* Registered WSH Officer * Registered Environmental Control Officer * MOM Approved Risk Consultant * MOM Approved WSH Auditor * MOM Approved Trainer for: * (1) Risk Management Course * (2) Basic Industrial Safety & Health Course for Supervisors (BISH) * (3) Safety Orientation Course for Workers (SOC Metalworking) * (4) Construction Safety Course for Project Managers (CSCPM) * (5) Building Construction Supervisors Safety Course (BCSS) * (6) Construction Safety Orientation Course (CSOC) Glad to be with you. Roger Tan Higher National Diploma in Electrical & Electronic Engineering U. K. Applied Technology and Management Training Certificate, Royal Air Force College, U. K. Industry Trainer Certificate Advanced Certificate in Training and Assessment

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1. Documentation: Safety Audit Checklist 2. Gaps observed at worksite 3. Examples on lack of evidence for procedures and documentation 4. Interviews’ findings 5. Problems encountered By Auditor Copyright 2011 Concord Associates Pte Ltd

* Uses quantitative auditing resulting in a more objective measurement; reducing discrepancies in the audit process of different auditing companies * Checklist was modelled after the Universal Assessment Instrument developed by the University of Michigan and published by the American Industrial Hygiene Association (AIHA). The principles of the UAI have been adopted by ILO in its OSHMS guidelines.Universal Assessment Instrument * The checklist structure follows SS506: Occupational Safety and Health Management System * Approximately 300 Questions The Safety Audit Checklist

THE ConSASS STRUCTURE 1.OSH Policy 2.Planning 2.1Planning for Hazard Identification, Risk Assessment and Risk Control 2.2Legal and Other Requirements 2.3Objectives 2.4OSH Management Programmes 3.Implementation and Operation 3.1Structure and Responsibility 3.2Training, Awareness and Competence 3.3Consultation and Communication 3.4Documentation 3.5Document and Data Control 3.6Operational Control 3.7Emergency Preparedness and Response 4.Checking and Corrective Action 4.1Performance Measurement and Monitoring 4.2Accidents, Incidents, Non-conformances and Corrective and Preventive Action 4.3Records and Records Management 4.4Audit 5.Management Review

Gaps Observed at Worksite 1 Evidence not available:- * Unable to interpret audit questions and requirements * Documentations and samples not available * Time constraint and Insufficient time to retrieve documents and samples for checking 2 Cases of WSHO :- * Unaware of QEHS Integrated manual * Unfamiliar with using the integrated manuals, procedures and forms for ConSASS Audit * Documentation not available on site (kept at HQ) 3 Cases of inadequate preparation for ConSASS Audit:- * The audit checklist is not printed out and not reviewed before the audit * No evidence information indicated in the ‘Remarks’ Column Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (1.5)Observations Is the policy reviewed at defined intervals sufficient to ensure its continuing suitability and effectiveness? Records of policy review must be provided. Check policy and documents for the above requirement. Insufficient or no evidence to show policy review Guidance notes and standard specifications: The policy shall be reviewed periodically to ensure that it remains relevant and appropriate to the organisation. (SS506 Specifications - 4.2g) System Element 1. OSH Policy Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit QuestionObservations Does the organisation's procedure for risk assessment meet the following requirements? Provide input into the determination of: 1. facility requirements 2. identification of training needs and/or 3. development of operational controls Check procedures for evidence. Most RA procedures did not show the required inputs when conducting risk assessment Guidance notes and standard specifications: The organisation's methodology for hazard identification and risk assessment shall provide input into the determination of facility requirements, identification of training needs and/or development of operational controls (SS506 Specification ) System Element 2. Planning - 2.1) Planning for hazard identification, risk assessment and risk control Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (2.1.11)Observations Are goals and objectives established? Verify documentation for evidences on the above requirements. Do not have sufficient OSH goals and objectives. Not specific and measurable (No targets) Guidance notes and standard specifications: The organisation shall establish and maintain documented occupational safety and health objectives, at each relevant function and level within the organisation (SS506 Specification – 4.3.3) Copyright 2011 Concord Associates Pte Ltd System Element 2. Planning - 2.3) Objectives

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (2.4.1)Observations Are OSH management programme(s) established and maintained for achieving its objectives? Verify documentation for evidences on the above requirement. Template available (Produce blank forms as document ) Guidance notes and standard specifications: The organisation shall establish and maintain (an) OSH management programme(s) for achieving its objectives. (SS506 Specification ) System Element 2.4 OSH Management Programme(s) Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (2.4.8)Observations Are the OSH management programme(s) reviewed at regular and planned intervals? Verify documentation for evidences on regular and planned review. Documentation has no evidence of review Guidance notes and standard specifications: The OSH management programme(s) shall be reviewed at regular and planned intervals. Where necessary the OSH management programme(s) shall be amended to address changes to the activities, products, services, or operating conditions of the organisation. (SS506 Specification ) System Element 2.4 OSH Management Programme(s) Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (3.3.31)Observations Is there a system in place to track the OSH hazards or risks identified by personnel to ensure that all issues raised are closed? Check for system and sample 3 issues raised. Cannot produced the samples Guidance notes and standard specifications: The communication system shall include a mechanism by which employee OSH concerns and observations can be transmitted to the appropriate person without fear of reprisal. (UAI - COMSYS03) System Element 3. Implementation & Operation – 3.3 Consultation & Communication Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (3.5.5)Observations Does the document and records management system procedures specify which documents and records should be considered confidential? Check procedures for evidence. Did not specify which documents and records should be considered confidential Guidance notes and standard specifications: Written procedures should define the controls for the identification, approval, issue and removal of OSH documentation, together with the control of OSH data. These procedures should clearly define the categories of documentation and data to which they apply. (SS506 Guidelines Process) System Element 3. Implementation & Operation – 3.5 Document & Data Control Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (3.6.29)Observations Does the organisation review regularly the effectiveness of sub contractor's safety plan? Check documentation for the above requirement. Do not review regularly the effectiveness of sub- contractor's safety plan Guidance notes and standard specifications: The occupier shall establish procedures to ensure that the safety requirements in the contract agreement are implemented effectively on site during the construction phase. The occupier shall: review regularly the effectiveness of the sub-contractor's safety plan (CP 79 - Section 8.5b) System Element 3. Implementation & Operation – 3.6 Operation Control Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit QuestionObservations Are there established and maintained procedures for defining responsibility and authority for the following? Conducting investigation of non- conformances Check procedures for above requirements Do not have procedures for investigation of non- conformance Guidance notes and standard specifications: The organisation shall establish and maintain procedures for defining responsibility and authority for the handling and investigation of nonconformances. (SS506 Specifications a) System Element 4. Checking & Corrective Action – 4.2 Accidents, incidents, non-conformances and corrective and preventive action Definition for Non-conformance: Any deviation from work standards, practices, procedures, regulations, management system performance etc. that could lead to injury, property damage, damage to workplace environment, or a combination of these

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit QuestionObservations Does the management review address the adequacy and possible need for changes to the following? Management programme(s) Check documentation for the above requirement. Do not have procedures & document to show management review addressing the adequacy & possible need for changes to management programme Guidance notes and standard specifications: The management review shall address the possible need for changes to policy, objectives and other elements of the OSHMS, in light of the audit results, changing circumstances and the commitment to continual improvement. (SS506 Specifications - 4.6) System Element 4.5 Management Review Copyright 2011 Concord Associates Pte Ltd

* ConSASS Interview Sheet – covers 17 pages * Questions are drawn from the main checklist * Cover a wide range of representation from different levels of the organizational hierarchy i.e management, line management, workers, OSH personnel, contractors, suppliers * Certain interview questions are applicable to a specific group of staff Copyright 2011 Concord Associates Pte Ltd

* Minimum 3 personnel are selected to be interviewed from the following:-  1 representing management;  1 representing OSH personnel/WSH committee member;  1 representing line management;  1 representing employees;  1 representing contractors/suppliers Copyright 2011 Concord Associates Pte Ltd

Sampled findings of system element interviewed : Copyright 2011 Concord Associates Pte Ltd

Auditor’s Finding(s) Audit QuestionInterview of Personnel Can employees demonstrate an understanding of the organisation’s Policy (based on sampling)? Line management i.e supervisory level; contractors/ suppliers were not able to articulate understanding of said policy System Element OSH Policy Copyright 2011 Concord Associates Pte Ltd System Element Planning - Planning for hazard identification, risk assessment and risk control Auditor’s Finding(s) Audit QuestionInterview of Personnel Are relevant personnel (e.g. direct employees, sub-contractor, suppliers, consultants) aware of the legal & other OSH requirements that they have to comply with General lack of awareness by contractor/ supplier on the requirements

Auditor’s Finding(s) Audit QuestionInterview of Personnel Did the organization determine and provide the level of staffing necessary to implement the management programme OSH personnel was not able to verify System Element OSH Management Programme(s) Copyright 2011 Concord Associates Pte Ltd Is management review documented and disseminated to personnel with OSH responsibilities & relevant parties Site personnel were unaware of the management review findings System Element Management Review

Problems encountered by Auditor 1. Some WSHO not aware of QEHS Integrated manual and not familiar with using the manual for ConSASS Audit 2. Unable to find evidence for the Procedures and Documents as specified in the checklist. 3. Inadequate preparation for ConSASS Audit by the worksite a) Did not print out the audit checklist and review before the audit. b) Did not indicate evidence in the ‘Remarks’ Column Above Causes Can Leads To:- 1. Insufficient time to cover adequately all audit questions in ConSASS Checklist, more than 300 questions 2. Auditor unable to complete the document review within 2 days and also to complete the Audit Score Card for briefing during closing meeting Copyright 2011 Concord Associates Pte Ltd

Preparation for ConSASS Audit 1. How do you prepare for ConSASS ? Understand ConSASS and Methodology (ConSASS Resources available in Website) 2. ConSASS Structure and Checklist Based on SS and UAI and CP 79 Standard 3. Be familiar with the Integrated manuals in your organisation (QEHS, Procedures Manual, QM, OHSAS 18001)

ConSASS Resources

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ConSASS Resources from the WSHC website

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Gaps Observed at Worksite 1 Evidence not available:- * Unable to interpret audit questions and requirements * Documentations and samples not available * Time constraint and Insufficient time to retrieve documents and samples for checking 2 Cases of WSHO :- * Unaware of QEHS Integrated manual * Unfamiliar with using the integrated manuals, procedures and forms for ConSASS Audit * Documentation not available on site (kept at HQ) 3 Cases of inadequate preparation for ConSASS Audit:- * The audit checklist is not printed out and not reviewed before the audit * No evidence information indicated in the ‘Remarks’ Column Copyright 2011 Concord Associates Pte Ltd

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Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (3.2.8)Observations Are competence necessary for tasks that may impact on OSH in the workplace (note: these tasks should not be limited to statutory requirements) defined in terms of education, training and/or experience? Check documentation to see if competency is defined in terms of relevant education, training and/or experience. Cannot show documentation evidence Guidance notes and standard specifications: Personnel shall be competent to perform tasks that may impact on OSH in the workplace. Competence shall be defined in terms of appropriate education, training and /or experience. (SS506 Specifications ) System Element 3. Implementation & Operation – 3.2 Training, Awareness & Competence Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (3.5.7)Observations Are there defined document disposal criteria and methods? Check procedures for evidence. Documented disposal criteria defined but not the methods Guidance notes and standard specifications: Obsolete documents and data are promptly removed from all points of isses and points of use or otherwise assured against unintended use. (SS506 Specifications ) System Element 3. Implementation & Operation – 3.5 Document & Data Control Copyright 2011 Concord Associates Pte Ltd

Examples on lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (4.1.11)Observations Are the evaluation's validity and reliability assessed during management reviews? Check documentation for above requirements. Do not have this procedures & documentation Guidance notes and standard specifications: The evaluation system should include sufficient quality assurance and quality control procedures to ensure that data collected during the evaluations are valid and reliable. (UAI - EVAL07) System Element 4. Checking & Corrective Action – 4.1 Performance measurement & monitoring Copyright 2011 Concord Associates Pte Ltd

Examples on Lack of evidence for procedures and documentation Auditor’s Finding(s) Audit Question (1.3.2)Observations Does the OSH Policy clearly state overall safety and health objectives. Check policy for the above requirement. Most policy did not clearly state overall safety and health objectives Guidance notes and standard specifications: There shall be an occupational safety and health policy authorised by the organisation's top management that clearly states overall safety and health objectives and a commitment to improving safety and health performance. (SS506 Specifications - 4.2) System Element 1. OSH Policy Copyright 2011 Concord Associates Pte Ltd

Auditor’s Finding(s) Audit QuestionInterview of Personnel Are the risk assessments conducted by personnel that have adequate knowledge of the activities involved and the risk assessment technique adopted Contractors and line management i.e supervisors were not familiar with the risk assessment technique though they were part of the RA team. System Element Planning - Planning for hazard identification, risk assessment and risk control Copyright 2011 Concord Associates Pte Ltd