Risk Management Procedure

OBJECTIVE

To define the process of the implementation of Risk Management (RM) in the workplace through Risk Assessment (RA) to identify hazards and environmental aspects, assess and prioritise EHS risk (WSH risks and environmental impacts) arising from organization’s activities/ processes, products and services.  Guidelines on selection of effective additional control measures are provided to minimise the probability and/or impact of undesirable EHS consequences.

SCOPE

Applies to all routine and non-routine activities/processes, products and services of all persons having access to the organization(including contractors and visitors) including non-production related activities, e.g. administration.

RESPONSIBILITY

Management shall:

Ensure RA is conducted on EHS risks with any activity in the workplace.

Take all reasonably practicable steps to eliminate any foreseeable risk to any person / environment

Support the implementation of risk control measures recommended by the RM or RA Teams.

Require the contractor or supplier where work has been assigned or awarded to, to conduct RA.

Designate, appoint or engage a competent person leading a team of personnel (including contractors) associated with the activities/products/services to conduct risk assessments;

Review and if necessary, revise the RA at least once a year from RA approval date, or when there are:

a)Accidents, near misses or dangerous occurrences as a result of exposure to a hazard.  These may or may not result in injury.

b)Introduction of new raw materials, significant change in processes, facilities, work practices or procedures, or change in workplace condition and site layout or ;

c)New information on EHS risks is made known; 

Provide training for relevant personnel in risk management;

Ensure that Risk Register is available and maintained at the workplace.

Ensure that Risk Register is readily available for review by designated persons at the workplace and by regulatory agencies

Managers

The Manager who oversee the area, function or activity where EHS risk exists shall:

Ensure that RA is carried out and risk control measures are implemented before any new work is carried out in the Manager’s area;

Approve the RA conducted for his/her area.  The Manager shall also ensure that the risk level is not rated “High Risk” when approving work to be carried out.

Ensure that the risk control measures are implemented without delay.

Ensure that, where applicable, all operations have established Safe Work Procedures (SWP)

Ensure all persons exposed to the risks are informed of:

• Nature of risks
• Any measures or SWP implemented; and
• The means to minimise or eliminate the risks.
• Ensure that the effectiveness of the risk control measures is monitored.
• Revise the RA if the risk control is inadequate and ineffective after implementation.
• Maintain RA documentation with measures and SWP implemented

The Manager may authorise other persons to execute the duties mentioned above but remains accountable for them. 

RM / RA Leaders

The RM Leaders shall assist the Management as the focal point for co-ordinating RM within the workplace. The RM or RAs Leader shall:

Provide regular updates to Management, preferably monthly (such as but not limited to Monthly Highlight Reports, etc) but no less than once a year, regarding appropriate risk control measures implemented to reduce or eliminate risks identified.

Facilitate / Conduct RAs of newly identified processes or tasks with their team through weekly pre-start work / toolbox meetings so as to ensure there is participation amongst rank-and-file members of the team.

Facilitate / Conduct continuous review of existing RAs with their team through weekly pre-start work / toolbox meetings so as to ensure there is participation amongst rank-and-file members of the team.

Assist Management to ensure that the Risk Register is prepared and maintained.

Employees

Employees are to adhere to the measures stipulated in the RAs. 

DEFINITION

Environmental aspects - element of an organisation’s activities, products and services that can interact with the environment;

Environmental impacts - Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation’s activities, products or service.

Indirect Environmental Aspects and Impacts - Aspects and impacts from activities, products, and service of suppliers and contractors, which company cannot control but can influence.

HOD - Head of Department

Accident – An incident which has given rise to injury, ill health or fatality. 

Incident – Work-related event(s) in which an injury or ill health (regardless of severity) or fatality occurred, or could have occurred. 

Emergency – An incident resulting in death/serious injury to people, damage to property and environment, shutdown of all operations.

Hazard – Source, situation or act with a potential for harm in terms of human injury or ill health, damage to property, damage to the environment, or a combination of these.

Risk - The combination of the likelihood of an occurrence of a hazardous event or exposure(s) and the severity of injury, ill health or environmental impact that can be caused by the event or exposure(s). 

Risk Assessment (RA) – Process of evaluating the risk(s) arising from a hazard(s) and/or environmental aspects, taking into account the adequacy of any existing controls, and deciding whether or not the risk(s) is acceptable.

Risk Management – Identification, assessment and prioritisation of EHS risks followed by the application of control measures to minimise the probability and/or impact of undesirable EHS consequences.

Risk owner – The HOD or Contractor who manage activities that contain hazards and result in risks in the organisation.

Risk Register – Collection of RAs within the organisation.

Acceptable risk - Risk that has been reduced to a level that can be tolerated by the organisation having regard to its legal obligations and it’s own policy.

Interested parties – person or organisation (external and internal) that can affect, be affected, or perceive itself to be affected by a decision or activity made by the organisation.    

Normal / Routine - Day-to-day operations and routine functions whereby processes/activities are working in the intended manners.

EHS – Environmental, Occupational Health & Safety

PROCEDURE

PREPARATION 

Formation of Risk Management (RM) Team 

Management shall:

• Appoint a RM Team Leader
• Appoint RM Team members

The RM Team shall be responsible for overall RM direction and RM activities in the Workplace.  The RM team can also function as a RA Team

The RM Team shall:

• Have a thorough knowledge of the work to be assessed; and
• Be multi-disciplinary, diverse with representation from major stake-holders of the workplace operating functions
• The RM leader should have direct access to the Management or shall at least be a senior member of the workplace

Management shall ensure that the RM Leader is competent for the task. Having attended a RM course conducted by MOM Approved Training Provider (ATP) or equivalent is sufficient demonstration of the fact.

RM Team members shall be made up of management staff, facility/process engineers, technical personnel, production operators, engineering staff and WSH personnel if available.

Risk Assessment (RA) Team 

All Supervisors have responsibility to lead their team in RAs and RA reviews.  In this sense, they also assume the role of RA Team Leaders. Non-Supervisors may also be appointed as RM Team Leaders by Management.

All employees have responsibility to participate in their team’s RAs and RA reviews. Especially employees involved in day-to-day factory operations. They assumed the role of RA Team members.

RA Teams shall have representatives from both the management and non-management levels.

RA Teams are responsible for conducting RAs within the scope defined by the RM team.  The scope of the RA shall be by functional area and work activities of each department.

Different RA Teams can be formed to conduct RA for work activities for the different departments.

The RA Team should include personnel who are involved with the work, including contractors and suppliers.  If available, persons who are familiar with the design and development of the site, machine or process should be included.

If RA experience or expertise is lacking, a WSH Officer, WSH Auditor or Approved Risk Consultant who is trained and has experience in conducting RA should be engaged to assist the RM/ RA leader in the conduct of the RA

Inventory of Work Activity Form

For each department’s identified functional areas and work activities to be assessed, the “Inventory of Work Activities” form  shall be used.

The following information is to be completed in the form:

• State the Department
• Complete the Location, Process and Work Activity
• List the Work Activity in sequential steps

Gather relevant Information

The risk assessment team shall gather the following information as far as possible:

• Plant/Workplace layout plan
• Process flowchart
• List of work activities in the process
• List of chemicals, machinery and/or tools used
• Records of past incidents and accidents
• Relevant legislation (These can be obtained via the organisation’s internal  network)
• Relevant codes of practice or specifications
• Observations and interviews
• EHS Inspection records
• Details of existing controls measures
• Environmental, Health and Safety audit reports
• Feedback from staff, clients, suppliers, or other stakeholders
• Safe Work Procedures
• Other information such as Safety Data Sheets (SDS), manufacturer’s instruction manual
• Copies of any relevant previous risk assessments
• Medical condition (e.g., allergy) of workers in the workplace or activity being assessed

RISK ASSESSMENT

General Requirement 

The steps in 2.2 Hazard and Environmental Aspect Identification, 2.3 Risk Evaluation and 2.4 Risk Control specify the methodology in conducting the RA

When the steps from 2.2 to 2.4 have been recorded in the “RA Form” (Appendix E) for a hazard / environmental aspect, the same steps from 2.2 to 2.4 are to be repeated till all the “Work Activity” from the “Inventory of Work Activities”  has been assessed.

All RA shall be reviewed continuously but no later than 1 year from its last review or when there are:

Accidents, near misses or dangerous occurrences as a result of exposure to a hazard.  These may or may not result in injury;

Introduction of new raw materials, significant change in processes, facilities, work practices or procedures, or change in workplace condition and site layout or; New information on EHS risks is made known

To promote good practice of continuous review on RAs of each department, RA leaders are advised / recommended to conduct one RA review per week with their team members at pre-start work briefings, toolbox meetings, dept safety meetings, etc.

Hazard and Environmental Aspect Identification 

General

The RA Team Leader is to determine the most appropriate way(s) of identifying the hazards.  These may include brain-storming, systemic process reviews, Process Hazard Analysis or Job Observations, etc.

When identifying hazards, the RA team is to consider if the hazards could cause harm beyond their immediate area of the work.

Work Activity

Copy the contents in “Work Activity” column of the “Inventory of Work Activities” form  to column (b)Work Activity in the “RA form” Identify the environmental aspect and/or hazard and record them in column (d)Aspect / Hazard

If there is more than one hazard for the work activity, different hazards should be recorded in different lines. 

Determine whether the hazard can occur under the following conditions and record it in column (c)Condition:

N – normal operating conditions e.g., preparatory and troubleshooting activities.

Ab – abnormal conditions e.g. shut down, start up, commissioning or maintenance of plant, untrained/new staff.

E – reasonably foreseeable accident or emergency situation

Where relevant, the following categories of environmental aspect should be considered:

• emission to air
• releases to water 
• waste management
• contamination of land
• use of raw materials and natural resources
• noise, dust, odour

When identifying hazards, consider the following sources of harm (List not exhaustive): 

• Behaviour, Capabilities, Other Human Factors
• Failure to successfully carry out an operation that is part of normal duties.
• Erroneously carrying out an operation that is not part of normal duties.
• Failure to respond correctly to an alarm situation (failure to control or making a situation worse).
• Deliberate or inadvertent degradation of the safety of a plant (eg switch an alarm off, or bypass a safety system)
• Deliberate rule flouting (eg smoking in a non-smoking area).
• Decision making errors (person making an action but the wrong one)
• Errors of omission (person failing to act)
• Introduction of failures by damaging equipment or leaving equipment mis-aligned during testing or maintenance
• Work ability – Rehabilitation, disability, aging workforce.
• Human failure resulting from actions, omissions and decisions taken by other people other than front-line persons (includes designers, managers, etc)
• Little time to perform (e.g., during abnormal or emergency operating conditions, Pressure to meet quota, etc)
• Fatigue (e.g., consecutive overtime, workload increase)
• Under influence of drugs, medication
• Highly complex task (Operator being asked to do a critical task that would probably be more reliably done automatically)
• Undue reliance on an Operator to identify and respond rapidly to an alarm condition.
• Experience (previous experience with equipment, etc)

Physical Hazards 

• Electrical hazards; frayed chords, missing pins, improper wiring
• Fire hazards; accumulation of rubbish in stairwells, overheating of faulty equipment, etc.
• Wearing unsuitable clothing or PPE when operating machinery
• Constant loud noise
• Exposure to extreme temperatures (heat or cold)
• Work at heights (2 m and above), on ladders, roofs
• Objects falling from height (unsecured, loose containers, tools, etc)
• Working with forklifts, reach trucks
• Trip hazards such as wet floors, cords running across floors 

Mechanical Hazards 

• Moving parts; rotating parts of machinery.
• Unguarded machinery and moving machinery parts; guards removed or moving parts that a worker can accidentally touch;

Biological Hazards 

• H5N1 virus 
• Blood or other body fluids (e.g., unprotected resuscitation to Hepatitis C virus carrier, etc)  

Ergonomic Hazards 

• Poor lighting 
• Improperly adjusted workstations and chairs 
• Frequent lifting
• Carrying for long periods of time
• Lifting / carrying loads above 20 kg
• Repeated stretching
• Poor posture 
• Repeating same movements (for long periods of time)
• Applying too much force (repeatedly)

Chemical Hazards 

• Hazardous substances such as flammables, toxics, corrosives, reactive materials, etc.
• Exposure to hazardous substances in the form of gases, dust, fumes, vapors,  liquid and solids (contact with eyes, skin, inhalation, ingestion)
• Fire & Explosion from use of flammable liquids

When Aspect / Hazard Identification is complete, proceed with 2.3 Risk Evaluation 

Risk Evaluation

Impact and Consequences

For each Aspect / Hazard identified, determine the environmental impact and consequences (possible injury / ill health) and record these in column (e)Impact / Consequence and Person(s)-at-risk 

Also record persons-at-risk in column (e)Impact / Consequence and Person(s)-at-risk. Persons-at-risk are not limited to persons performing the work.  They can also include suppliers, contractors and visitors.

When identifying environmental impacts, consider, where relevant, the following:

• global warming
• ozone depletion
• acid rain
• water pollution
• soil and ground water contamination
• noise pollution
• depletion of natural resources
• employee’s safety and health

When identifying consequences (possible injury / ill health), the following shall be considered:

• Physical injuries (e.g. cuts, fractures, bruises, loss of body parts etc.)
• Ill-health (headaches, breathlessness, deafness, limb disorders, diseases, etc)
• Property damage

Existing Risk Controls

Identify the existing risk controls for the aspect / hazard and record these in column (f) Existing Risk Controls 

When there is more than one existing risk control for the aspect / hazard being evaluated, they should be recorded in the same line as the aspect / hazard.

Also record persons-at-risk in column (e) Impact / Consequence and Person(s)-at-risk. Persons-at-risk are not limited to persons performing the work.  They can also include suppliers, contractors and visitors.

When there is more than one existing risk control for the aspect / hazard being evaluated, they should be recorded in the same line as the aspect / hazard.

Assessment of Severity

With the existing risk controls in consideration, each team member is to rate the most likely severity outcome of the possible impact / consequence (possible injury or ill-health)  

Enter the number average of the RA Team’s severity score in column (g)S “Severity”

Use “Table 1: Criteria for Risk Evaluation” (Appendix B) as guidance in selecting the level of severity (i.e, 1, 2, 3, 4 or 5)

Should the difference in rating among team members be 2 or greater, the following should be done:

The Team Leader is to facilitate a discussion to understand the reasons behind the variance.

The team is then allowed to reconsider their rating.

Should the difference in rating among team members continue to be 2 or greater, the Team Leader may choose to allow this difference or to take other courses of action to gain a better understanding of the rating.

Assessment of Likelihood

With the existing risk controls in consideration, each team member is to rate the likelihood that the environmental aspect / hazard may cause environmental impact / consequence (possible injury or ill-health)

When considering likelihood, the RM or RA Team is to consider the existing medical condition of the affected persons that may affect the livelihood rating.

Enter the number average of the RA Team’s likelihood score in column (h)L  “Likelihood” 

Use “Table 1: Criteria for Risk Evaluation” (Appendix B) as guidance in selecting the level of likelihood (i.e, 1, 2, 3, 4 or 5)

Should the difference in rating among team members be 2 or greater, the following should be done:

The Team Leader is to facilitate a discussion to understand the reasons behind the variance.

The team is then allowed to reconsider their rating.

Should the difference in rating among team members continue to be 2 or greater, the Team Leader may choose to allow this difference or to take other courses of action to gain a better understanding of the rating.

Risk Prioritisation Number (RPN)

Obtain the Risk Prioritisation Number (RPN) by multiplying the (g) S “Severity” and (h) L “Likelihood” columns and entering the score in column (i) RPN  (RPN = S x L).

Classification of Risk – Risk Matrix

Compare the RPN against “Table 2 – EHS Risk Ranking Matrix” (Appendix C).

Proceed to Risk Control if the RPN is NOT within the green zone (“Low Risk”) or yellow zone (“Medium Risk”).

Action for Risk Levels 

Actions are to be implemented based on Risk Level as shown in “Table 3 – Action for Risk Levels”

RISK CONTROL

Additional Controls 

Compare the existing controls against the Hierarchy of Control (Figure 1) 

The control of hazards / environmental aspects and reduction of risks / environmental impacts can be accomplished by following the Hierarchy of Control (Figure 1). These control measures are not usually mutually exclusive. Generally, it may be more effective to use multiple control measures e.g. engineering controls can be implemented together with administrative controls like training and safe work procedures.

Elimination

Elimination of risks / environmental impacts refers to the total removal of hazards / environmental aspects, effectively making all the identified possible environmental impacts, accidents and ill health impossible.

This is a permanent solution and should be attempted in the first instance. If the hazard is removed, all the other management controls, such as workplace monitoring and surveillance, training, safety auditing, and record keeping will no longer be required.

Example: Using water to wash and rinse mixing equipment eliminates the use of corrosive chemicals such as Sulphuric Acid and Potassium Hydroxide, used in the washing. This eliminates hazards that may arise from chemical handling, such as burns resulting from contact, excessive inhalation of vapors, etc.

Substitution

This involves substituting a process or a product with a less hazardous one to mitigate the risk or reduce the environmental impact.

Example: replacing formaldehyde, a carcinogenic substance (cancer causing), with a non-carcinogenic substitute in the blending of certain products or replacing damaged light bulbs with energy saving ones, etc.

Engineering Controls

Engineering controls are physical means that reduce the likelihood of occurrence or severity of consequence of the mishap. These include structural changes to the work environment or work processes, erecting a barrier to interrupt the transmission path between the worker and the hazard.

Example:  Machine guards, confined space ventilation, manual handling devices and bund walls around chemical bulk tanks, etc.

Administrative Controls

These reduce or eliminate exposure to a hazard / environmental aspect by adherence to procedures or instructions. Documentation should emphasis all the steps to be taken and the controls to be used in carrying out the activity safely.

Examples: Implementation of permit-to-work systems and scheduling of incompatible works, Safe Work Procedures and Training,

Personal Protective Equipment

This should be used only as a last resort, after all other control measures have been considered, or as a short term contingency during emergency / maintenance / repair or as an additional protective measure. 

The success of this control is dependent on the protective equipment being chosen correctly, fitted correctly, worn at all times and maintained properly.

When considering additional measures to reduce risk, the more effective measures in the Hierarchy of Control should be considered first. 

Re-evaluation with Additional Controls 

When Additional Control(s) have been decided in column (j), re-rate the Severity, Likelihood and RPN scores and record them in columns (k)S, (l)L, and (m)Final RPM columns in the Risk Control Section. 

The Final RPN (column m) CANNOT be HIGHER than the RPN (column i).

Note:  Preferably the Final RPN should be within the Low Risk (Green) zone.

However, an improvement in Final RPN is acceptable provided it is not within the High Risk (Red) Zone.

Work CANNOT commence if Final RPN is in the High Risk (Red) Zone.  

Implementation Person and Date 

A specific person should be identified to lead the implementation of the Additional Controls. The person’s name and due-date for implementation is to be recorded in column (n) Implementation Person and Due Date. 

The Implementation Person is to provide progress updates to the RA Team on a periodic basis as determined by the RA Team Leader.  

RA Approval 

Completed RA forms must be approved by the Risk Owner (i.e., Manager of the area, function or activity where the risk is being assessed).  

Implementation Actions  

As far as practicable, the Manager is to implement the recommended risk control measures as soon as possible.  

The Manager shall ensure that an action plan is prepared to implement the measures. The plan should include a timeline and responsible persons implementing the safety and health control measures.

The Manager shall ensure that the plan is monitored regularly until all the measures are implemented.

The Manager shall ensure that all persons exposed to the risks are informed of:

• The nature of risks; and
• Any measures or SWP implemented.

The Manager shall ensure that regular inspections and process audits are carried out to ensure that risk control measures have been implemented and are functioning effectively.

Communication  

The Manager who oversees the area, function or activity where the WSH risks exists shall ensure that all persons exposed to the risks are informed of:  

• The nature of risks; and
• Any measures or SWP implemented; and
• The means to minimise or eliminate the risks.
• Record Keeping

The Manager (Risk owner) shall assist the employer to ensure that RA records, including but not limited to RA forms and control measure records, are kept for at least 3 years

Risk owners shall ensure that a copy of the completed RA for each work activity is submitted to the WSH Officer and he/she shall keep these records for reference for at least 3 years.

The WSH Officer shall compile a *Risk Register and ensure that the Risk Register is readily available for reviews, audits and by regulatory agencies 

*Risk Register is a compilation of RAs