How to Develop a Safe Operating Procedure

Transcription

1 How to Develop a Safe Operating Procedure A guide to researching, creating and issuing safe operating procedures in your workplace from start to finish. Michael Selinger Partner, Holding Redlich Lawyers simplify your business portnerpress.com.au

2 2014 Portner Press Pty Ltd. All rights reserved. No part of this publication may be reproduced or transmitted in any form by means electronic or mechanical, including recording, photocopying, or via a computerised or electronic storage or retrieval system, without permission granted in writing from the publisher. The information in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. No action or inaction should be taken based solely on the contents of this publication; instead readers should consult with appropriate professionals on any matter relating to health and safety in the workplace. The information and opinions provided are believed to be accurate and sound, based on the best judgments available to the authors at the time the publication went to print. We do not guarantee that the information is accurate at the date it is received or that it will continue to be accurate in the future. The publisher is not responsible for any errors or omissions. If you have any subscription queries, please contact Customer Services on We may monitor and record calls to maintain and improve our service. Publisher: Pippa McKee Associate Publisher: Joanna Weekes Sub-Editor: Alanna Furlan Consultant: Michael Selinger For editorial queries please us at: cs@portnerpress.com.au Portner Press Pty Ltd Bridport Street Albert Park VIC 3206 ACN ISBN

3 CONTENTS Are you the right person to develop the safe operating procedure?... 2 What is a safe operating procedure?... 2 Why do you need safe operating procedures?... 3 Who do safe operating procedures apply to?... 4 Step-by-Step: How to develop a safe operating procedure... 4 Template: Hazard Register Sample: Safe Operating Procedure Template: Document Control Register Template: Training and Induction Record

4 ARE YOU THE RIGHT PERSON TO DEVELOP THE SAFE OPERATING PROCEDURE? Safe operating procedures should be developed by someone experienced in the task The person who will develop and write safe operating procedures for your business should be experienced at performing the type of work for which the procedure is being developed. Therefore, you may find it beneficial to have different staff members develop the safe operating procedures in different tasks and areas of your business, and then have one person oversee the development of all the safe operating procedures to ensure consistency, e.g. the health and safety coordinator. The person developing the safe operating procedure will also need to consult with other workers who are familiar with the task and draw on observations, knowledge and experience to identify hazards effectively. Important: If the work is particularly complex, or involves specialised knowledge, the safe operating procedure should be written by (or with the assistance of) a technical expert. WHAT IS A SAFE OPERATING PROCEDURE? Definition: Safe Operating Procedure A safe operating procedure is a written document that provides stepby-step instructions on how to safely perform a task or activity in the workplace. A safe operating procedure should be used for tasks and activities in your workplace that are undertaken on a regular basis and require workers to follow step-by-step procedures to ensure the task is carried out safely, e.g. cleaning a deep fat fryer (see page 16 for a sample). Caution: A safe operating procedure should not be a generic document, but one specific to the work you carry out. It should be created after undertaking a risk assessment for the task. 2

5 To develop your safe operating procedure, you need to: undertake hazard and risk identification for the particular work task; choose and implement control measures for those risks; and document the step-by-step procedure for carrying out the work and incorporate the control measures to minimise the risk. Identify hazards and risks for all tasks that are performed Important: Make sure you have procedures in place to regularly monitor and review the safe operating procedures you have developed to ensure that the procedures remain effective. Once developed, the safe operating procedure will demonstrate that you have taken into account any particular hazards that might affect the work you carry out and how you control risks associated with each task. WHY DO YOU NEED SAFE OPERATING PROCEDURES? As part of your duty of care under health and safety legislation, you are required to provide and maintain a safe environment for anybody who enters your workplace, including contractors and visitors. Documenting procedures and eliminating unplanned approaches to health and safety are a vital part of this responsibility. The benefits of developing safe operating procedures include that they: are regarded by law as an important aspect of complying with an employer s general duty to protect their workers and others in the workplace; You are required to protect the safety of all people who enter your workplace result in management having a better understanding of operational risks; reduce the risk of illness and injury in the workplace; raise awareness of health and safety among workers; demonstrate your business s commitment to improving safety in the workplace; 3

6 Benefits of developing safe operating procedures help to train workers to consider the steps required to perform their jobs safely; and improve communication among workers and between workers and supervisors. WHO DO SAFE OPERATING PROCEDURES APPLY TO? All workers (including contractors) must be inducted and given regular training in the safe operating procedures that apply to their work tasks. You must have evidence that they are competent in these procedures. Important: Under health and safety legislation, a workplace is any place where work is performed. If your workers perform some of their work from home or on the road (e.g. as a courier), your health and safety obligations extend to these workplaces and you also need to create safe operating procedures for those home office environments and motor vehicles. STEP-BY-STEP: HOW TO DEVELOP A SAFE OPERATING PROCEDURE Safe operating procedures should be created for all major work processes in your workplace that involve risk. Important: Existing safe operating procedures should be reviewed and new procedures should be developed whenever a change is introduced in the workplace, e.g. when a new job or procedure is adopted or when new equipment or substances are introduced. Develop a new safe operating procedure each time a change is introduced Step 1: Familiarise yourself with how a safe operating procedure should be written Explanations of the way a work process should be carried out should outline in a clear and simple way how the user should perform the task so that the task can be completed in a safe and legally compliant manner. 4

7 Important: The safe operating procedure should be written in a way that gives the person performing the task complete information on how to safely undertake the task without needing to refer to other resources. An effective safe operating procedure must: be specific and provide step-by-step instructions; be written so that a person who has no prior knowledge of the job can follow the safe operating procedure without difficulty; How to write effective safe operating procedures use language that is clear and appropriately adapted to the likely user (i.e. the worker who will undertake the task), opting for simplicity wherever possible; and if necessary, use photographs or diagrams to provide clarity or identify particular components in the safe operating procedure. Caution: If there are discrepancies between levels of literacy or different native languages among your workers and contractors, you must communicate your safe operating procedures in appropriate ways so that they are understood by everyone. This may require the safe operating procedure to be written in a number of languages or by using additional diagrams or photographs where appropriate. Step 2: Identify all critical tasks in your workplace Identify all critical tasks and activities carried out in the operation of your business. Each of these tasks may require a safe operating procedure. Definition: Critical Task A critical task is a task or activity that the business performs on a regular basis and is fundamental to the business s operation. Critical tasks can be identified through observation and knowledge of workplace operations. 5

8 Tip: If you are not confident in identifying critical tasks and developing appropriate safe operating procedures for your business, you can engage an independent consultant to assist you with this process. Step 3: Conduct a risk assessment to determine which critical tasks need to be prioritised Once you have identified the critical tasks in your workplace, you need to determine which of these tasks have the highest level of risk and this will determine the order you prioritise the development of your safe operating procedures. To do this, you need to conduct a risk assessment of each critical task to determine: the likelihood of a risk occurring; and the seriousness of any possible outcomes. Prioritise hazardous tasks when developing safe operating procedures When determining which critical tasks need a safe operating procedure developed as a priority, focus on the most hazardous activities, e.g. critical tasks that involve working with mobile plant such as forklifts, working at heights or operating machinery. If there is a high chance of a hazard causing an injury or illness, and the injury or illness is likely to be serious or even fatal, that hazard should be addressed first. When reviewing critical tasks to determine priorities, you must consult the affected workers and supervisors who work in the area you are assessing. These people often have greater knowledge of the task and can help identify activities that carry greater risk. Tip: Reviewing work injury and illness statistics (in the injury register) and looking at incident investigation reports can help determine which critical tasks in your workplace have the highest risk of injury. Caution: Any change in the task or plant will require you to develop additional safe operating procedures to identify and address any new hazards that have been introduced. 6

9 Important: Address the most serious risks first. Step 4: Break up each critical task into operational steps For each critical task you identify, you need to divide the task into a number of operational steps. Doing this will assist you in drafting step-by-step instructions so that the task can be performed safely. Within each of these operational steps there may be a number of separate steps required to ensure the task is safely performed. Example There may be a risk to a picker working in the warehouse floor of being struck by a forklift, as well as manual handling risks if too many items are picked up. The steps involved in that process may require the worker to: 1. Keep a proper look out for mobile plant before entering the factory floor. 2. Approach the picking site by a designated walkway. 3. Only pick two items at a time. Example: Breaking up a task into operational steps 4. Move the items to the packaging section of the warehouse by placing the items on a pallet. Additionally, each critical task may have associated tasks that will require a safe operating procedure. For example, operating and maintaining machinery may have a number of associated tasks which require separate safe operating procedures, such as: cleaning processes; breakdown issues; maintenance; and quality inspection. These separate documents will form part of the overall safe operating procedure for the critical task. See the sample on page 16. 7

10 Step 5: Identify all the hazards associated with each operational step A detailed hazard identification process for each operational step is the foundation for developing a safe operating procedure. At this point, you should also review accident history (including near misses) related to the operational step and conduct a review of the task, consulting workers who regularly perform work of that kind. A single task may require separate controls for each hazard For each operational step, make records of the associated hazards direct and indirect these may need to be controlled separately. For example, an operational step might include a direct hazard of amputation when the equipment is operating, but also involve an indirect hazard caused by noise exposure from the equipment that also needs to be controlled. Tip: Make records of the hazards and risk control measures and base the operational steps in the safe operating procedure around these to ensure that you develop an effective procedure. See page 15 for a template hazard register. To determine the hazards associated with an operational step, you need to ask questions that are relevant to the task, such as: Could the worker trip or fall? Could the worker be struck by a falling object? Consider these questions in relation to each operational step Could the worker fall from a height? Is lighting adequate? Could clothing or a body part get caught in the moving parts of a machine? Could debris fly out from the machinery? Are there any live electrical hazards in the vicinity? Is there excessive noise or dust in the work area? Could the worker come into contact with chemical or biological hazards? 8

11 Is ventilation adequate, particularly if the worker is in a confined or enclosed space? Are employees wearing suitable personal protective equipment (PPE) for the work? Could employees come into contact with moving vehicles, such as forklifts? Does the job involve hazardous manual handling, such as lifting heavy boxes? Consider questions such as these to determine what hazards exist Does the body position or location create a hazard? Will interaction with surrounding activities create a hazard? Definition: Personal Protective Equipment (PPE) Personal protective equipment is equipment used or clothing worn by workers to reduce the risk of illness or injury from exposure to workplace hazards. Tip: When identifying the hazards associated with each operational step, consider the different ways that hazards may arise. These could include mechanical hazards (e.g. rotating parts, sharp edges, etc.), environmental hazards (e.g. noise, temperature and terrain) or ergonomic hazards (e.g. awkward working postures, strains from lifting, etc.). Step 6: Choose risk controls for the identified hazards Each identified hazard must be accompanied by the precautions and control measures which, when carried out by the operator, will either eliminate the hazard or reduce the hazard to an acceptable level. After you have listed each hazard, determine whether the job can be performed in another way that eliminates the risk. If this is not possible, use the hierarchy of control to determine control measures to reduce the risk of injury or illness. Can the job be performed in a way that eliminates risk? 9

12 To use the hierarchy of control, consider each hazard and ask, in this order: Using the hierarchy of control to reduce risks 1. Can the hazard be removed completely (e.g. by modifying equipment, choosing a different process or removing people from the hazard)? 2. Can the hazard be isolated (e.g. by only cleaning the machine when it s switched off and tagged)? 3. Can risk controls be engineered (e.g. safeguarding)? 4. Can you think of ways to reduce exposure to the hazard (e.g. by using protective equipment and/or performing the task for shorter periods of time)? Tip: If you are considering a new procedure for performing a job, discuss it with relevant workers. Their feedback and recommendations will be invaluable for fine-tuning the safe operating procedure. Important: Safe operating procedures are specific to particular tasks and pieces of machinery in the workplace. A different safe operating procedure should be drawn up for every task and piece of machinery, even if there are only small differences between them. Any change in the job process should also involve a review of the adequacy of any existing safe operating procedure. Tip: Warnings about performing particular tasks provide further information to enable workers to perform the task safely. For example, when working in a noisy environment, a general caution about wearing ear protection should be included in your safe operating procedure. Include information about mandatory safety matters Additionally, mandatory safety matters should be referenced at the start of any safe operating procedure document, such as the need for the operator to be: licensed; or wearing correct PPE, e.g. a seatbelt and a safety vest. 10

13 Step 7: Create and review the draft safe operating procedure Once you have collated all this information, develop a draft safe operating procedure and distribute it to all relevant workers to review the procedure and provide feedback. The aim of this is to ensure that the content is accurate and without gaps. Show drafts of the safe operating procedures to all workers who are likely to be involved in or affected by the task, including: operators; maintenance personnel; cleaners; supervisors; health and safety representatives (HSRs); and health and safety committee members. Make notes about any suggestions for how the safe operating procedure can be improved. Assess the feedback and adapt the draft by: collating all comments; and Obtain feedback on the safe operating procedure to ensure it is accurate and complete consulting further about suggested improvements. Step 8: Approve and issue for use Prior to a safe operating procedure being issued for use, all relevant staff members need to approve the final draft. Relevant staff members can include: the department manager or supervisor; an HSR; the health and safety committee; and/or a health and safety coordinator. A copy of the safe operating procedure should be: displayed in the work area where the procedure or task is undertaken, e.g. posted on the relevant piece of machinery; Make sure the safe operating procedure is displayed and easily accessible 11

14 stored in a suitable place for reference; and kept somewhere that all workers can access, e.g. on the company intranet. Step 9: Maintain control of documents Ensure that documents are adequately maintained To maintain control of documents, each safe operating procedure must be: dated; and assigned: a procedure number; a version number; a review date; and a copy number. Definition: Copy Number A copy number is a number allocated to the department where a safe operating procedure will be used. Important: Set up a document control register so that you know: which safe operating procedures have been issued; the date of issue; and who they have been issued to. The register should state how often the procedure will be reviewed and set out the next scheduled review date. See page 17 for a template document control register. Step 10: Train your workers in the safe operating procedure All workers must be instructed, trained and educated on the hazards of the tasks they are required to perform and how to follow the safe operating procedure. This instruction, education and training regime needs to be tested to ensure it has been effective. 12

15 Workers who are likely to perform a critical task in the future, and not just those who currently perform it, should be provided with training about the task s safe operating procedure. All new workers likely to perform the task must be instructed about the procedure as part of the induction process. Test your workers to ensure they understand how to safely perform tasks Important: Under the WHS Act, it is not enough to train workers (including contractors) on the safe operating procedures. You must also be sure they are competent and make records of their competency. A training and testing register that makes a record of when training and testing has been conducted should be kept in the safe operating procedure folder. Tip: Retain a record of the training and regularly test your workers knowledge of safe operating procedures to ensure the training has been adequate. You should keep a record of all test results. See page 18 for a template training and induction record. Step 11: Supervise workers and enforce safe operating procedures Regular supervision is necessary to ensure everyone who undertakes the critical task complies with the approved and documented safe operating procedure. Higher levels of supervision are required when: Supervise workers to ensure compliance the task is initially assessed; the task is complex and involves multiple risks; and inexperienced workers are expected to follow the safe operating procedure. Important: If an employee deviates from the written procedure, their supervisor should take immediate action to counsel or discipline them and show them the correct method of carrying out the task. Re-training may be required. 13

16 When should you review a safe operating procedure? Step 12: Review your safe operating procedures You should review your safe operating procedures if: you receive a request to do so from your workers or contractors, e.g. if there is a gap in the procedure which did not become apparent until later; you notice there is repeated non-compliance with the documented safe operating procedure this may indicate an error in content or a need to revise the procedure or re-train workers; there is a change to a task, process, plant or environment; there has been an incident involving the task, process or plant (whether it resulted in an injury or a near miss); there is fresh information about a hazard this information could come internally from a worker or externally from the safety regulator, manufacturer or industry association; or you have reached the time period specified by your document control register (typically every 1 2 years). 14

17 Click title to download TEMPLATE: HAZARD REGISTER HAZARD REGISTER [Insert description of critical task] Company name: Site name: Procedure no: Version no:. Copy no:.. Review date:. Critical Task: Basic steps Hazards Risk controls 15

18 SAMPLE: SAFE OPERATING PROCEDURE Click title to download Critical task: Cleaning the deep fat fryer Document no: 072 Date: 17/05/15 SAFE OPERATING PROCEDURE Personal protective equipment Wear the following personal protective equipment during all steps: goggles and face shield; elbow-length rubber gloves; a rubber apron long enough to cover your lower legs; and non-slip, closed-toe shoes. Task: Draining the hot oil from the deep fat fryer into a container 1. Allow the oil to cool as much as possible before removing it from the deep fat fryer. Turn off the fryer 3 hours ahead of time. 2. Use the designated metal container marked For Hot Oil Use. It has a metal lid, a handle at the base and is fitted with clasps. 3. Ensure that the container is dry. 4. Fit a hose to the drain spout of the fryer and carefully direct the oil into the container. Task: Transporting the oil through the kitchen and out to the oil dump drum 1. Make sure aisles and pathways are clear of tripping hazards and that the outdoor path to the drum is not slippery. 2. Make sure the container is closed properly. 3. Use a dolly to move the container. Make sure the container is securely fastened. Task: Transferring the oil from the container to the oil dump drum 1. Check that your personal protective equipment is properly adjusted to protect you from spills or splashes. 2. Grasp the handle at the base of the container as you pour the oil into the drum. Caution: Handle and dispose of hot oil safely. Many metal buckets have metal lids with clasps and a tight seal to prevent splashing. Newer fryers incorporate automatic draining systems that minimise the risk to workers. In addition, a variety of specialised equipment is available for safe handling and disposal of hot oil. Contact your local restaurant equipment supplier for more information. Source: WorkSafe ACT, 16

19 Click title to download TEMPLATE: DOCUMENT CONTROL REGISTER DOCUMENT CONTROL REGISTER Document name and number Location Initial issue date Current version issue date Review date Person responsible 17

20 TEMPLATE: TRAINING AND INDUCTION RECORD Click title to download TRAINING AND INDUCTION RECORD Name of trainee:... Name of trainer/s:... Induction Operation of Machinery Accident and Emergency Procedures Personal Protective Equipment First Aid Facilities Date and time completed:... Signature of trainee:... Signature of trainer:... Notes: Date and time completed:... Signature of trainee:... Signature of trainer:... Notes: Date and time completed:... Signature of trainee:... Signature of trainer:... Notes: Date and time completed:... Signature of trainee:... Signature of trainer:... Notes: Date and time completed:... Signature of trainee:... Signature of trainer:... Notes: