• SH&E is a line management responsibility. Ownership and accountability for SH&E performance is embedded in the line at all levels and Line Managers are responsible for providing SH&E leadership and for development and implementation of SH&E management plans for their areas of responsibility. 

As we are moving forward SHE Management Plan is taking a shape already!

To be continued… 

Performance Monitoring

Unless you measure you cannot improve…old age saying…

Performance Monitoring has to be part of SHE Management Plan. Further, you need to compare your performance with Industry Standards first and later with the best in the world.

Key Performance Indicators for SH&E and Sustainability are:

• All Worker lost workday / recordable case rate;

• Hygiene - performance sampling to plan (%) & samples < exposure standard (%);

• Health assessment – performance to plan (%);

• Number of site losses of containment;

• Number of distribution incidents;

• Number of justifiable public complaints / prosecutions;

• Number of security incident;

• Environmental licence non-compliance (%);

• Energy usage per tonne of production;

• Total Greenhouse Gas emission per tonne of production;

• Water usage per tonne of production;

• Waste generated per tonne of production;

• Sustainability Index;

• Audit programs completed;

• Compliance with procedures / standards; and

• Incident / audit actions overdue.

One can start with critical ones and later add more indices to reports.

If operation is big with multiple operations and large number of people then once can employ a data base for such reporting.
 

The Company can set up challenging short and long term targets for these key performance indicators.

The initial metric for Process Safety is the number of Process Safety related incidents.

At the site and operation level measurement will also focus on positive performance measures including behavioural safety.

To be continued…

 • SH&E is a line management responsibility. Ownership and accountability for SH&E performance is embedded in the line at all levels and Line Managers are responsible for providing SH&E leadership and for development and implementation of SH&E management plans for their areas of responsibility. 

Clearly compliance with all local regulations is mandatory. Line accountability in the company should be explicit.

To be continued…

Training & Development

Central to SH&E strategy is that appropriate training is in place to equip all personnel to carry out their tasks so as to take care of themselves and others. And therefore it forms an important ingredient of SHE Management Plan.

There are standard SHE Training modules available concerning SH&E Leadership. The following categories and roles of business leaders across the organisation should first be subjected to these trainings:

• Senior Manager  & Business Management Leadership.

• Operations Managers and Senior Manufacturing / Production Leadership.

• Commercial / Business Product Manager Leadership.

It is the responsibility of the Business to nominate the appropriate personnel for training and to ensure training records are maintained.

It is essential that all new Managers, either upon joining the company or for those moving into new senior manager/leadership roles, attend within the first year of appointment. These courses aim to explore and develop the "leadership" characteristics of SH&E within the various roles, as opposed to delivering solely the technical aspects of SH&E.

Additionally, all Site Managers has to undergo an initial Site Manager’s Competency Assessment, and preparation of a development plan. Follow up assessments are determined based on the initial assessment and any role changes.

The SH&E Department will provide an annual program of the SH&E Leadership Training suite.

SHE Training is not something which is once done and then forgotten. Refresher training is a must for sustenance of SHE performance and this should be considered while drawing up training calendar.

As we are moving forward SHE Management Plan is taking a shape already!

To be continued…  

• SH&E is a line management responsibility. Ownership and accountability for SH&E performance is embedded in the line at all levels and Line Managers are responsible for providing SH&E leadership and for development and implementation of SH&E management plans for their areas of responsibility. 

Maintenance of employees health makes a good business sense if you see number of court cases abroad concerning these matters. It would not be long before such cases start cropping up in India as well. Being proactive would help avoid big compensations later!

Sustainability

The term sustainability means the balancing of the environmental, social and economic factors in a company so that it is indeed sustainable for the long term. In today’s time one has to be very clear concerning this aspect of operations. One has to see that in the SHE Management Plan this is articulates clearly like for example “no harm to people and the environment”.

Matter concerning environment means:

• Conduct all operations in a socially responsible manner.

• No net greenhouse gas emissions to the atmosphere.

• No net consumption of potable town water.

• No net generation of waste to landfill, requiring innovative ways to prevent, reduce, re-use and recycle by-product streams.

• Environmentally friendly operations, products and services (which have no unintended consequences to the environment or the community).

                                    ….. in a commercially responsible way.

All these would be elaborated as we move along. Priorities would be set up to see that resources are not constraint.

The environment related Model Procedures cover the issues of legacy management plus on-going environmental management and design issues. If it is a new set up then we need not worry about legacy issues, however, in case of set in existent for a long period, legacy issue take prime importance and should be dealt with suitably.

 Any facility, as a minimum, must comply with the legal requirements of the jurisdiction in which they operate. Having said this my suggestion would be that we should comply with the global standards if these are more stringent.

Safe movement of product from supplier to customer is also the responsibility of the company. The company has to embrace the concept of product stewardship, which includes all aspects of a product’s life cycle. The requirements for operation and practice are set out in the relevant procedures and the same to be considered in SHE Management Plan.

Clearly compliance with all local regulations is mandatory. Line accountability in the company should be explicit.

To be continued…

• SH&E is a line management responsibility. Ownership and accountability for SH&E performance is embedded in the line at all levels and Line Managers are responsible for providing SH&E leadership and for development and implementation of SH&E management plans for their areas of responsibility. 

As said in the last Blog, Model Procedures are categorized under SHE Management, Safety, Health, Environment and Engineering. As can be seen here, process part is not fully covered.

All these bullet points require further elaboration as we move along….

Health

Health and Hygiene of people working at your works is of prime importance with awareness in this regard increasing in the country and legislation becoming more stringent globally. This should definitely be part of SHE Management Plan.

The occupational health strategy should be in line with contemporary occupational health practice in hazardous industry and based upon the principles of:

• Assurance of control of exposure to hazardous agents and working environments;

• Fitness for work; and

• Health and well-being.

The assurance of exposure control processes includes:

• setting of appropriate global exposure standards to priority hazardous agents; It is prudent to set up global standards which sometimes are more stringent than Indian Standards. This helps set up systems and controls from the very beginning which is world class.

• comprehensive hygiene assurance processes to be in place at sites; and

• control of workplace hazardous substances (chemicals and materials) within the company operations.

The focus of the fitness for work program is on the integrated application of measures required to ensure the on-going fitness for work. This should include:

• health surveillance and monitoring programs;

• pre-placement and work transfer medical reviews;

• fatigue risk management;

• drugs and alcohol; and

• recording, analysis and management of absences and sick leave etc.

Whilst Health and Well Being is sometimes promoted in a headline context, the nature of programs falls best under a comprehensive approach to fitness to work.

Impact on health of employees most of the times is a very slow process and impact is normally seen at the fag end of his working career. It is therefore important to understand health hazards of chemicals in use at site controls to be put in place and regular monitoring of health of employee to see that systems are working well.

Maintenance of employees health makes a good business sense if you see number of court cases abroad concerning these matters. It would not be long before such cases start cropping up in India as well. Being proactive would help avoid big compensations later!

 • SH&E is a line management responsibility. Ownership and accountability for SH&E performance is embedded in the line at all levels and Line Managers are responsible for providing SH&E leadership and for development and implementation of SH&E management plans for their areas of responsibility. 

The Model Procedure Suites are indexed as below:

• SH&E Management

• Safety

• Environment

• Engineering

• Health

Will discuss this further….

Process Safety

Whilst the Model Procedures provide some guidance to the management requirements of hazardous processes, it is recognized that they may not provide comprehensive coverage.

Process Hazard related  SHE Management Plan inputs to be looked at separately. These inputs would be coming from the following sources:

• Basis of Safety on which the processes should be designed and operated. Basis of Safety will be discussed separately.

• Model Procedures which must be fully implemented for a particular technology which may be part of a plant.

• Authorization any major process changes.

• Requirements of technology specific engineering standards which must be applied.

• Upgrades and sustenance capital requirements to maintain integrity.  

As said in the last Blog, Model Procedures are categorized under SHE Management, Safety, Health, Environment and Engineering. As can be seen here, process part is not fully covered.

All these bullet points require further elaboration as we move along…. 

 • SH&E is a line management responsibility. Ownership and accountability for SH&E performance is embedded in the line at all levels and Line Managers are responsible for providing SH&E leadership and for development and implementation of SH&E management plans for their areas of responsibility. 

Next we need to look at set of Model procedures.

The SH&E Model Procedures provide detail on what has to be done to implement the SH&E Policy and the SH&E Standards.

The Model Procedures are used to facilitate compliance and capture best practice. They cover the full range of SH&E activities and standard model procedures have been developed by experts in the field (assisted with a range of inputs – see diagram below).

There are over 100 standard model procedures. Businesses are required to prioritise their implementation of the Model Procedures based on a risk profile of their activities and hence they logically address the most serious risks first. It is a long-term goal to achieve and sustain compliance with the Key Requirements of all the applicable Model Procedures.

The purpose of the prioritisation exercise is to give sites some focus and allow them to proceed with their SH&E management in a logical, risk-based manner, in order to develop a manageable program for implementation of the Model Procedures. This is an effective way to better utilise SH&E resources and avoid the dilution of the attention required to manage significant risks that results from resources being spread across too broad a range of activities.

Each Model Procedure identifies the issues relating to a topic and describes practical controls to be applied.  

The Model Procedure Suites are indexed as below:

• SH&E Management

• Safety

• Environment

• Engineering

• Health

Will discuss this further….

 • SH&E is a line management responsibility. Ownership and accountability for SH&E performance is embedded in the line at all levels and Line Managers are responsible for providing SH&E leadership and for development and implementation of SH&E management plans for their areas of responsibility. 

Problem and the beauty is that SHE Performance improves as you grow – you do not realize!!

To be continued…

Now what are SHE Standards and how these can be part of SHE Management System which we need to prepare?

The SHE Standards are the documents that provide a broad overview of the main SH&E activity areas. These are not used in the implementation process or day-to-day activities, but to categorise the full suite of Model Procedures

           

            Safety, Health and Environmental (SH&E) Commitment

            Safety, Health and Environmental Policy has to apply to all operations of the company. The appropriate organisation and arrangements to implement the SH&E Policy and Standards has to be put in place. The conduct expected and the accountabilities of employees for SH&E performance has to be established.

            Management and Resources

            Line management shall lead the implementation of the SH&E Policy and shall establish and monitor programmes aimed at the continuous improvement of performance towards defined goals.  Appropriate SH&E and engineering support resources and facilities shall be made.

            Communication and Consultation

            Relevant information shall be provided, to employees, contractors, customers, suppliers and the public, concerning the effects of company’s materials, products and activities on the safety and health of people and of the environment

            Selection and Training

            Competencies and expertise for safety, health and environment protection shall be taken into consideration in the selection and placement of employees. Training needs shall be identified and satisfied to ensure that all employees have the necessary skills and behave with proper regard for the safety and health of themselves and others, and for environmental protection.

            Material Hazards

            A complete and current inventory shall be available of all raw materials, intermediates, products, wastes and other materials present in the workplace. Their hazards shall be identified and risks to people and the environment assessed. 

           

            New Plant, Equipment and Process Design

            There shall be systems for the management of projects and the design of all new facilities, plants, equipment and processes. Design and construction shall be in accordance with relevant engineering guidelines, local codes and regulations.  Relevant studies shall be carried out to identify hazards and assess risks to people and the environment.  

            Management of Change

            Any modifications to facilities and the arrangements for their operation, including personnel, shall not compromise and, where possible, shall improve SH&E performance.  Proposals for changes to plant, equipment, processes and control systems shall be registered and assessed, and modifications shall be authorised.

           

            Systems of Work

            Systems of work shall be drawn up and maintained to ensure the safety and health of people and the protection of the environment.  Hazards shall be eliminated or consequent risks reduced as far as is reasonably practicable. 

           

            Emergency Plans

            The nature and scale of all reasonably foreseeable emergencies, including transport emergencies, shall be identified.  Adequate formal arrangements, appropriate to the hazards and risks involved, shall be established to deal with these emergencies.   Plans shall be communicated and regularly rehearsed and reviewed.

           

            Environmental Impact Assessment

            Each location shall prepare and maintain an up-to-date assessment of the environmental impact of its activities. This assessment shall take into account, but not be limited to, the solid, liquid and gaseous wastes produced and the measures for their disposal.

            Resource Conservation

            Natural resources shall be conserved by efficient energy use, by minimising the consumption of non-renewable resources and by reducing waste to the minimum practicable.  Re-use and recycling of materials shall be promoted, having regard for safety, health, environmental, social and economic factors.

            Waste Management

            The handling and disposal of wastes shall be properly managed.  Records shall be maintained of the handling and disposal of all solid, liquid and gaseous wastes generated.

            

            Product Stewardship

            Company shall ensure that operations are managed, in an ethical and responsible manner, all the safety, health and environmental aspects of a product from its initial conception to its ultimate use and disposal. 

            SH&E Performance and Reporting

            Company shall report safety, health and environmental performance.  Incidents and public complaints shall be recorded, investigated and appropriate corrective action taken to prevent recurrence

            Auditing

            Formal auditing procedures shall be defined and implemented to ensure that the systems and behaviours adopted to meet these Standards are soundly established, maintained and observed

 • SH&E is a line management responsibility. Ownership and accountability for SH&E performance is embedded in the line at all levels and Line Managers are responsible for providing SH&E leadership and for development and implementation of SH&E management plans for their areas of responsibility. 

As can be seen there are various aspects and based on the need of the company these may be considered for inclusion in SHE Management Plan after due prioritization.

 To be continued….

Having looked at the requirements related to Plant and Procedure, now let us see what all one has to consider related to People in SHE Management Plan.

Principles and behaviours that promote continuous SH&E performance improvement through leadership and personal responsibility

 Providing leadership

 Performance management

 Targeted selection / training

 Behaviour Based Safety

 Adherence to procedures

 Participation in SH&E training and activities

 All work-related injuries, illnesses and environmental incidents are preventable

 Safety meetings and networks

 SH&E Charter

 Site Manager Competency Assessments

 SH&E based personal objectives

 Key behaviours: take care of yourself and others; present fit for work; meet customer needs in an environmentally sustainable manner; strive for continuous SH&E improvement

 Encouraging SH&E awareness outside the workplace

I personally tend to believe that while all three P’s have to be equal for stool to remain stable and steady, people related requirements are in reinforced then it helps take care of any deficiencies which may be there under Plant and Procedure

As discussed earlier role as a SHE Leader is first and foremost. You need to set example.

Selection of people for different roles is also critical as people are your extended arms who can help improve safety at work place on their own

Then one needs to change behaviour of people at work place. It sounds easier than what it takes to achieve this! Will see what all tools are there to affect this at work place. Mindset has to be that all injuries are preventable.

Site Manager is leading the initiative at site and his competency is of upper most importance. There has to be a system of evaluating this.

Then each individual has to have their own personal goals and targets towards improving SHE Performance.

Well the realization must be sinking in that a lot needs to be done. But, having said that, it would be possible if these actions are taken up earnestly and given sufficient time.

SHE Performance cannot be improved overnight and therefore one should not lose heart if nothing seems to be improving in the short term.

Problem and the beauty is that SHE Performance improves as you grow – you do not realize!!

To be continued… 

 • SH&E is a line management responsibility. Ownership and accountability for SH&E performance is embedded in the line at all levels and Line Managers are responsible for providing SH&E leadership and for development and implementation of SH&E management plans for their areas of responsibility. 

Modifications, Critical systems, Basis of safety, risk Assessment, responsible Engineering, Process Safety, Product Stewardship are all key to SHE Management Plan concerning Plant and should for part of it.

All these aspects would be elaborated in detail when we come to implementation stage. 

To be continued…

Having looked at plant, let us now have a look at Procedure related requirements

A management system which facilitates the implementation of effective SH&E processes

 SH&E Policy & Strategy

 Group Standards

 Model Procedures

 SH&E plans

 SH&E Reporting

 Auditing programs  

 Risk Assessment and Management techniques

 Industrial Hygiene programs

 Prevention of Fatalities initiative

 Legacy management

There are SHE standards which include Safety, Health, Environment, Fire, Engineering and Distribution requirements.  They state what sites must do to meet the Orica SH&E Policy.

The SH&E Model Procedures provide further detail on what has to be done to implement the SH&E Policy and the SH&E Standards. The Model Procedures are used to facilitate compliance and capture best practice. They cover the full range of SH&E activities. These need to be prioritized and made part of SHE Management Plan.

SHE Reporting, Auditing are essential part of Plan and should be included hereunder,

There are various ways of conducting Risk Assessment but basic ingredients are same and this tool is very effective in bringing about improvement in safety.

While most of the companies gibe not much relevance to low probability and high consequence events but in my eyes this is one area which should be given adequate attention as any such incident would push you back by several years. One should have fatality prevention initiatives in SHE Plan.

For old set ups legacy management system would play an important role in coming years with law of the land becoming more stringent in such matters.

As can be seen there are various aspects and based on the need of the company these may be considered for inclusion in SHE Management Plan after due prioritization.

 To be continued….