NEBOSH International Diploma UNIT- D Assignment February 2016 Page

NEBOSH International Diploma in Occupational Health and Safety

February 2016

Practical approach of International Health, Safety, Environment and the Risk Management

CANDIDATE STUDENT NO:

MDP 11

ASSIGNMENT

ASCON

ASSOCIATED CONSTRUCTION AND

INVESTMENT LLC

DUBAI UNITED

ARAB EMIRATES

(UAE)

SUBMISSION: FEBRUARY 2016

Main Ref.

Sub Ref. TABLE OF CONTENTS

Page No.

1.0 Executive Summary 3

2.0 Introduction 4

2.1 Aims and Obejectives 4

2.2 Methodology 4

2.2.1 Research Methods 4

2.2.2 Critical Document Reviews 5

2.2.3 Interviews/ Questioning 5

2.2.4 Referencing Style Employed 5

2.3 Description of the Organisation 5

2.3.1 The size of the organisation / workplace 5

2.3.2 The nature of the work undertaken 5

2.3.3 A description of what processes are undertaken 5

2.3.4 The employment profile 7

2.3.5 The work patterns and Production schedules employed 8

2.3.6 Department or site Chosen And its relationship to the work of the

organisation 8

2.3.7 Any special situations that are likely to have an impact on health and safety 8

2.4 Legal Environment 8

2.4.1 Constitutional Structure of the UAE 8

2.4.2 Judicial System Adopted in the UAE 9

2.4.3 Types of Courts in the UAE 9

2.4.4 Court of Cassation 9

2.4.5 Legislation Relating to Health, Safety and the Environment – Federal (UAE) 10

2.4.6 Legislation Relating to Health, Safety and the Environment – Emirate of Dubai 11

2.4.7 Codes of Practice Relating to Health, Safety and the Environment – Emirate of Dubai 11

3.0 Review of the Health and Safety Management System 13

3.1 Description 13

3.2 Gap Analysis 16

4.0 Hazard Identification 26

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Main Ref.

Sub Ref. TABLE OF CONTENTS

Page No.

4.1 Physical Hazards 27

4.2 Health and Welfare Hazards 29

5.0 Risk Assessment 32

5.1 Physical Hazards 35

5.2 Health and Welfare Hazards 40

6.0 Conclusions 42

7.0 Recommendations 43

8.0 Action Plan 46

8.1 Action Plan for Management System 46

8.2 Action Plan for Hazards and Risks 50

8.2.1 Physical Hazards 50

8.2.2 Health and Welfare Hazards 52

9.0 References / Bibliography 53

10.0 Appendices 54

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EEXXEECCUUTTIIVVEE SSUUMMMMAARRYY::

This assignment has been prepared to identify the compliance level of the company against BS OHSAS 18001:2007 management commitment towards Occupational Health and Safety (OH&S) and compliance with the applicable legislation of United Arab Emirates Ministerial Order No 32 and Dubai Municipality Code of Construction Practices (Adopted under Local Order 61/1991 as amended in 2008) requires Directors to take all reasonable care to ensure the safety of their personnel and ensure that the Corporation complies with the regulations.

A detailed review has been carried out to identify the gaps and to provide a number of measures for the improvement of the Health and safety management system of the company and major health and safety concerns, the details of which are found in the Recommendations and Action Plan. However during the review process significant findings were identified and are listed below:

1. OH&S policy of the company doesn’t classify either the nature or scale of operation. Organisation and arrangements need to be made legally appear in Arabic and other languages of different workers, so that the policy should be understood to the maximum workforce.

2. Corporate objectives need to be made specific, Measurable, Achievable, Realistic and Time Based.

In the absence of which clear action plans will not emerge and will result in poor achievement of the OH&S objectives.

3. Frequent review of Hazard identification and risk assessment is required to include all routine and non-routine activities which involved hazards from unforeseen event like sudden imminent danger caused by adverse weather conditions, sand storms and vehicle movements etc. would need to be considered and make them mandatory.

4. Needs proper planning to organize HSE training programmes in order to fulfill its Duty of Care towards the employees.

Benefits in terms of productivity will far outweigh the expenses this may incur.

5. Needs Emergency Preparedness to save any mishap which is likely to occur in confined space, working at height or any other activity showing high potential risk to workers.

6. Needs Pre medical health checks to ensure all site workers and staffs are fit for the job.

This is a legal requirement and be sanctioned.

7. During the review a positive view of the incidence and frequency rates have begun to decline, which depicts a change in the safety culture and the reputation of the company and the effort put by Health and Safety Department.

8. It is very essential to remember that poor health and safety performance invites both direct and indirect financial losses. Direct costs which include those associated with suspension of work while accident is being investigated, damage to plant and equipment, compensation to the victims and penalties awarded by the courts. Indirect costs could be damage to company reputation leading to business loss and increase in insurance premium etc.

The content of this report shall be in comparison with the local and international standards and regulations and this report will be helpful in reducing incident, increase in compliance with the rules and procedures thereby reduce fines and compensation claims, improved production, staff morale and reduce negative publicity.

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22..00 IINNTTRROODDUUCCTTIIOONN::

The preparation of this report is based from the construction of 440 numbers of housing projects at Dubai TECOM Territory under contract by ASCON (Associated Constructions & Investments LLC) which is located at south Al Barsha Dubai United Arab Emirates. The company is certified for ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007.

A review of Health and Safety and Management System of ASCON has been carried out to determine the gaps in existing Management system. The study provides an assessment of organisational risk and existing controls. The study also is a demonstration of how company can achieve health and safety objectives and how the statues and standards can be met through adopting Plan, Do, Check and Act principles of occupational health and safety management system; OHSAS 18001:2007. The name of the construction project is PT-121 Villas Development for TECOM Investment Residential Units Projects at south Al Barsha Dubai, United Arab Emirates.

2.1 AIMS AND OBJECTIVES:

The aim of this assignment is to assess and detail the OHSMS performance and practice of ASCON and to recommend and justify an action plan with a view towards continual improvement.

Specific objectives of this assignment are:

a. To assess the current OHSMS of the organization with reference to OHSAS 18001:2007 and the inherent risk profile.

b. To identify noncompliance with legal and other requirement with the aim of avoiding penalties and prosecutions.

c. To identify physical, health and welfare hazard associated with the activities and processes in the workplace and selecting priorities as required.

d. To find out areas which need attention by carrying out hazard identification and risk assessment in order to provide the management with action areas for further continual improvement.

e. To prepare an action plan and highlighting the gaps with recommended measures.

2.2 METHODOLOGY

The methodology adopted for this assignment was based on the following:

2.2.1 RESEARCH METHODS

Method 1 - This review include Health Safety and Environmental Policy statement, Construction phase OHS Plan, Hazard identification and Risk assessments, Accident/ Incident Reporting, OHS statistics, Management of Fire and other emergencies, non-conformities, training plan and records, previous audit reports, Permit to work system

Method 2 - Consultation with work forces and gathering information. Pre-prepared questionnaires have been used in this section and carried out in all departments within the project. The consultation was helpful in assessing the level of knowledge and awareness of employees in OHS management system.

Method 3 - Site inspection together with site management representatives. Carried out a detailed and thorough inspection at construction phase to identify the non-compliance and took samples such as photos, color coding, inspection tags, inspection details etc., to compare with applicability of management system. All the observations were noted and took evidences during inspection with specific location of non-conformities.

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2.2.2 CRITICAL DOCUMENT REVIEWS

External and legal documents reviews a. UAE federal law 8 of 1980

b. Ministerial decision 32/1982

c. Code of Construction Safety Practice (Guidelines for Construction Industry in the Emirate of Dubai)

Internal/ company documents reviews

a. HSE policy

b. HSE manual

c. Different HSE procedures

d. Previous HSE audits and HSE inspection reports

e. Project specific HSE plan

2.2.3 INTERVIEWS/ QUESTIONING

a. Interviews with project manager, construction manager, QA/QC manager and Safety Personnel.

b. Interviews with Department Heads and Line supervisors

c. Random interviews of workers during site visits/ inspection

2.2.4 REFERENCING STYLE EMPLOYED

The referencing system that will be employed throughout this assignment presentation will be based on the Harvard System.

2.3 DESCRIPTION OF THE ORGANISATION

ASCON (Associated Constructions & Investments LLC) this organisation has several construction projects within the UAE and the project selected is PT-121 Villas Development for TECOM Investment Residential Projects in south Al Barsha Dubai, United Arab Emirates

ASCON is certified with ISO 9001:2008, ISO 14001:2004 & OHSAS 18001:2007, ASCON is the recipient of several prestigious awards namely the Dubai Quality Award 2011, Dubai Quality Appreciation Program 2008 and the Mohamed Bin Rashid Al Maktoum Business Award 2007.

The work force is multicultural and accommodation for workers is arranged by the Company. Transportation of workers to and from sites is managed by Company transport.

2.3.1 THE SIZE OF THE ORGANISATION / WORKPLACE

ASCON is a Business Conglomerate originating from the United Arab Emirates, comprising of dedicated business units for Civil Construction, Electro Mechanical Engineering, Real Estate, Facilities Management and Trading. ASCON has a turnover of approximately USD 5

Billion and employs 65,000 people in the UAE.

2.3.2 THE NATURE OF THE WORK UNDERTAKEN

ASCON is adept at completing projects in sectors such as High Rise Towers, Residential, Commercial, Healthcare, Mixed Use Developments, Industrial, Multi-Storey Car Parks, Oil & Gas, Airports, Hotels, Public Parks, Stadiums and Educational Institutions.

2.3.3 A DESCRIPTION OF WHAT PROCESSES ARE UNDERTAKEN

The regular activities carryout at site are excavation, manholes, scaffoldings, carpentry, mason works, painting, tile laying, water proofing, pre-cast boundary wall erection, mechanical lifting and shifting of materials, mechanical, electrical and plumbing works, manual handling, hot works, underground water tank construction and surface coating works etc.

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2.3.4 THE EMPLOYMENT PROFILE

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2.3.5 THE WORK PATTERNS AND PRODUCTION SCHEDULES EMPLOYED

ASCON also has specialized divisions for supply and installation of Marble & Granite, Roads and Infrastructure, Heavy structural steel fabrication and erection, Dewatering, Landscaping, Swimming pools, Floor coating and GRC / GRP works which support ASCON in executing projects for its valuable clients. It has several other specialist divisions in every sector related to the construction industry such as Joinery and Interiors, Low Voltage Switchgear Panels, Elevators, Structural Steel

Fabrication, Composite Aluminum Cladding.

2.3.6 DEPARTMENT OR SITE CHOSEN AND ITS RELATIONSHIP TO THE WORK OF THE ORGANISATION

ASCON (Associated Constructions & Investments LLC) this organisation has several construction projects within the UAE and the project selected is PT-121 Villas Development for TECOM Investment Residential Projects in south Al Barsha Dubai, United Arab Emirates

Since ASCON has built numerous landmarks dotting the landscape that stand as testimony to its engineering and construction capabilities in United Arab Emirates

2.3.7 ANY SPECIAL SITUATIONS THAT ARE LIKELY TO HAVE AN IMPACT ON HEALTH AND SAFETY

Environmental Health & Safety achievement award: Al Hosn Gas Project – EHS Champions

League 2012 Winner

a) ADNOC (Abu Dhabi National Oil Company) Project - got 7 Million Safe Man-Hours

a) Borouge (Abu Dhabi Innovation Center) Project - got 7 Million Safe Man-Hours

b) GASCO (Abu Dhabi Gas Industry Ltd) Project-got 10 Million Safe Man-Hours

2.4 LEGAL ENVIRONMENT1

2.4.1 CONSTITUTIONAL STRUCTURE OF THE UAE

The United Arab Emirates (UAE) was formed on 2nd December 1971 by the passing of the Union Declaration by six states, namely, Abu Dhabi, Dubai, Sharjah, Ajman, Fujairah and Umm Al Quwain. Ras Al Khaimah joined the Federation in 1972.

The UAE is governed in accordance with the Constitution as per the Constitutional Amendment Law No 1 of 1996.

The UAE Constitution permits each Emirate to have its own legislative body and judicial authority. Accordingly there are Federal Courts and Local Courts in the UAE.

All Emirates other than Dubai and Ras Al Khaimah have now brought their judicial systems into the UAE Federal Judicial Authority, with Dubai and Ras Al Khaimah retaining their own judicial systems which are not part of the UAE Federal Judicial Authority.

Federal and Local courts apply UAE Federal Laws which are enacted by the UAE Federal Legislative Authority as well as laws and regulations enacted by the Rulers of the individual Emirates.

Although the legal procedures and laws applicable to courts in the individual Emirates are all fairly similar, there are differences, particularly where a special law has been enacted and applied in a particular Emirate.

In the event of a conflict between the Federal and Local laws, the Federal Law will supersede the Local law of the Emirate.

1 Al Tamimi (2007) The Framew ork for Litigation in the United Arab Emirates. Al Tamimi, UA E, pp 2 - 10

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2.4.2 JUDICIAL SYSTEM ADOPTED IN THE UAE

The UAE is a civil law country and follows a civil law system; as such the primary source of law is a statutory code.

The UAE legal system has been influenced to a large extent by the Egyptian legal system which has its source in French and Roman law.

The law in the UAE has also naturally been influenced by Islamic law codified in the Shari’a and embodied in the UAE Civil and commercial law.In matters of procedure, the UAE courts follow the Federal Law of Civil Procedure (No 11 of 1992) and Federal Law of Criminal Procedure (No 35 of 1992) in civil and criminal proceedings respectively.

These laws set out in detail the law and procedures for conducting civil and criminal cases before the UAE courts, whether Local or Federal.

Judges in the UAE Federal and Local courts apply the provisions of the specific laws, established usage, or customs as well as the Islamic Shari’a.

There is no system of case reporting in the UAE and as usual in a civil law system, a judge is under no obligation to take previous decisions of the court into consideration in an action before him. Such decisions are, however, persuasive and when repeated by the Supreme Court established principles are laid down which serve as guidance rather than a precedent.

2.4.3 TYPES OF COURTS IN T HE UAE

In general, in the UAE, both Federal and Local courts are divided into the Civil Courts, the Criminal Courts and the Shari’a Courts. The Civil Courts hear civil and commercial matters including private suits and company and insurance matters.

The Shari’a Courts are responsible for civil matters in the UAE for Muslims. Non-Muslims will not appear before the Shari’a Court in any matter.

The Shari’a Courts hear mostly matters of family law relating to issues such as divorce, inheritance and succession, alimony and custody of children.Cases for non-Muslims will be decided in the Courts based on civil and commercial law in general matters.Criminal matters are almost always heard by the Criminal Courts after referral by the Police to the Prosecutor’s office for investigation and prosecution. Some crimes such as assault and adultery may be transferred to the Shari’a Courts in some Emirates. However, even where a case is transferred to the Shari’a Court, the provisions of the UAE Federal Criminal Code will be applied.

As far as procedure is concerned, the UAE Law of Criminal Procedure will always apply to a case, whether it is heard by a Criminal Court or a Shari’a Court.

2.4.4 COURT OF CASSATION

Federal judgements delivered by the Federal Courts in the UAE (Abu Dhabi, Sharjah, Fujairah, Ajman, Umm Al Quwain) are subject to an appeal to the Abu Dhabi Supreme Court of Cassation. Judgements delivered by the Dubai Court of Appeal are subject to an appeal to the Dubai Court of Cassation. There is no Cassation Court in Ras Al Khaimah.

The UAE Federal Supreme Court of Cassation in Abu Dhabi is also the UAE’s Constitutional Court.

Appeals on facts are not referable to the Court of Cassation. Only appeals on a point of law are allowed.

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2.4.5 LEGISLATION RELATING TO HEALTH, SAFETY AND THE ENVIRONMENT – FEDERAL (U AE)

a. Federal Law No (1) 2002:- Regarding the regulation and control of the use of radiation sources and protection against their hazards.

b. Federal Law No (8) 1980:- Regulating Labor Relations.

c. Federal Law No 24 of 1999:- Protection and development of the environment.

d. Ministerial Decision 32 of 1982:- Determination of preventive methods and arrangements to project laborers from work hazards.

e. Ministerial Decision 37/2 of 1982:- Standards of medical care which the employer shall undertake to provide his laborers. In addition to these legislation the municipalities of each Emirates has Municipal laws. Approved Code of Practice and technical Guide lines that form the base of HSE practices of organizations in various locations all through the

UAE. Some Emirates have introduced Free Zone Areas at various ports, e.g. Hamriah Free Zone Authority, Jebel Ali Free Zone Authority (JAFZA) wherein differing and more stringent Environment Health and Safety (EHS) legislation and standards in this norm.

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2.4.6 LEGISLATION RELATING TO HEALTH, SAFETY AND T HE ENVIRONMENT – EMIRATE OF DUBAI

LOCAL ORDER No: 61 of 1991 issued by Dubai Municipality Emirate of Dubai

Chapter IV - Occupational Health & Safety Regulations (Composed of seven Articles from Article 37 to 43)

Explanatory Memo With Regard to Local Order No. 61 of 1991 on environment protection regulations In the Emirate of Dubai

4. Occupational Health & Safety Regulations

Labour Law in the United Arab Emirates contains a chapter on work accidents and occupational diseases and specifies compensation rates for workers involved in accidents during working hours, or sustain injury because of work, in accordance with the provisions mentioned therein. However, the mentioned law or its executive regulations did not include security and safety conditions, which the worker shall be familiar with during working hours whether working in the construction, alteration, repair, demolition, carry out structural maintenance or painting works, in shops, factory or industrial establishments.

The Local Order stipulated that industrial establishments, factories, mining plants, mines, and construction sites shall take certain procedures to protect workers from any occupational illness that results from exposure to a physical, chemical or biological agent in a work place. It also stipulated that worker shall comply with certain rules and co-operate with the employer to protect himself from occupational illness or work accidents.

Administrative Order No. 211 of 1991 on the Issue of Executive Regulations for the Local Order No. 61/1991 on the Environment Protection Regulations in the Emirate of Dubai

Chapter VI - Noise Control (Composed of four Articles from Article 42 to 46)

Administrative Order No. 211 of 1991 on the Issue of Executive Regulations for the Local Order No. 61/1991 on the Environment Protection Regulations in the Emirate of Dubai

Chapter VII: Noise control regulations (Composed of ten Articles from Article 74 to 83)

Chapter IX- Penalties

2.4.7 CODES OF PRACTICE RELATING TO HEALTH, SAFETY AND THE ENVIRONMENT – EMIRATE OF DUBAI

CCooddee ooff CCoonnssttrruuccttiioonn SSaaffeettyy PPrraaccttiiccee

((GGuuiiddeell iinneess ffoorr CCoonnssttrruuccttiioonn IInndduussttrryy iinn tthhee EEmmiirraattee ooff DDuubbaaii))

Corporate Marketing and Relations Technical Supervision and Proofreading

Chapter 1…..Preliminary

The current Construction Safety Code is set out to regulate the working conditions in construction projects for all employees who work with contractors or sub-contractors companies.

Each employer shall protect his employees by complying with the following:

A. Provision of Local Oder no. 61/1991 on Environmental Protection Systems in the Emirate of Dubai.

B. Provision of Local Order no. (3) of 1999 on Construction Activities Regulations in the Emirate of Dubai.

C. Provision of Local Order no. (11) of 2003 on Public Health and community Safety in the Emirate of Dubai.

D. Administrative Decision no. (125) of 2001 on Endorsement of Construction Regulations, Conditions and Specifications.

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E. Administrative Order no. (211) of 1991 on Issuance of the Executive Regulations of the Local Order no. (61) of 1991 concerning Environmental Protection Systems in the Emirate of Dubai.

F. Explanatory Note of the Local Order no. (61) of 1991 on Environmental Protection Systems in the Emirate of Dubai.

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33..00 RREEVVIIEEWW OOFF TTHHEE HHEEAALLTTHH AANNDD SSAAFFEETTYY MMAANN AAGGEEMMEENNTT SSYYSSTTEEMM

3.1 DESCRIPTION

Occupational Health and Safety Management System of the organisation follows the model of BS OHSAS 18001:2007. Managing health and safety at the project site follows the project OH&S management plan, implemented, maintained and other legal requirements are identified and maintained as Register of Regulations and is periodically reviewed.

Occupational Health and Safety Policy:

The OHS Policy is written in English and Arabic, signed by CEO of the organisation. The policy states a clear commitment to prevent occupational injuries and ill health and to comply with applicable legal regulations and other requirements. The policy requirement is relevant to section 4.2 of BS OHSAS 18001:2007 “OHS Management System”.

OHS policy established an overall sense of direction and sets of principles of action for OHS objectives and performance required. The policy is posted at all offices and various locations around the work site. It is also noted that the policy has to be communicated to other interested parties.

Planning:

A management programme for achieving OH&S objectives have been established and maintained. It includes documentation of responsibilities and authorities for achievement. Procedure for ongoing identification of hazard, risk assessment and implementation of control measures are necessary activities to be achieved. Procedures for identifying and

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accessing the legal and other OH&S requirements are applicable. The information has been communicated to its employees and other relevant interested parties. This section is

specified in 4.3 of BS OHSAS 18001:2007.

Implementation and Operation:

The organisation has appointed a management level senior person with specific responsibilities for OH&S with defined roles and authority for ensuring the OH&S management system, establishment, implementation and maintenance in accordance with the section 4.4 of BS OHSAS 18001:2007

Checking and Corrective Action:

The organization has to ensure that it regularly measures and monitor Health and Safety performance (proactive, reactive, qualitative, and quantitative). Procedure to record and investigate accidents/non-conformances and insuring that remedial actions are implemented and that such action have been effective. This section is relevant to 4.5 of BS OHSAS 18001:2007.

Management review:

A site specific OH&S Plan need to be reviewed and apply the procedures available for the identification and assessment of hazards, and the introduction and implementation of necessary control measures. Risk assessment is available for various routine and non-routine activities they are clearly identified with specific numbers, assessment date and next review date along with authorized signatures. In addition management commitment to review the policy as and when required. This section is relevant to 4.6 of BS OHSAS 18001:2007.

Continual Improvement is a prime important requirement as per OHSAS 18001:2007. It shall need to be reviewed, monitored to ensure adherence and achievement of the system.

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3.2 Gap Analysis

A critical study has been conducted in order to review the OHS Management system of ASCON to find gaps related to the actual practices and performances records and functions based on set procedures/requirements including applicable laws/rules/regulations and to address to improve the OHS Management system as per BS OHSAS 18001:2007 OHSMS

Gaps were identified and prioritized under the following justification. See the table below:

Priority Matrix

Note: Priority will not be applicable (N/A) if the requirement is fulfilled.

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GAP ANALISYS FINDINGS

OHSAS-18001:2007 Section/clause

Status in the current system Compliance

Status Yes/No

ASCON EHS/PLAN

MS-Reference

Gaps Identified Priority

4.2-OH&S POLICY Policy commitment is to prevent all types of incidents, pollution and ill health arising out from its business activities.

Display on notice boards and offices to be view/read by all interested parties.

Compliance with valid UAE legislation and other requirements.

Yes

Partially

Yes

Partially

Yes

EHS/PLAN/ ASCON/R0

Section-4.3

The policy doesn’t classify either the nature or scale of risks in construction works.

Multifarious workforce with different nationalities, majority of them unable to read and understand the policy statement which is in English and Arabic. It should be translated in their mother tongue in order to understand by majority of them.

P2

P2

4.2 OH&S Policy

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GAP ANALISYS FINDINGS

OHSAS-18001:2007 Section/clause

Status in the current system Compliance

Status Yes/No

ASCON EHS/PLAN

MS-Reference

Gaps Identified Priority

4.3-PLANNING Standard procedure for hazard identification, risk assessment and control measures are in place. Routine and non-routine activities are included

Human nature and ability not considered during review of Hazard identification and risk assessment

Management change in the organization, hazards and risk associated with unforeseen event aside from workplace activities was not included in procedure.

PPE related hazards not included

Yes

Yes Partially

No

No

EHS/PLAN/ ASCON/R0

Section-10.1

Multinational workforce, civilization, language barrier and unskilled, the aspect of their capabilities, competency levels, behavioral/attitudes and other factors are not considered while identifying and assessing hazards and associated risks.

Apart from the work place hazards those projects at remote area like parasite/insect bite, transportation accidents, sudden imminent adverse weather conditions like dust storms and their associated health risk are not considered.

PPE effective guidelines and their standardization should be included in the procedure to review in order to develop the proactive approach by suggesting control measures in accordance with the Hierarchy of risk reduction principles.

P2

P1

P1

4.3.1

Planning for Hazard identification, Risk assessment and determining controls

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GAP ANALISYS FINDINGS

OHSAS-18001:2007 Section/clause

Status in the current system Compliance

Status Yes/No

ASCON EHS/PLAN

MS-Reference

Gaps Identified Priority

4.3.2 Legal and other Requirements

This section is identified in

HSE/PLAN/ASCON/R0 Legal and Other Requirements.

Legal register has been maintained and updated regularly.

Yes EHS/PLAN/A

SCON/R0

Section-10.2

Full compliance with the standard.

4.3.3 Objectives

General objectives at the company level are documented.

They are generic in nature and not specify in the method of measuring the compliance. Lack of clear procedure to classify and accessing the legal and other OH&S requirement.

Yes

Yes Partially

EHS/PLAN/ASCON/R0

Section-4.2

.

OHS objectives in the company are not clear regarding relevant functions and level of classification is not comprehensive. The management representative shall need to undergo OHSAS 18001:2007 lead auditor training to set down the OHS Objectives and Programmes as per OHSAS 18001 requirements.

P2

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GAP ANALISYS FINDINGS

OHSAS-18001:2007 Section/clause

Status in the current system Compliance

Status Yes/No

ASCON EHS/PLAN

MS-Reference

Gaps Identified Priority

4.4-IMPLEMENTATION AND OPERATION

Clear roles and responsibilities of OH&S management personnel were documented but the same is missing for line management implementation of the OH&S requirements.

The organisation has appointed a management level senior person with specific roles/responsibilities and authority, establishment, implementation and maintenance relevant to OHSAS 18001:2007

No

Yes Partially

EHS/PLAN/ ASCON/R0

Section-5.2

OH&S roles, duties and responsibilities of line management are not clearly defined and monitored.

Supervisors tend to compromise safety for production by involving workers to take short cuts and circumvent safe working procedures during the time of pressure for job completion.

P1

P2

4.4.1

Resource, roles responsibilities, accountability and authority

4.4.2 Training Awareness and Competence

OH&S induction training records for all employees and other competency training programmes and records are available.

Training calendar is available

Yes

Partially

EHS/PLAN/ ASCON/R0

Section 7.1&3

Identification procedure is not available in the training.

During interviews with the workers it was found that their understanding of the extent of tool box talks was limited.

P2

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GAP ANALISYS FINDINGS

OHSAS-18001:2007 Section/clause

Status in the current system Compliance

Status Yes/No

ASCON EHS/PLAN

MS-Reference

Gaps Identified Priority

4.4.3

4.4.3.1

Communication participation and consultation

Communication

Requirements of this section are identified in the following procedures incident and accident reporting and investigation Tool box talk and safety talk conducted are carried out on daily basis prior to start the work.

Internal communications is mentioned in HSE Plan and through Project HSE Committee communication and consultation to various levels and functions of the organizations is taken care of.

Yes

Yes

Yes Partially

EHS/PLAN/ ASCON/R0

Section-6.1

The safety committee members need to be trained further to enhance skills on communication and consultations for effective utilization of this forum.

P2

4.4.3.2

Consultation & Participation

Requirements of this section are identified in the following procedures, Risk Assessment, Hazard Reporting Procedure, Accident/ Incident reporting and investigation

Yes Partially

EHS/PLAN/ ASCON/R0

Section 6.6

Employee and sub-contractor involvement need to be developed.

P2

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GAP ANALISYS FINDINGS

OHSAS-18001:2007 Section/clause

Status in the current system Compliance

Status Yes/No

ASCON EHS/PLAN

MS-Reference

Gaps Identified Priority

4.4.4 Documentation

Requirements of this section are identified in Policy, HSE Management system viewpoint, HSE management system manual, A document control system exists and all documents are controlled though intranet, soft/hard copies.

Yes EHS/PLAN/ ASCON/R0

Section 6.5

4.4.5 Control of Documents

At different locations the relevant revision procedure and other documents are not available.

Yes

EHS/PLAN/ ASCON/R0

Section16.2

4.4.6 Operational Control

The different operational procedures relating to critical operations are available in the HSE Plan. Requirements in this section are identified which includes: Control of substances Hazardous to health (COSHH) Risk assessment, Reporting procedures, Confined space, Work at Height, Deep excavations, PTW System, Subcontractor control procedure, Visitors, Vehicle and Management change

Yes Partially

No

EHS/PLAN/ ASCON/R0

Section 13.18

Procedure for maintenance operation not properly documented.

Most of the Work Permits are not closed after completion although it is required as per the procedure.

P2

P1

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GAP ANALISYS FINDINGS

OHSAS-18001:2007 Section/clause

Status in the current system Compliance

Status Yes/No

ASCON EHS/PLAN

MS-Reference

Gaps Identified Priority

4.4.7

Emergency Preparedness and Response

Emergency procedures are documented separately and also mentioned in site HSE plan. Mock drill records are also available

Yes

EHS/PLAN/ ASCON/R0

Section 9

4.5- CHECKING AND CORRECRTIVE ACTION

Requirements in this section are identified in the HSE plan, monitoring, evaluation, inspection, audit and data control.

Records not available for monitoring OHS performance & the monitoring of OHS Objectives at site.

Separate proactive measures or performance measurement is not available.

Weekly and monthly reactive measures performance records are available.

Yes

No

Yes Partially

Yes

EHS/PLAN/ASCON/R0

Section 14.2

All site and departments need to be monitored periodically and observations communicated to them for improving the performance.

The quality of proactive performance measures for line responsibilities concerning OHS were not monitored.

.

P1

P2

4.5.1

Performance Measurement and Monitoring

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GAP ANALISYS FINDINGS

OHSAS-18001:2007 Section/clause

Status in the current system Compliance

Status Yes/No

ASCON EHS/PLAN

MS-Reference

Gaps Identified Priority

4.5.2 Evaluation of Compliance

Requirements of this section are identified in the following section of HSE plan

Legal and other Requirement

Yes

Yes

EHS/PLAN/ ASCON/R0

Section 10.2

4.5.3.1

Incident Investigation

Requirements in this section are identified in “Accident /Incident Reporting and Investigation Procedure” section of HSE plan

Incident investigations records are available.

Yes

Yes

EHS/PLAN/ ASCON/R0

Section 15.1

Annexure-7

4.5.3.2

Nonconformity, corrective action and preventive action

Requirements in this section are identified in the “Proactive Monitoring” and “Corrective and preventive action procedure” section of HSE plan

Yes Partially

EHS/PLAN/ ASCON/R0

Section 14.5

Should develop a clear procedural guidelines for proactive identification of nonconformity and corrective actions and preventive actions

P2

24

GAP ANALISYS FINDINGS

OHSAS-18001:2007 Section/clause

Status in the current system Compliance

Status Yes/No

ASCON EHS/PLAN

MS-Reference

Gaps Identified Priority

4.5.4 Control of Records

Requirements in this section are identified in the “Document and Data Control” section of HSE plan

Yes

EHS/PLAN/ ASCON/R0

Section16.3

.

4.5.5 Internal Audit

Requirements in this section are identified in the “Audit Routine and System Review” section of HSE plan

Yes

EHS/PLAN/ ASCON/R0

Section 14.4

4.6 MANAGEMENT REVIEW Monthly meeting records and schedule of HSE meeting with CEO and Chief operating officer is available

Yes Partially

EHS/PLAN/ ASCON/R0

Section 14.3

The status management review Implementation need to be further expanded to include all departmental heads and site management

P2

4.6 Management Review

25

4.0 HAZARD IDENTIFICATION

For hazard identification process at residential unit’s project, all identified hazards listed from their working environment have been categorized mainly into two: Physical Hazards and Health/Welfare Hazards.:

Priority Matrix

Note: Priority will not be applicable (N/A) if the requirement is fulfilled.

Accident and ill health statistics management collected for review as shown in pie chart the number of accident vs. each hazard for physical hazards respectively. See the figure below:

26

4.1 PHYSICAL HAZARDS

Physical hazards include unsafe acts or conditions that can cause injury, illnesses, death or other losses. See observation below:

PHYSICAL HAZARDS

SN

Observation List hazard unsafe practices

and good practices

Action to be taken (If any) List all immediate and long

term action required

Time scale (Immediate, 1 week etc.)

Priority

1

Working at height like on scaffolding, working on floor edges, floor and wall openings.

Give internal training for working at height, conduct TBT and fix edge protections

Immediate P1

2

Unprotected trenches and excavation for building foundation, manholes and buried services.

Complete the edge protection in excavated area with appropriate warning signage & lighting.

Immediate P1

3 Unprotected floor edges and shafts at high level.

Monitor and maintain properly all edge protection at high level.

Immediate P1

4

Contact with sharp edges such as steel, metal sheets, tools, wood splinters, nails, tie wires etc.

Use of suitable hand and eye protection. Immediate P1

5

Crane lifting operation and other lifting heavy equipment use for shifting of materials at site.

Appoint dedicated trained and certified crane rigger/banks man and operator.

Use certified lifting tools and tackles.

Barricade the surrounding of the lifting area.

Adequate supervision

1 week P1

6 Poor cable management in the workplace

Reroute properly all cables causing obstruction to walkways and vehicle

movement.

Maintain all cables in good working condition.

1 week P2

7

Hot work activities associated with fire and explosion like use of compress gas cylinders, welding and cutting works.

Purchase suitable flash back arrester and attach to the hose.

Keep gas cylinders at vertical position or use trolley

Provide fire-fighting equipment

Follow the PTW system

Three days P1

27

PHYSICAL HAZARDS

SN

Observation List hazard unsafe practices

and good practices

Action to be taken (If any) List all immediate and long

term action required

Time scale (Immediate, 1 week etc.)

Priority

8

Contact of workers with live electricity from defective connections, extension, trailing cables and electrical power tools

Avoid using damaged electrical cables and power tools

Use of appropriate PPEs

Immediate P1

9

Contact of workers with rotating/moving parts such as grinding machine, wood cutting, steel cutting and bending machine etc.

Arrange training for operators from supplier

Keep the record.

Use of appropriate PPEs.

Immediate P1

10

Poor housekeeping in many areas consisting of hazardous construction waste.

Facility Manager shall need to deploy housekeeping team at site

Arrange for regular disposal

Carry out good stacking of materials

1 week P2

11

Falling hazards like falling materials from dismantling of scaffold, work platform, formworks removal, block work and mechanical lifting operation etc.

Barricade the below surrounding area of height activity.

Assign person for look out at ground surface

Display warning signs

Immediate P1

12 Construction vehicle movement

Separate the pedestrian access from vehicle route using barriers

Provide road signs.

Provide adequate road lighting special at night.

1 Week P2

28

4.2 HEALTH / WELFARE HAZARDS

Health and Welfare hazards that can affect the health of the employees such as such as resulted by poor condition of welfare facilities, chemical, dust, noise, vibration, ergonomics, inadequate breaks, job rotations etc.

Priority Matrix

Accident and ill health statistics management collected for review as shown in pie chart the number of accident vs. each hazard for health and welfare hazards respectively. See the figure below

29

HEALTH AND WELFARE HAZARDS

SN Observation

List hazard unsafe practices and good practices

Action to be taken (If any) List all immediate and long

term action required

Time scale (Immediate

, 1 week etc.)

Priority

1

Confined space operatives expose to resins and fibers for water proofing activity.

Purchase mechanical ventilation, suitable and sufficient respiratory, eye, clothing and hand protections.

Immediate P1

2

Exposure of workers to dust for concrete grinding/ cutting and concrete cleaning using air compressor.

Use of suitable hearing, eye and hand protection.

Immediate P1

3 Contact of workers with the chemical content of cement for concreting and plastering work

Use of suitable foot, eye, and hand protection.

Immediate P1

4

Contact of workers to chemical for spraying anti termite at ground surface before concrete pouring.

Use of suitable respiratory, eye and hand protection.

Correct handling and storage of chemical must be applied.

Immediate P1

5

Exposure of workers to adhesive flammable liquid for duct insulation, pipe fitting and water proofing

Use of suitable respiratory, eye and hand protection.

Correct handling and storage of chemical must be applied

Immediate P1

6

Exposure of workers to

noise and vibration such as power tools, and other construction machineries etc.

Purchase of suitable and sufficient hearing & hand protection.

Use anti vibration device and give adequate rest breaks

Immediate P1

7

Ergonomic hazard from manual handling of concrete

blocks and shifting of steel materials at far distance.

Conduct internal training regarding manual handling techniques.

Use of mechanical lifting and vehicle for shifting.

Immediate P1

8

Exposure of workers to solvent paint for internal and external painting work.

Use of suitable respiratory,

eye and hand protection.

Correct handling and storage of chemical must be applied.

Immediate P1

30

HEALTH AND WELFARE HAZARDS

SN Observation

List hazard unsafe practices and good practices

Action to be taken (If any) List all immediate and long

term action required

Time scale (Immediate

, 1 week etc.)

Priority

9 Expose of workers to extreme temperature and humidity during summer season.

Give adequate rest break and cool drinking water

Immediate P1

10 Poor illumination and visibility at night work

Provide adequate lighting at all working area and

walkways prior the work start

Immediate P1

11

Excessive duty and inadequate rest break for operatives working 12 hours & giving one hour break only.

Arrange work shifting for night and day activities

Give adequate rest break

Immediate P1

12

Psychological hazards like stress, fatigue, workplace violence and working alone etc.

Give adequate rest breaks

Avoid lone working

Provide sufficient facilities for eating, resting and amusement centre etc.

Implement incentive and motivational scheme

3 days P2

31

55..00 RRIISSKK AASSSSEESSSSMMEENNTT

The term ‘risk’ can be defined as the combination of the severity of harm with the likelihood

of its occurrence,

I.e. Risk = Severity of harm X Likelihood of its occurrence.

‘Risk assessment’ is process of estimating the level of risk and decide whether the risk is

tolerable or not and applying suitable control measures to minimize the risk to an acceptable

level known as ALARP (As Low as Reasonably Practicable).

There are eight steps in risk assessment process; the steps are as follows,

Step 1-Select the task and analyze

Step 2- Identify hazards

Step 3- Identify who/what might be harmed and how.

Step 4-Quantify the risk.

Step 5- Check existing control measures

Step 6- Apply mitigating control measures (Provide Personal Protective Equipment)

Step 7- Reappraise the residual risk

Step 8- Report the findings

Risk Matrix or Risk Score Calculator:

Risk matrix or Risk score calculator is a tool used to determine the level of risk in the Risk assessment process; it allows the likelihood and severity of the risk of an event occurring to be determined.

Once the hazards are identified for each task of a risk assessment process, they evaluated

through the risk matrix to determine the risk value

32

Severity Ratings:

The severity of occurrences is categorized as 6 parts such as “Fatality, Major injury

(Hospital Admission/> 21 days medical rest), Reportable (3-21 days) Medical rest,

Minor injury (Hospital referred cases), and First Aid injury”. The details of these

severity ratings are specified in the given box below.

Likelihood Ratings:

The likelihood of occurrences is categorized as 6 parts such as “Very Unlikely, Remote,

Likely, Quiet likely, Highly Unlikely”. The details of these likelihood ratings are specified in

the given box below.

The risk evaluation is then multiplying by the Likelihood of occurrence and Severity of

Occurrence. The result will determine the level of risk, such as High, Medium and Low.

Risk Rank: Helps to identify the level of risk;

Hierarchy of Control Measures - is used in the process of risk assessment to control or minimize the risk to an acceptable level. This hierarchy can be categorized as 6 steps in order to follow for the application of control measures.

The 6 steps of hierarchy of control measures are as follows;

33

Likelihood Rating Severity Rating Risk Matrix

34

5.1 PHYSICAL HAZARD

Risk Assessment Justification: Scaffoldings.

The reason for selecting this scaffolding erection is creating a high potential risk of fall to operatives.

36

35

5.1 PHYSICAL HAZARD

RISK ASSESSMENT

TITLE OF THE ACTIVITY: SCAFFOLDING ERECTION

ASSESSOR: Risk Assessment Committee

Activity Sequence Hazards

How might harm be caused

Persons at risk

Existing control

measures S L

RR

Proposed control measures (If Hazards any)

Reviewed/Action

Levelling of ground surface, compaction

Slip, trip and fall

All protruding steel rebars, sharp nails from wood wastes can caused foot and bodily injuries,

Employees involved in the scaffolding erection, other contractor, supervisor, and visitor.

Supervision, The area was isolated by providing adequate barricading and signage of ‘No entry for unauthorized person’ around the scaffolding erection.

2 1

2

LO W

Prior to start scaffold erection barricade and signage needs to be in place.

Ensure toolbox talk delivered by Competent Scaffolding Foreman on related hazards and its control measures.

Foreman shall ensure that all scaffold erectors are trained from company approved third party

Ensure proper compliance of PPEs like safety shoes, coverall, helmet, goggles, gloves etc

HSE Manager/

Committee

6 Months

Housekeeping and lay out preparation

Unsafe access/ egress

Obstructed access/egress can cause injury from slips, trips and fall

Employees involved in the scaffolding erection, Supervisor/ Foreman

Good housekeeping and stacking of materials

2 1

2

L O W

Ensure good housekeeping and stacking of material is done prior to scaffold erection to avoid slip, trip and fall.

All protruding re-bars shall be properly secured with rebar caps.

Ensure clear and unobstructed access has been provided to work site.

HSE Manager/

Committee

6 Months

36

RISK ASSESSMENT: SCAFFOLDING ERECTION

Activity Sequence Hazards

How might harm be caused

Persons at risk

Existing control

measures S L

RR

Proposed control measures (If Hazards any)

Reviewed/Action

Shifting of scaffolding materials near the erection area

Poor ergonomics during manual lifting

Poor manual handling techniques can cause muscle pains, strains

Employees involved in the scaffolding erection,

Supervisor/ Foreman

Vehicle provided for transporting, shifting and lifting

2

1

2

L O W

Replace manual lifting with mechanical means e.g. trolleys

Give consideration of strong workers for manual lifting of heavier components wherever possible

HSE Manager/

Committee

6 Months

Erection of scaffold at the base

Unsecured planks and ladders

Slips and fall due to unsecured planks and ladders

Employees involved in the scaffolding erection, Supervisor/ Foreman

Nylon rope have been used for securing ladder

2 1

2

L O W

Substandard scaffolding materials shall not be used for scaffolding erection especially corroded and deformed.

Ladders shall be inspected and tagged prior to use.

Scaffolding erectors shall never use unsecured ladders. Ladders must be secured with proper clamps.

Scaffolding shall be erected on firm and levelled surface

HSE Manager/

Committee

6 Months

Erection of scaffold above first layer

Substandard scaffolding material

Scaffold collapse resulting in multiple fatalities and injuries

Employees involved in the scaffolding erection,

Supervisor/ Foreman

Visual Inspection for defects

3

1

3

L O W

Scaffolding foreman shall ensure making of scaffolding register.

Do not engage any worker with height phobia.

100% Tie off shall be ensured with life line and use of harness while working at height.

HSE Manager/

Committee

6 Months

37

RISK ASSESSMENT: SCAFFOLDING ERECTION

Activity Sequence Hazards

How might harm be caused

Persons at risk

Existing control

measures S L

RR

Proposed control measures (If any) Reviewed/

Action

Erection of scaffold carried out at night shift or during severe weather condition

Poor illumination, rain and sand storms

Poor illumination, strong winds, rains and sand storm can lead to fall of person and materials from height and sometimes scaffold collapse due to heavy rains

Employees involved in the scaffolding erection, other contractor, supervisor, and visitor

Supervision 3 1

3

L O W

Scaffolding erection shall not be carried out due to poor illumination, rain or sand storms.

Proper illumination shall be provided for safe execution of job.

HSE Manager/

Committee

6 Months

38

RISK ASSESSMENT: SCAFFOLD DISMANTLING

Activity Sequence

Hazards How might harm be caused

Persons at risk

Existing control

measures S L

RR

Proposed control measures (If any) Reviewed/

Action

Removal of handrails, work platforms, ladders, posts (standards),transoms and horizontal braces (ledgers)

Material/Personnel fall

Injuries, Fatality, Property Damage

Employees involved in the scaffolding erection, other contractor, supervisor, and visitor

Fall prevention Equipment

3 1

3

L O W

Prior to start scaffold dismantling barricade the area and appropriate

signage must be in place.

Edge protection and any means of access can be removed as the scaffolding is dismantled, provided it is removed at the last possible stage.

Ensure that when dismantling scaffold, the platform immediately below the level where worker is standing on, has

a full set of planks across its width.

Dismantled component shall never be thrown down; it will be transferred from

one hand to other.

100% Tie off shall be ensured with life

line and use of harness be ensured.

No simultaneous activity shall be

carried out during scaffold dismantling.

Life line shall be fixed on permanent structure and certificates are available,

inspected and tightened properly.

No scaffold dismantling shall be done during poor illumination, rain or sand

storms.

Proper illumination shall be provided for safe execution of job.

HSE Manager/

Committee

6 Months

39

5.2 HEALTH AND WELFARE HAZARD

Risk Assessment Justification: Uses of hazardous chemicals.

The reason for selecting the use of chemicals is because, it is highly hazardous in nature such flammability, oxidizing, toxic and irritant in nature and the activity takes place inside a confined space and which is increasing the risk to operatives and may result in potential serious incidents.

RISK ASSESSMENT

TITLE OF THE ACTIVITY: MANHOLE WATER PROFING

ASSESSOR: Risk Assessment Committee

Activity Sequence

Hazards How might harm be caused

Persons at risk

Existing control

measures S L

R R

Proposed control measures (If any) Reviewed/

Action

Application of fiber glass lamination compound for water proofing inside man-hole chamber.

Confined space and hazardous chemicals

Generation of poisonous or hazardous

vapors.

Inhalation can cause fainting

or collapse.

Chronic effect such as lung

cancer.

Other health hazards when in contact like skin and eye irritation, burn injuries or even death.

Employees involved in water proofing works, supervisor, other contractor.

MSDS of the chemicals is available.

COSHH assessment is carried out.

Supervision is available.

2 4

8

M E DIUM

The mixing procedures and other applicable control measures from MSDS and COSHH assessment shall

be followed.

COSHH and MSDS must be

communicated to all employees.

Safe storage procedures shall be

followed.

Select competent individuals to carry

out this task.

Suitable PPE such as impervious hand gloves, goggles, disposable cover all, RPE – such as specific filter masks.

HSE Manager/

Committee

6 Months

40

RISK ASSESSMENT: MANHOLE WATER PROFING

Activity Sequence

Hazards How might harm be caused

Persons at risk

Existing control

measures S L

R R

Proposed control measures (If any) Reviewed/

Action

Generation of hazardous vapors when applying lamination compounds.

Generation of poisonous or hazardous vapors can cause oxygen deficiency.

Inhalation can cause fainting or collapse.

Chronic effect such as lung cancer.

Other health hazards when in contact like skin and eye irritation, burn injuries or even death.

Employees involved in water proofing works.

Confined space Permit to work is available and following.

Engineering controls such as ventilation or extraction fans are provided and effective.

Gas detector is available and checking regularly.

2 4

8

M E DIUM

Reduce the storage quantity at work location.

Do not store chemicals inside chamber.

Only take required quantities for a period or shift.

Operatives involved in this task shall attend COSHH training.

Administrative controls such as regular break, job rotations, and appropriate welfare facilities shall be arranged.

Suitable PPE shall be provided such as RPE – filter masks, goggles, hand gloves, disposable coveralls.

Arrangements for emergency rescue like retrieval tripod with winch and attach safety harness.

Regular health screening and biological monitoring shall be carried out for operatives involved in this task.

First aider and facilities shall be arranged.

A standby man must be available at the entrance of confined space.

HSE Manager/

Committee

6 Months

41

66..00 CCOONNCCLLUUSSIIOONN

Overall project site have more numbers of issues which requires immediate corrective action. Employer’s responsibility must protect the workforce from workplace hazards that are present in the workplace and that is the management duty to ensure the protection measures are in place, which would beneficial to both workforce and to the organization. Management system follows the model of BS OHSAS 18001:2007 Management System and is a part of the Integrated Management System operated by the Company.

A thorough study into the organization policy, structure and management system documents and OHS Management system records was carried out, a detailed gap analysis to find out the status of the gaps in the existing management system in comparison to the original standard clauses was carried out and findings in the gap analysis were recorded, a complete health and safety management system does exist but lends itself to improvements. Legal and other requirements taken into account in the Health and Safety Management System was verified and found to be complying with the legal requirements. Method Statements of various activities are available; risk assessments are carried out by the safety committee members and communicated to the work force before start of the activity by the Supervisors and Site Safety advisor. Tool box talks on general Health and Safety topics are being conducted every day and records thereof are available.

Training on Confined space entry by Competent authority was carried out only once for a handful of people on projects. During interviews with workers it was found that their understanding of the extent of tool box talk’s content was limited and hence they do not fully understand the safe system of work. The Emergency Response Plan is available in the health and safety plan but emergency response drills are held only for fire.

Conclusion for physical and health hazard there were several activities taking place during site inspection in full operational stage of construction and overall performance on health and safety was identified in good order. The results of hazard identification and its consequence, locations were detailed on the above report. From hazard identification two major hazards are selected from Physical hazard and Health/ Welfare Hazard, such as unsafe scaffoldings and use of hazardous chemicals inside a confined space.

The major physical hazard observed in the scaffolding erections are those erected scaffolds unsafely, and obviously showing erected by incompetent, untrained and uncertified personnel who are continuously ignored by site management. The consequences of this hazard can be fatalities, serious injuries such as loss of limbs, loss of production, damages to company properties. Therefore based on the results of risk assessment process and necessary recommendations are given below to control and reduce the incidents. Action plan are also available for taking necessary actions based on the recommendation, with the priorities, costs, time scale and responsible person.

The major health and welfare hazard observed whilst application of fiber glass lamination compound, for water proofing inside man-hole chambers, using chemical having hazardous property, flammable, oxidizing, toxic, and irritant in nature. The major hazards of these operations are generation of hazardous vapors whilst mixing lamination compounds and applying it inside the man-hole chamber. The consequences of this hazard can be fatalities, chronic health effects can result in lung cancer, fibrosis by inhalation, other health hazards such as skin and eye irritations, can be dermatitis, and other physical injuries can be fainting or collapse of individual. Accident /incident statistics were studied which reveal a steady decrease since the last few years.

Health and welfare hazards, based on the results of risk assessment process necessary recommendations are given below to reduce the incident of occurrence. Action plan are also available for taking necessary actions based on the recommendation, with priority, costs, time scale and responsible person. In addition to that recommendation within this report must have workplace risk assessment, awareness and training programmes, tool box talks etc should be implemented.

42

77..00 RREECCOOMMMMEENNDDAATTIIOONNSS

The recommendations have been prepared relevant to BS OHSAS 18001: 2007 in order to improve Occupational Health and Safety management system and the result of review from gap analysis findings including risk assessment for physical and health/welfare hazards are

listed below:

Recommendations for Management system:

1. Inadequacy of OHS Policy needs to be made specific in its nature, scale of operations and set a frame work to measure the achievement of its objectives.

If these are not clear and specific to its nature, gaps will remain and procedures will be deficient and it cannot be measurable to meet the objectives.

2. Majority of the workforce with different nationalities cannot read and understand the policy statement in English. It should be translated to their mother tongue which could be understood by workers and display at all conspicuous location.

3. Hazard identification and risk assessments need to be conducted whenever there is a change of key personnel, new equipment, new rules, procedures and premises so that foreseeable hazards like sudden adverse weather conditions, dust storms, transport accidents and their associated health risks must be included in hazard identification and risk assessment.

4. Multinational workforce, civilization, language barrier and unskilled, the aspect of their capabilities, competency levels, behavioral/attitudes and other factors should considered while identifying and assessing hazards and associated risks.

The organization need to establish minimum competency criteria for each employee roles related to training, experience, skills and abilities before giving them any responsibilities.

5. PPE effective guidelines and their standardization should be included in the procedure to review in order to develop the proactive approach by suggesting control measures in accordance with the Hierarchy of risk reduction principles.

6. OHS objectives in the company need to be clearly defined regarding relevant functions and level of classification to make them comprehensive.

The management representative shall need to undergo OHSAS 18001:2007 lead auditor training to set down the OHS Objectives and Programmes as per OHSAS 18001 requirements.

7. Role of line management towards their responsibility for implementation of OHS standards need to be clearly defined and monitored.

Clear role of line responsibilities for implementation needs to be monitored otherwise line Managers and line site staffs will not be responsible and accountable. Identify nonconformities and appropriate disciplinary action should be imposed to ensure compliance in OH&S.

8. Supervisors tend to compromise safety for production by involving workers to take short cuts and circumvent safe working procedures during the time of pressure for job completion.

Therefore it is very essential that all supervisors should undergo training in IOSH Managing Safely before allowing them to work in the projects.

9. During interviews with the workers it was found that their understanding of the extent of tool box talks was limited. In this issue working safely cannot be ensured and accidents and injuries will be imminent.

43

Plan for a clear documented identification of training needs which can be used in preparing a training programme for particular weak areas like specific training for particular job etc.

This will help to improve the competence and skills required expected by the company.

10. The safety committee members need to be trained further to enhance skills on communication and consultations to get the effective involvement of employees and sub-contractors.

11. Procedure for maintenance operation need to be properly documented and Work Permits must be closed after completion of the site activities.

12. Key personnel of the line management need specific training to be conducted on the basis of accident/incident investigation and corresponding corrective and preventive actions to be taken.

This will improve the quality of root cause analysis and lead to better corrective and preventive actions being taken , thereby reducing the incidence rate and lost time injuries.

13. Records not available for monitoring OHS performance & the monitoring of OHS Objectives at site.

All site and departments need to be monitored periodically and observations communicated to them for improving the performance.

14. The quality of proactive performance measures for line responsibilities concerning OHS were need to be properly monitored.

Establish a Key Performance Indicator (KPI) for employees to identify their individual performance so as to ensure their commitment concerning health and safety.

15. Should develop clear procedural guidelines for proactive identification of nonconformity and corrective actions and preventive actions. Follow up and maintain record for compliance.

16. The status of management review implementation need to be further expanded to include all departmental heads and site management so as to cover the overall OHS performance of the organization.

A continual improvement is a prime important requirement as per OHSAS 18001:2007. By reviewing and taking necessary action in weak area so as to ensure adherence and achieving the objectives.

Physical Hazard in scaffolding activity where there is a high potential risk of fall of

operatives.

Based on the hazard identification and risk assessment process and analyzing the existing control measures additional control measures have been recommended to minimize the

serious injuries or fatality to individuals are listed below:

1. Plan in advance for scaffolding erection and usage and ensure competent operatives shall be deployed in such activity.

2. Arrangements of training need for scaffolding operatives from approved Third Party Company & obtain certificates.

3. Introduce Permit to Work System to site management for scaffolding activity & ensure compliance.

4. Scaffolding operatives shall need to secure hand tools while on scaffolding to avoid fall of tools from height.

44

5. Regular inspection on scaffolding and its component parts shall be conducted in order to avoid usage of defective accessories during erection. Defective and rejected scaffolding parts shall not be stored on site.

6. Organize housekeeping team for proper stacking & shifting of scaffold materials to safe designated area.

7. Provision of information to all line responsibility regarding the risk in Mobile tower scaffold working under overhead power lines.

8. Provision of information, communication and restriction for working scaffold during poor illumination and after heavy rain falls.

9. Provision of protection caps for protruding steel re-bars at the surrounding area of scaffolding erection.

Health and Welfare Hazard in confined space carrying out fiber glass lamination inside the man-hole chambers, using resins and fibers for water proofing.

The following are additional recommendations to prevent any serious potential injuries to

operatives are listed below:

1. Provision of suitable and sufficient PPEs for the task such as disposable coverall, impervious hand gloves, goggles, respiratory protective equipment.

2. Provision of emergency rescue equipment such as retrieval tripod with winch. Training can be done by supplier and internal.

3. Arrangement of refresher training for operatives involved to COSHH and mixing of chemicals.

4. Introduce Permit to Work System to site management for confined space activity & ensure compliance.

5. Provision of competent first aider and emergency arrangements.

6. System for regular health screening and biological monitoring shall be arranged as the operatives involved in frequent use of highly hazardous chemical.

7. Arrangement of job rotation in confined space activity and provision of entrant person for emergency requirement.

8. Provision of appropriate chemical storage with COSHH store container, adequate firefighting equipment & warning sign.

These recommendations can be done without requiring a high cost and by doing this it will enhance the production smoothly and protecting the workers from injuries and other ill-health.

45

88..00 AACCTTIIOONN PPLLAANN

8.1 ACTION PLAN FOR MANAGEMENT SYSTEM

SN RECOMMENDATIONS ACTION(S) TIME

SCALE RESPONSIBILITY COST

REVIEW BY & DATE

1

Inadequacy of OHS Policy needs to be made specific in its nature, scale of operations and set a frame work to measure the achievement of its objectives.

Amend the policy and consult all departmental heads considering the risks in every operation.

2 Month

TOP Management

and HSE Manager

10,000/-AED

Managing Director

(MD), CEO

25-April-16

2

In line with the legal requirements of OHS Policy written in English only it should be translated according to worker’s languages and displayed in all conspicuous locations.

Prepare translated versions and arrange distribution to all departments

1 Month Management

Representative and HSE Manager

10,000/-AED

MD, CEO & HSE

Manager

25-Mar-16

3

Make Hazard Identification and Risk Assessments more comprehensive and include all routine & non routine activities to identify foreseeable hazards like weather conditions, dust storms, vehicle accidents etc must be included.

Project manager to review their risk assessments whenever required and improve to ensure its effectiveness.

Keep up to date regularly whenever a change occurs.

1 Month Project manager &

HSE Manager 2,000/-AED

HSE Committee

25-Mar-16

4

Multinational workforce, civilization, language barrier and unskilled, the aspect of their capabilities, competency levels, behavioral/attitudes and other factors should considered while identifying and assessing hazards and associated risks.

Establish minimum competency criteria for each employee roles related to training, experience, skills and abilities before giving them any responsibilities.

1 Month Project manager &

HSE Manager 20,000/-

AED

HSE Committee

25-Mar-16

46

SN RECOMMENDATIONS (Management System)

ACTION(S) TIME

SCALE RESPONSIBILITY COST

REVIEW BY & DATE

5

PPE effective guidelines and their standardization should be included in the procedure to review in order to develop the proactive approach by suggesting control measures in accordance with the Hierarchy of risk reduction principles

HSE manager with the coordination of procurement manager has to ensure this standardization

1 Month

Project manager, HSE Manager &

Procurement Manager

250,000/-AED

HSE Committee

25-Mar-16

6

OHS objectives in the company needs to be clearly defined its implementation regarding relevant functions and level of classification to make them comprehensive.

Management representative shall need to undergo OHSAS 18001:2007 lead auditor training to set down the OHS Objectives and Programmes as per

OHSAS 18001 requirements

1 Month Top Management 20,000/-

AED

MD, CEO

26-Mar-16

7

Clear role of line responsibilities for implementation needs to be clearly defined, monitor their performance and to identify non conformities.

Amend the procedure and monitor the performance and appropriate disciplinary action should be imposed to ensure compliance.

1 Month Top Management and Department

heads

15,000/-AED

MD, CEO

25-Mar-16

8

The malpractices of Supervisors by getting involve the operatives to take short cuts or circumventing safe working procedures must be curbed immediately.

Train Supervisors by attending IOSH– Managing safely

Internal behavioral based safety training including Moral, legal and financial obligation towards the work force.

1 Month Project director

and Project Manager

20,000/-AED

HSE Committee

25-Mar-16

47

SN RECOMMENDATIONS (Management System)

ACTION(S) TIME

SCALE RESPONSIBILITY COST

REVIEW BY & DATE

9

Quality of training needs for Supervisors and Safety advisors for improving their communication abilities to ensure that operatives have clear understanding of the content of tool box talk.

Project managers must make random checks to ensure the achievement of its purpose.

1 Month Project Manager &

HSE Manager 30,000/-

AED

HSE Committee

25-Mar-16

10

The safety committee members need to be trained further to enhance skills on communication and consultations to get the effective involvement of employees and sub-contractors.

Safety committee members shall need to undergo training for improving their communication skills.

1 Week

Top Management Project director

and Project Manager

20,000/-AED

MD, CEO

25-May-16

11

Procedure for maintenance operation need to be properly documented and Work Permits must be closed after completion of the site activities.

Give internal training to all concerned persons to make them aware of the consequences and be familiar with the procedures and other legal requirements.

1 Week Project director,

Project Manager & HSE Manager

5,000/-AED

HSE Committee

25-Mar-16

12

Arrangement of training needs for investigation of accidents and near miss incidents to improve the quality of root cause analysis and lead to better corrective & preventive actions to be taken.

Identify trainees and train all line responsibilities as recommended.

1 Month Project Manager &

HSE Manager 20,000/-AED

HSE Committee

25-Mar-16

48

SN RECOMMENDATIONS (Management System)

ACTION(S) TIME

SCALE RESPONSIBILITY COST REVIEW

BY & DATE

13

The management shall need to review the overall OHS performance of the organization on regular basis as a requirement relevant to OHSAS 18001:2007 concerning continual improvement.

Organize a management review as prescribed by OHSAS 18001.

Prepare a continual improvement plan and communicate to all line responsibilities for compliance.

1 Month TOP Management and HSE Manager

2,000/-AED

MD, CEO & HSE

Manager

25-Mar-16

14

Establish a Key Performance Indicator (KPI) for all employees to identify their individual performance so as to ensure their commitment concerning health and safety.

Health and Safety KPIs to be embedded in employees overall KPIs.

1 month

General Manager, Human resource and departmental Managers

1500/-AED

MD, CEO & HSE

Manager

25-Mar-16

15

Develop a clear procedural guideline for proactive identification of nonconformity and corrective actions and preventive actions.

Follow up and maintain record for compliance 1 month

General Manager, Human resource and departmental Managers

1500/-AED

MD, CEO & HSE

Manager

25-Mar-16

16

Management review implementation need to be further expanded to include all departmental heads and site management so as to cover the overall OHS performance of the organization.

Take necessary action in weak area so as to ensure adherence in achieving the objectives.

1 Month TOP Management and Human resource

5,000/-AED

HSE Committee

25-Mar-16

49

8.2 ACTION PLAN FOR HAZARDS AND RISKS

8.2.1 PHYSICAL H AZARDS

SN RECOMMENDATIONS ACTION (S) TIME

SCALE RESPONSIBILITY COST SUCCESS

CRITERIA

REVIEW

BY & DATE

1

Plan in advance for scaffolding erection and usage and ensure competent operatives shall be deployed in such activity.

Project Manager in coordination with the Engineers shall deploy operatives as recommended.

1 Month Project Manager &

Engineers 500/-

TBT conducted

in daily basis & recorded

HSE Committee

25-Mar-16

2

Arrangement of training for scaffolding operatives from approved third party company & obtains certificates.

Contact approved third party company scaffolding training provider.

2 Weeks Project Director & Project Manager

65,000/-

Training approval &

training certificates

HSE Committee

10-Mar-16

3

Introduce Permit to Work System to site management for scaffolding activity & ensure compliance.

Monitor the compliance of Permit to Work System in scaffolding activity.

1 week

HSE Manager, Project Manager &

Engineers 5,000/-

Record is maintained

HSE Committee

03-Mar-16

4

Scaffolding operatives need to secure hand tools while on scaffolding to avoid fall of tools from height.

Line responsibility shall monitor the compliance as recommended.

1 week

Construction Manager & Engineers

6,500/- Compliance monitoring

Line Managers & HSE Dept.

03-Mar-16

5

Organize housekeeping team for proper stacking & shifting of scaffold materials to safe designated area.

Introduce housekeeping inspection checklist & enforce them. Monitoring shall be done by the Engineers.

1 week Project Manager &

Engineers 50,000/-

Compliance monitoring & record

HSE Committee

03-Mar-16

50

SN RECOMMENDATIONS

(Physical Hazards) ACTION(S)

TIME

SCALE RESPONSIBILITY COST

SUCCESS

CRITERIA

REVIEW BY & DATE

6

Regular inspection on scaffolding and its component parts shall be conducted in order to avoid usage of defective components during erection. Defective/ rejected scaffolding parts shall not be stored on site.

Develop scaffold inspection format & implement them.

Communicate to line responsibility

Ensure monitoring of this procedures

1 Week Project Manager &

Engineers 6,000/-

Record is Maintained

Compliance Monitoring

HSE Committee

03-Mar-16

7

Provision of information to all line responsibility regarding the risk in Mobile tower scaffold working under overhead power lines.

Send a circular to all Engineers and Supervisors advising them to involve in such activities.

1 week Engineers/ Supervisors

1,000/-

Compliance monitoring & record

Line Managers & HSE Dept.

03-Mar-16

8

Provision of information, communication and restriction for working scaffold during poor illumination, adverse weather condition and after heavy rain falls.

Advise site management for strict compliance

1 week Project Manager &

Engineers 1,000/-

Compliance monitoring & record

Line Managers & HSE Dept. 03-Mar-16

9

Provision of protection caps for protruding steel re-bars at the surrounding area of scaffolding erection.

Purchase suitable steel protection caps or protect them by any practicable means

1 week Project Manager &

Engineers 6,000 /-

Procurement of new material

HSE Committee

03-Mar-16

51

8.2.2 HEALTH AND WELFARE H AZARDS

SN RECOMMENDATIONS ACTION(S) TIME

SCALE RESPONSIBILITY COST

SUCCESS CRITERIA

REVIEW BY & DATE

1

Provision of appropriate PPEs for the task such as disposable coverall, shoe, hand gloves, goggles and respiratory protective equipment.

Purchase of suitable and sufficient PPEs 1 week

Project Manager & Procurement

manager 40,000/-

Provided & Maintained

HSE Committee

03-Mar-16

2

Provision of emergency rescue equipment such as retrieval tripod with winch. Training can be done by supplier and internal.

Purchase of appropriate rescue emergency equipment & training arrangement.

1 week

Project Manager & Procurement

manager 60,500/-

Provided & Maintained

HSE Committee

03-Mar-16

3 Arrangement of refresher training for operatives involved to COSHH and mixing of chemicals.

Conduct awareness training about using chemicals.

2 weeks Project Manager &

HSE Manager 10,000/-

Trained & Maintain record

HSE Committee

10-Mar-16

4

Introduce Permit to Work System to site management for confined space activity & ensure compliance.

HSE Manager shall incorporate the implementation & monitoring system.

1 week Project Manager &

HSE Manager 3,000/-

Trained & Maintain record

HSE Committee

03-Mar-16

5 Provision of competent First Aider and emergency arrangements

Appoint competent/trained first aider and provide first aid arrangement.

2 week Project Manager & Health Coordinator

200,000/- Trained

HSE Committee

10-Mar-16

6

System for regular health screening and biological monitoring shall be arranged as the operatives involved in frequent use of highly hazardous chemical.

Initiate in conducting & monitoring to this activity.

1 week Project Manager & Health Coordinator

10,000/- Arranged & Monitored

HSE Committee

03-Mar-16

52

99..00 RREEFFEERREENNCCEESS // BBIIBBLLIIOOGGRRAAPPHHYY

1. Health and Safety at Work at Act 1974.

2. Health and Safety Executive Guidance - HSG 65.

3. Industrial Guidelines - INDG 163.

4. The management of Health and Safety Regulations 1999.

5. Workplace Health, Safety and Welfare Regulations 1992.

6. Control of Substances Hazardous to Health and Safety Regulations (COSHH) 2002.

7. Electricity and Work Regulations 1989.

8. Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 1995.

9. Handling Operations Regulations 1992.

10. Health and Safety (First Aid) Regulations 1981.

11. Provision and Use of Work Equipment Regulations (PUWER) 1998.

12. The Lifting Operations and Lifting Equipment Regulations 1998.

13. The Working at height Regulations 2005.

14. International Labor Organization (ILO) Convention C155 and C174.

15. UAE Ministerial Order No. 32 1892 – Protection and Care of Workers.

16. UAE Federal Law No. 8 1980 – Chapter 5 Safety, Protection and their Health and Social Care of the Employees.

SN RECOMMENDATIONS (Health and Welfare Hazards)

ACTION(S) TIME

SCALE RESPONSIBILITY COST

SUCCESS CRITERIA

REVIEW BY & DATE

7

Arrangement of job rotation in confined space activity and provision of entrant person for

emergency requirement.

Line Manager & HSE staff shall incorporate in monitoring this activity.

1 week

Project Manager and Competent

Supervisor 1,500/-

Arranged & Monitored

HSE Committee

03-Mar-16

8

Provision of appropriate chemical storage with COSHH store container, adequate firefighting equipment & warning sign.

Construct of appropriate chemical storage and purchase adequate fire fighting equipment &

warning signage.

2 week Project Manager &

Procurement Manager

60,000/- Provided & Monitored

HSE Committee

10-Mar-16

53

1100.. AAPPPPEENNDDIICCEESS

ALARP – As Low as Reasonably Practicable

HSE- Health Safety and Environment

HAVS- Hand - Arm Vibration Syndromes

WULRD- Work Relate Upper Limb Disorder

PPE- Personal Protective Equipment

RPE- Respiratory Protective Equipment

OH&S- Occupational Health and Safety

OHSAS-18001-Occupational Health and Safety Assessment Series

QA- Quality Assurance

QC- Quality Control

CAPA- Corrective Action and Preventive Action

SOR- Safety Observation Report

OSHA- Occupational Safety and Health Administration

EPCM- Engineering, Procurement and Construction management

PMI- Positive Material Inspection

FDT- Field Density Test

ILO- International Labour Organization

HSG- Health and Safety Guidelines

PDCA- Plan, Do, Check and Act

MSDS- Material Safety Data Sheet

HAZOP- Hazard and Operability Study

PTW- Permit to Work

JCB- Back Hoe

PRV- Pressure Relive Valve

UV- Ultra Violet Radiation

IR – Infra Red Radiation

DNA-Deoxyribonucleic Acid (Molecule)

IMS- Integrated Management system

ISO- International Standard Organization

EPD- Electronic Personal Dosimeter

TLD- Thermo Luminescent Dosimeter

MPI– Magnet Particle Inspection

JSA- Job safety analysis NDT- Non-Destructive Testing

SMART- Specific, Measureable, Achievable, Realistic and Time Scale (Objectives)

Websites:

1. www.ilo.org

2. www.hse.gov.uk

54