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5. (a) (i) How might the external health and safety audit benefit PPL?
UNIT DN1 / DI1 Level 6 Diploma for Occupational Health and Safety Management Professionals
PRACTICE PAPER 1 OF 2
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SCENARIO
Plastic Pressings Ltd (PPL)
A year ago, factory workers had been working extra hours and rushing to complete orders. The high production demands agreed by the production manager left workers feeling stressed, and they were not taking enough breaks. In addition, PPL had not been able to employ enough supervisors to monitor activities due to budgetary constraints. During this time, there were two minor accidents in the factory; nobody was badly injured, but the managing director (MD) was shocked at how easily the accidents had happened. Soon afterwards, the MD decided to attend a directors’ health and safety awareness course. They also employed a full-time health and safety officer (HSO) in the hope of achieving zero injuries at PPL. The HSO reports directly to the MD.
Shortly after starting their role, the HSO recommended that more factory workers were employed to deal with the increasing demand. This was actioned, but the HSO was unable to obtain a budget from the finance director (FD) to employ additional supervisors. The HSO asked the existing supervisors to make sure that factory workers took their rest breaks. An area was created where all workers could take a break. The HSO also made sure that all factory workers were provided with suitable equipment to protect their hands and their hearing in the noisy factory, as this equipment had not been replaced for some time.
The MD asked the HSO to book all of the other directors and senior managers onto the same directors’ health and safety awareness course that the MD had attended. However, due to busy schedules, the HSO found it difficult to get an agreement from any of them about when they might be available to attend.
Since arriving at PPL, the HSO has inherited an electronic document control system, supplemented by a manual system. They believe that all workers have been trained on the procedures contained in these systems.
Due to the previous accidents in the factory, the HSO also develops safe working instructions for the factory workers. The instructions are simple and easy to follow, and include diagrams and photographs. The HSO uploaded these instructions onto the health and safety section of PPL’s intranet. Senior managers have not had time to read these instructions and they were not involved in the development of them; they tend to leave the day-to-day operations to the factory supervisors.
PPL is now planning to trade in markets in other countries. They have developed a new range of products for these markets. All of the departmental managers attend the senior management team (SMT) meetings every week, where every aspect of the business should be discussed. The MD is often travelling, talking to new clients and suppliers, so the FD usually leads these meetings. In a recent meeting, the FD emphasised that developing this new range of products is extremely important to PPL’s finances. The FD privately thinks that the MD’s additional expenditure on health and safety is unnecessary. Therefore, when the FD chairs the SMT meetings, the HSO’s reports and findings are not discussed. The HSO uploads the health and safety reports and findings to the intranet, and informs all workers where to access them. The FD would rather use PPL’s budget and time towards making future projects successful and obtaining business in new markets.
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Production improvements The existing machinery in the factory was purchased from reputable manufacturers, even though the FD challenged the cost. To make production of the new range more cost-efficient, the production manager is experimenting with reconfiguring some of these existing machines. This will involve having four separate machines being connected together. As the factory floor is well laid out and kept clean, it was easy to find a suitable area where the connected machinery can be set up.
A four-person team will be connecting the machinery. The team will include the production manager; an engineer; a setter (a person who configures and operates the moulding machine); and an operator. The operator will assist the setter, and clean the machine and surrounding areas during the connection task. Most of the team have been chosen because of their experience and knowledge. The operator, who has been with PPL for 6 months, was selected due to their enthusiasm to be involved and to learn new skills.
The machines involved in the project are:
A large injection moulding machine that forms the product.
A robot arm that is fixed across the top of the moulding machine and removes the product.
A metal plate where the robot arm places the product; the plate moves backwards and forwards at high speed on a motorised bed.
A conveyor belt to bring the product to the main production line.
The area in the factory where the machinery is located is not fenced off. The HSO asks the production manager to make sure that warning signs and ‘Do Not Enter’ signs are displayed on retractable barriers around the project area. The HSO also asks them to display information regarding the project on the nearby noticeboard. The production manager displays the warning signage later that day, but forgets to add the information to the noticeboard. All PPL workers have been told during their toolbox talks that the area is restricted to authorised personnel only, and only a select team are allowed to enter. Out of curiosity, some of the senior managers have entered the area without the production manager’s knowledge.
The production manager has created a risk assessment for the use of the machinery, and filed it away in their office. Also filed there are the instruction manuals of the machines that list any relevant hazards in using them.
Most mornings, the project team gather to discuss what will be tested that day, what the expectations are, and any foreseeable risks with the work. The whole project is only expected to last around two months, and no written records of these discussions are made. Once the day’s plan has been agreed, the production manager and engineer usually leave to focus on other tasks around the factory. They return occasionally throughout the day to discuss progress. Due to a lack of training, the operator usually has a list of questions for the engineer and production manager, including issues to resolve.
The accident One month into the project, the four machines are operating together as a single unit. Following the usual morning briefing, the operator decides to clean up some debris around the caged area that guards the metal plate adjacent to the moulding machine.
A worker from another department approaches the operator to talk about the project and how it is progressing. The operator is happy to discuss the project because they are proud to be involved in it. They point out some of the features on the machines. The operator suggests to the worker that they will get a better look at how the metal plate moves from inside the cage. The worker agrees, pushing the warning signage and retractable barriers to the side, and crawls under the cage.
The entire machine is running at this point as the setter is testing it. The worker raises their head to get a better look at the surface of the metal plate. Just as they do so, the metal plate returns from its cycle and strikes them forcefully on the side of the head.
The worker is knocked unconscious and falls to the floor. The operator sees this happen and reaches for the emergency stop button on the side of the cage. This stop button, however, is not connected because the machines are in test mode. The operator shouts to the setter, but due to all of the background noise in the factory, the setter does not hear them. The operator then rushes around the moulding machine to tell the setter what has happened. The setter presses the main power isolating switch, and both workers retrieve the unconscious worker from inside the cage, where they lay injured. All the operator can say to the setter is, “I don’t know what happened”.
The injured worker is taken to hospital by ambulance and checked for concussion. They are allowed to leave the hospital the same day and are sent home to rest. The doctor advises them to take five days off work to recover. The only physical evidence of the impact is a visible bruise to the side of the worker’s head.
The MD was absent when the accident happened. They arrive at PPL three hours later and are informed of the accident during a conversation with the senior managers. The MD asks the HSO to conduct a thorough investigation into the accident immediately. The HSO tries to find the project’s risk assessment in the risk assessment folder. After searching through electronic and manual folders, they ask the production manager where it can be found. The production manager responds by saying “it’s in my office, where it should be”. The HSO follows the production manager to their office to look for the risk assessment. After 30 minutes of searching they finally find it in a pile of paperwork on the floor. The HSO notes that some sections have not been filled in correctly, and a date and signature are missing.
The eventual report of the investigation concludes that management factors at PPL were the root cause of the accident. The HSO makes reasonable recommendations based on the findings.
Legal claim Two and a half years later, the MD receives a telephone call from a legal organisation acting on behalf of the injured worker. They ask if there was an investigation into the accident. The MD confirms that there was an investigation. Believing it is in PPL’s best interests, they send an unencrypted copy of the report to the organisation. Soon after this, PPL receive a notice that a legal claim for compensation is being brought against them by the worker.
The MD suggests to the Board that a sum of money should be set aside to pay the worker, and the MD seeks the advice of the HSO. The HSO immediately says that the report should not have been sent and not to settle out of court. They also recommend that PPL’s insurance organisation is informed straight away and that all of the paperwork relating to the accident is retrieved. However, some of the paperwork has been misplaced and poorly filed. The HSO discovers that some important documents from two years ago are difficult to read or missing completely. There is no electronic record of them either. Also, filed risk assessments are incomplete.
Health and safety audit After dealing with the claim, the MD asks the HSO to conduct a full health and safety audit of the organisation. Due to continuing high demands in production, the HSO has difficulty scheduling in time to conduct the audit interviews with the senior managers. The HSO has conducted audits in previous workplaces, but not on this scale.
The HSO’s concerns, combined with PPL’s production demands mean that many of the senior managers feel that they will be unable to provide a great deal of time for the audit. Some senior managers suggest that perhaps their supervisors can answer the HSO’s questions. As they are reluctant to upset any senior managers, the HSO agrees to this suggestion. Unfortunately, this information does not reach the supervisors. Although hesitant to approach them, the HSO is left to explain to each supervisor, at length, what the purpose of the audit is, and its importance.
The supervisors begin to get suspicious that this is a plan to reduce their roles and responsibilities even further. Previously, the MD had instructed the HSO to take on the role of conducting the factory inspections, which was formerly the responsibility of the supervisors. Since then, the supervisors have declined to be involved in any health and safety inspections, and their results. The HSO begins to worry that they might not be able to conduct the audit successfully. After speaking to the MD about the challenges, the MD decides to bring in an external auditor to conduct the audit.
1
(a) What are the negative indicators of health and safety culture at PPL? Note: You should support your answer, where applicable, using relevant information from the scenario.
(b) How could the health and safety culture at PPL be improved? (i) Explain why the survey results for opinion 1 are worrying Note: You should support your answer, where applicable, using relevant information from the scenario
(20)
(10)
2
Assume that the International Labour Organisation’s (ILO’s) Occupational Safety and Health Convention 1981 (No.155) and associated Recommendation R164 – Occupational Safety and Health Recommendation, 1981 (No.164) are used as Regulations in PPL’s country of operation. This includes the actions required at the level of the undertaking under Article 16 and Recommendation 10 respectively.
(a) Comment on how effective PPL is, as the employer, in implementing these actions. Note: You should support your answer, where applicable, using relevant information from the scenario.
(b) Workers have responsibilities under Recommendation 16 (part a) of the International Labour Organisation’s (ILO’s) – Occupational Safety and Health Recommendation, 1981 (No. 164). How have the workers failed to meet their responsibilities? Note: You should support your answer, where applicable, using relevant information from the scenario.
(15)
3
Outline financial arguments which you could use to convince the Finance Director (FD) to spend money on health and safety.
(10)
4
Internal influences can affect health and safety within an organisation.
How are senior management adversely affecting health and safety at PPL?
(8)
Note: Your answer must be based on the scenario only.
5
(a) (i) How might the external health and safety audit benefit PPL? Note: You should support your answer, where applicable, using relevant information from the scenario.
(ii) How can senior managers at PPL assist with the auditing programme? Note: You should support your answer, where applicable, using relevant information from the scenario.
(iii) One of the key purposes of health and safety audits is continual improvement. How could PPL improve the document control system?Note: Your answer must be based on the scenario only.
(12)
(6)
(8)
(b) Shortly after the audit, PPL are carrying out a health and safety management performance review. What inputs to the health and safety management performance review should PPL prioritise? Note: Your answer must be based on the scenario only.
(6)
End of assessment
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