best Practice SHE Auditing: Five Star Model Lunch and Networking

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British Safety Council An overview of British Safety Council’s policy and engagement work

The vision and work of the British Safety Council

• We are a charity with public benefit at the heart of everything we do

• We have been in existence for fifty six years • We have over 6,000 corporate members in UK, India and Middle East • Construction, manufacturing, energy generation and supply, transport are some of the areas where we have a strong membership presence • Our services include health, safety and environmental audit, advisory, training and qualifications • Our awards including the Sword of Honour, Globe of Honour and ISA

• We use the knowledge, expertise and views of our members to influence and shape health, safety and environmental management policy and law.

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British Safety Council’s manifesto

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Our Manifesto – 5 steps

1 2 3 4 5 7

Promote the importance of H&S Build understanding and capability

Commit to leadership and worker engagement Share knowledge and experience Campaign for sensible legislation, regulation and application

The Löfstedt review

https://www.britsafe.org/policy-and-opinion/lofstedt-reform-updates

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Our regulatory framework for health and safety in Great Britain

Health and Safety at Work Act 1974 (primary legislation) Health and safety regulations (secondary legislation) – 200 sets of regulations

Approved codes of practice (special legal status - what you need to do to comply with law) – 55 codes of practice Guidance in support of legislation – 1000+ sets of guidance

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Key legal and regulatory changes

1 2 3 4 5 10

Löftstedt update Fee for intervention

Temple review of HSE and commercialisation Sentencing proposals for health and safety offences CDM2015

Follow us @britsafe

Like us Facebook.com/britishsafetycouncil

Watch us Youtube.com/user/britishsafetycouncil

Legislative update and SHE trends

Chris Green / James Muller Weightmans

Business benefits of SHE auditing

What is an audit?

Final stages in the heath and safety management control cycle:

Audit and performance review

The structured process of collecting independent information on the efficiency, effectiveness and reliability of the total health and safety management system (including establishing corrective action plans) Health and Safety Executive

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Business benefits of auditing • Identification of areas for improvement / strengths / trends within the safety management system • Enables informed targeting of resources • Provides factual information for the continual improvement of risk control and reduction of loss (potential or actual) within the organisation

• Provides validation (accreditation if external) of effectiveness of SMS arrangements • Pro active method of demonstrating self regulation • Monitors legislative (and sector standard) compliance • Improves management understanding of safety management systems • Enhance workplace environment and employee wellbeing • Maintenance of a positive corporate image • Influence supply chain standards.

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Internal and external auditing Internal

External

• Operational knowledge

• Objective and independent verification

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Focus on key areas of risk

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Input factor into future planning

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Monitors legislative compliance

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Participative factor

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Mitigating factor (civil / statute).

• Certification / accreditation • Source of best practice benchmarking

• Continual improvement • Validation of progress and organisational practice • Mitigating factor (civil / statute)

• Enhanced reputational confidence.

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Benefits of Health and Safety Auditing Corporate Manslaughter and Corporate Homicide Act 2007 (and other Health and Safety Regulations) Areas for dispute (so essential to have demonstrable evidence)

Grossness of breach will be determined by (among other factors)

Compliance with law / standards / guidance (best practice) Safety Management System (effectiveness, suitability, etc) Organisational safety culture Role of Senior Management (leadership and commitment)

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ISO 14001: Environmental Standard Update

Where are we now? Worldwide certification – ISO Survey • 2011 267,457 • 2012 284,654 • 2013 301,647 +17,000 (up 5%)

Certification across 158 countries globally UK 6th in top 10 countries for growth up 996 certificates between 2012/13 UK 4th (behind Italy, China and Japan) for number certificates

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New structure ISO14001 1

Scope

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Normative references

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Terms & definitions

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Context of the Organisation • • • • •

4.1 Understanding the organisation & its context 4.2 Understanding the needs & expectations of interested parties 4.3 Determining the scope of the EMS 4.4 Environmental management system

5 Leadership • 5.1 Leadership & commitment • 5.2 Environmental Policy • 5.3 Organizational roles, responsibilities and authorities

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Clause 4. Context of the organisation • Determination of internal and external issues “relevant to its purpose” and which may influence the effectiveness of the EMS. (Clause 4.1) • External environmental conditions includes climate change adaptation, biodiversity and resource depletion, for example.

• Also includes external cultural, social, political, legal, regulatory, technological, economic, natural and competitive context • Understanding the needs and expectations of interested parties (Clause 4.2) • Determining the scope of the EMS. (Clause 4.3)

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Clause 5: Leadership Policy commitment broadened from prevention of pollution to include protection of the environment (Clause 5.2) Commitments may address: • Sustainable resource use / recycling • Local air and water quality • Climate change mitigation and adaptation • Protection of biodiversity and ecosystems

Give consideration of environmental performance in strategic planning Restriction on delegating authority for setting policy, assigning roles and responsibility, performance evaluation in management review (Clause 5.3)

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Clause 5: Leadership There are likely to be more areas where Top Management need to demonstrate their involvement and engagement with the environmental management system (Draft clause 5.1) such as: •

Ensuring integration of EMS requirements into the organisation’s business processes

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Promoting awareness

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Assuring the EMS achieves its intended results

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Supporting other relevant management roles to demonstrate their leadership

Top Management : “Person or group of persons who direct(s) and control(s) an organisation at the highest level” (Annex SL)

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New structure ISO14001 6

Planning

• 6.1 Actions to address risks associated with threats and opportunities -

6.1.1 General 6.1.2 Significant Environmental Aspects 6.1.3 Compliance Obligations 6.1.4 Risks Associated with threats and opportunities 6.1.5 Planning to take action

• 6.2 Environmental objectives & planning to achieve them - 6.2.1 Environmental objectives - 6.2.2 Planning actions to achieve environmental objectives

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New structure ISO14001 7

Support

• 7.1 Resources • 7.2 Competence • 7.3 Awareness • 7.4 Communication - 7.4.1 General - 7.4.2 Internal Communication - 7.4.3 External Communication

• 7.5 Documented information - 7.5.1 General - 7.5.2 Creating & updating - 7.5.3 Control of documented information

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New structure ISO 14001 8 Operation

• 8.1 Operational planning & control • 8.2 Emergency preparedness and response 9

Performance evaluation

• 9.1 Monitoring, measurement, analysis & evaluation - 9.1.1 General - 9.1.2 Evaluation of compliance • 9.2 Internal audit • 9.3 Management review 10

Improvement

• 10.1 Nonconformity & corrective action • 10.2 Continual improvement

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Clause 8: Operation 8.1 Operation planning and control • Control of outsourced services and supplied products need to be considered • Develop & specify requirements for procurement of goods and services as appropriate

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Clause 10: Improvement

Non-conformity and corrective action (10.1) - documented information on corrective actions, the result of the corrective action and review of the effective of these actions Continual improvement (10.2) - continually improve the adequacy, suitability and effectiveness of EMS to enhance environmental performance

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The next steps 2014 July: The Draft International Standard (DIS) is now available for public comment

2015 February: The Final Draft International Standard (FDIS).

Q3 – The International Standard is due to be published

2015 - 2018 The expected transition period is 3 years

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The next steps •

Get a copy of the DIS / revised standard and understand the impact it has upon your organisation and its environmental management system

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Contact your certification body and discuss whether they can help you transition to the requirements of the new standard

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Develop a transition plan with your certification body which will involve a GAP analysis to allow identification of the training / system development requirements to benefit your organisation for successful certification by the 2018 date.

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ISO 45001: Beyond OHSAS 18001 A new international standard for OH&S management systems

ISO 45001 • Natural progression from BS OHSAS 18001:2007 • Lobbying from various sources for an international SMS standard • Need to harmonise various OH&S standards (allowing for local regulatory requirements) and share good practice •

ILO key player in the development of ISO 45001

• Standardised global approach to benchmarking / improving health and safety

• Provide a framework for local regulatory compliance • ISO PC283 (development committee) established October 2013 • 50 countries represented by 83 delegates • BSC represented on HS/1 committee review group • Closely aligned to ISO 9001 and ISO 14001

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ISO 45001 • A new international standard for OH&S management systems

• Standard will be reflective of Annex SL (management system standard for ISO standards) • “New” concepts will be included as individual clauses; context of organisation, leadership, information management

• Preventive action clause within OHSAS 18001 will be dropped as considered integral to risk management requirements within ISO 45001 • Committee draft (CD 45001) - responses informed to PC 238 and CD 45001 was rejected. Re-draft in progress

• Final Draft International Standard (DIS) Q3 2015 / ISO 45001 Oct 2016 • BSC represented on HS/1 committee review group.

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Main changes A new High Level Structure (HLS) for all future ISO standards Annex SL (MSS) requirements • Scope • Normative references • Terms and definitions • Context of the organisation • Leadership • Planning

• Support • Operation • Performance evaluation • Improvement 38

Clause 5: Leadership There are likely to be more areas where Top Management need to demonstrate their involvement and engagement with the safety management system (Draft clause 5.1) such as: •

Ensuring integration of SMS requirements into the organisation’s business processes

•

Promoting awareness

•

Assuring the SMS achieves its intended results

•

Supporting other relevant management roles to demonstrate their leadership

Top Management : “Person or group of persons who direct(s) and control(s) an organisation at the highest level”

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ISO 45001 Latest Developments • PC 283 (WG1) meeting held in January • UK response to survey of key issues to feed into meeting (via OHSAS PG/HS1) • Inclusion of “OH&S risk” as a defined term (risks and opportunities) • Inclusion of the word “acts” in the definition of “hazard”

• Should ISO 45001 include the term “incident” as a defined term? • Should ISO 45001 include the term “compliance obligations”? • Should the term “workplace” be used as a defined term?

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British Safety Council SHE auditing Five Star Audit Model Health and Safety / Environmental / Integrated

Five Star (best practice) audit process Features/benefits: • Comprehensive, independent and objective assessment of SMS • Quantifiable evaluation against best practice technique • Internationally recognised audit • Clarifies strengths and identifies areas for improvement

• Detailed recommendations and action planning • Supports continual improvement • Can be used as supportive evidence during tender submissions • Genuine examination of maturity of SMS arrangements • Generates structured route toward excellence • Pre-requisite for prestigious Sword of Honour award 42

Five Star Occupational Health and Safety Audit A comprehensive audit to benchmark health and safety management performance against the latest best practice.

• Improves safety performance, workforce morale and wellbeing • Potentially reduced rates of accidents, injuries and ill health

• Mitigates litigation costs • Enhances reputation.

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We have the British Safety Council as our external partner for all these years primarily because of the quality of their auditors. They are very knowledgeable guys with a wide range of industrial experience and they came up with very good ideas. Andy McLean Site Health and Safety Coordinator, Hargreaves Industrial Services

www.britsafe.org/fsa

Five Star audit specification Development factors • Mapping against recognised SMS models (HSG65 revised, ILO 2001, OHSAS 18001,18002,18004, OSHA, etc.) • Based upon PLAN – DO – CHECK – ACT management model • Five domain sections which include core elements and specific sub elements • Number of elements (66) with emphasis on certain subject areas and key aspects of safety management • Leadership and Continual Improvement a common theme throughout audit: Safety Management Indicators (SMI) • SMI carry cumulative scoring which can lead to extra%.

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Five Star Audit Specification 2013 Safety management indicators

Leadership Running throughout five sections via elements or question sets Cumulative scoring may increase overall grading by 0.5% 2% Continual Improvement

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Five Star Audit: Specification Model

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Five Star Audit Specification Model Sectional headings Section 5

Section 1

Evaluation and Review

Policy and Organisation

500 points

750 points

Section 4

Section 2

Performance Measurement

Strategy and Planning

1125 points

1125 points Section 3

Implementation and Operation 1500 points 47

Five Star Audits Scoring and grading The Five Star Audit is an audit conducted using the British Safety Council’s numerical safety grading system.​ The overall audit grading is as follows:

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Five Star Audit Specification Model Section 1: Policy and organisation • 1.01 Safety policy statement • 1.02 SMS scope, nature and scale (control arrangements) • 1.03 Leadership and commitment • 1.04 Roles and responsibilities

• 1.05 Document management • 1.06 Consultation and communication • 1.07 Competence and capability • 1.08 Occupational health and wellbeing • 1.09 Change management

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Five Star Audit Specification Model Section 2: Strategy and planning • 2.01 Occupational health and safety objectives • 2.02 Occupational Health and safety plan • 2.03 Benchmarking and initial review • 2.04 Provision of resources

• 2.05 Occupational health and wellbeing • 2.06 Consultation and communication • 2.07 Leadership and commitment • 2.08 Risk management and control • 2.09 Risk profiling • 2.10 Change management 50

Five Star Audit Specification Model Section 2: Strategy and planning • 2.11 Legislative compliance • 2.12 Emergency incident planning • 2.13 Procurement and design (including contractor approval) • 2.14 Competence and capability

• 2.15 Sustainable health and safety attitudes and behavior

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Five Star Audit Specification Model Section 3: Implementation and operation • 3.01 Risk management and assessment • 3.02 SMS controls (general) • 3.03 Work equipment • 3.04 Personal protective equipment

• 3.05 Manual handling • 3.06 Workstation (DSE) ergonomics • 3.07 Housekeeping, storage and welfare facilities • 3.08 Traffic management • 3.09 SMS controls (specific) • 3.10 Permit to work systems 52

Five Star Audit Specification Model Section 3: Implementation and operation • 3.11 Safe isolation • 3.12 Working at height • 3.13 Lifting equipment • 3.14 Pressure systems

• 3.15 Hazardous substances • 3.16 Electrical safety • 3.17 Management of noise • 3.18 Management of vibration • 3.19 Safe working/operating procedures • 3.20 Competence and capability 53

Five Star Audit Specification Model Section 3: Implementation and operation • 3.21 Sustaining occupational health and safety attitudes and behaviors • 3.22 Emergency incident management • 3.23 Fire safety management • 3.24 Management of other potential emergency occurrences/incidents.

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Five Star Audit Specification Model Section 4: Performance measurement • 4.01 Occupational health and safety plan (monitoring) • 4.02 Occupational health and safety objectives (monitoring) • 4.03 Active measurement • 4.04 Inspections and audits

• 4.05 Risk assessment review • 4.06 Legal and other requirements compliance monitoring • 4.07 Health surveillance • 4.08 Contractor and supplier monitoring • 4.09 Documentation management • 4.10 Reactive measurement 55

Five Star Audit Specification Model Section 4: Performance measurement • 4.11 Accident, incident, near miss reporting and investigation systems • 4.12 Ill Health and absenteeism monitoring • 4.13 Loss/damage analysis

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Five Star Audit Specification Model Section 5: Evaluation and review • 5.01 Management review and reporting • 5.02 Provision of resources • 5.03 Continual improvement • 5.04 Legislative compliance and other requirements

• 5.05 Occupational health and safety programmes and planning

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Audit delivery process

A Review of safety management documentation B Interview with managers and staff C Site tour and inspection

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Five Star Audits Audit report Upon completion of the audit process, a detailed report is prepared by the auditor and will be issued within 28 days. The report content will include: • Executive summary (including graphical performance indicators) • Overall star grading and sectional scoring • Observations • Recommendations for Improvement • Action planning tables.​

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Integrated SHE Five Star Audit An integrated best practice audit evolving from our two existing Five Star products.

It will audit against both OH&S and environmental best practice by looking at the common areas and also the specifics of each subject.

Why have we developed this model? • There are many synergies and alignment within the two disciplines • Many companies now have (or are moving toward) integrated management systems

• In many organisations, the same person oversees the two disciplines (SHE Advisor / Manager) • We are looking to offer a cost effective way of measuring performance against best practice.

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Audit progression

When you’re working to do the right thing, we help you do it the right way. Document title