CS-OHS-11 (Amd 09/11) CS ENERGY PROCEDURE FOR A JOB SAFETY AND ENVIRONMENTAL ANALYSIS CS-OHS-11 Responsible Officer: Group Manager Health and Safety Approved: EGM Corporate CONTENTS 1 Purpose... 3 2 Context... 3 3 Scope... 3 4 Responsibilities... 3 4.1 General Manager... 3 4.2 Manager... 3 4.3 Superintendents and Supervisors... 4 4.4 Principal s Site Representative... 4 4.5 Health and Safety Specialists/Advisors... 4 4.6 Officers in Charge / Person in Charge of Work... 4 4.7 Work Party Members, Other Employees and Contractors... 4 5 Application... 5 5.1 When to Use a JSEA... 5 5.2 When to Modify a JSEA... 5 5.3 Completing a JSEA... 5 5.3.1 Identifying the Tasks for the Work Being Assessed... 5 5.3.2 Identifying Hazards and Environmental Impacts... 6 5.3.3 Assess the Risk Initial... 6 5.3.4 Determine the Control Measures... 6 5.3.5 Assess the Risk with the Control Measures Residual... 6 5.3.6 Checking, authorisation and sign-off... 7 6 Recording... 7 7 Monitoring and Review... 7 8 Training... 7 9 Reference Documentation... 8
10 Definitions... 8 11 Appendix 1 JSEA Flow Chart... 9 12 Appendix 2 Sample JSEA Form... 10 13 Appendix 3 JSEA Quality Checklist and Score... 14 Version History 4 Review of content to reflect Risk Management Framework by Risk and Assurance B Johnson 29.09.11 3 Updated to include latest risk management framework F Welch 14.03.11 2 Updated to include new JSEA form and consistent with training package F Welch 19.11.2008 1 Modified F Welch 21.10.2005 0 Issued for implementation F Welch 15.04.2003 Revision Description Originator Date Job Safety and Environmental Analysis, CS-OHS-11 2
1 PURPOSE The purpose of this procedure is to provide the minimum requirements for personnel to conduct a Job Safety and Environmental Analysis (JSEA) effectively across CS Energy sites. The aim of a Job Safety and Environmental Analysis is to evaluate, select, record and specify safe systems of work to eliminate or minimise the risk of injury, illness, hazard exposure, near miss, property damage, environmental impact and process loss in the performance of work and enable the work to be completed with the risk level as low as is reasonably practicable. 2 CONTEXT The JSEA is a formalised and structured process within the CS Energy risk management system following the standards set out in the CS Energy Risk Management Framework. It is an essential part of a safe system of work as it provides a process for hazard identification, risk assessment and implementing suitable control measures based on the hierarchy of control. It is a mandatory component of the Permit To Work (PTW) system. The JSEA is a higher level risk management tool to the Task Risk Analysis (TRA). While the TRA is the initial risk assessment tool for any work, its resulting outcome determines whether a JSEA is required, such as if the risk is significant or high and/or a PTW is required. The aim of the JSEA is to eliminate a hazard or where this is not possible; the risks associated with the hazard are reduced to as low as is reasonably practicable. 3 SCOPE This procedure applies to all CS Energy company employees, and any other persons working for, or on behalf of CS Energy and its associated operations. This procedure is not intended to consider specialist plant control, reliability, efficiency and risk analysis methods that may be used via specific and specialised risk management tools e.g. fault tree analysis, outcome analysis and hazard and operability studies. All personnel shall be informed of this procedure at induction. Additional competency based training shall be undertaken as part of the company health and safety training program. Contractors may use the risk analysis tool specific to their organisation, only if it does not compromise the integrity of the requirements of CS Energy s procedures and format, i.e. must include a breakdown of the task or activity, task steps, hazards identified, control measures proposed and an assessment of the risk outcome. These are to be approved by site management. 4 RESPONSIBILITIES 4.1 General Manager The General Manager is responsible for authorisation of any JSEA completed where the residual risk assessed is high. 4.2 Manager Managers are responsible for: implementation of this procedure; ensuring sufficient resources are provided to effectively conduct JSEAs; provision of appropriate training; authorisation of a completed JSEA where the residual risk is significant; and ensuring quality and effective JSEAs are carried out. Job Safety and Environmental Analysis, CS-OHS-11 3
4.3 Superintendents and Supervisors Superintendents and Supervisors are responsible for: monitoring compliance with this procedure and the risk control measures being implemented by the work party/team members; conducting periodic review of process, completed JSEA s for quality and adherence to the PTW scope of work and report on effectiveness and application; provision of appropriate training and other support to all personnel in application of this procedure; conducting and/or assisting personnel with JSEAs; and authorisation of a completed JSEA where the residual risk is moderate. 4.4 Principal s Site Representative The CS Energy principal s site representative is responsible for: ensuring contractors are aware of the requirement to provide JSEAs for the work they perform on site; reviewing contractors completed JSEAs for compliance with CS Energy s health and safety site rules and conditions; and obtaining assistance from the relevant site specialist, where necessary, to review and comment on contractor developed JSEAs. 4.5 Health and Safety Specialists/Advisors The Health and Safety Specialists/Advisors are responsible for: providing support and advice to personnel regarding a JSEA; periodic monitoring and review of completed JSEA s to the CS Energy standard; and ensure the procedure and form is relevant and current. 4.6 Officers in Charge / Person in Charge of Work Officers in Charge (OIC) and Persons in Control of Work (PCW) are responsible for: preparing the JSEA prior to the work being performed and modifying the JSEA if conditions or the scope of work change; involving team members or work party members in the development of the JSEA; seeking assistance from the technical/experienced persons on site in identifying hazards and implementing appropriate control measures; monitoring the work tasks to verify the control measures are implemented, effective and appropriate for the work; identifying any new hazards in the work activity that have been previously overlooked, have appeared due to a change in work conditions or if the controls put in place have not been effective in controlling the risk; and Communicating the JSEAs to work party team members via training and or site instruction. 4.7 Work Party Members, Other Employees and Contractors Work party members are responsible for: being involved in developing and reviewing the JSEA; knowing and understanding the hazards and control measures on the JSEA; asking their OIC/Supervisor if they are unsure about any control measures to be used; sign the JSEA sign on sheet, only once you are satisfied with the control measures, before commencing the activities; and Job Safety and Environmental Analysis, CS-OHS-11 4
during the work, notify the OIC/Supervisor if additional hazards are observed and further control measures need to be added to the JSEA. 5 APPLICATION The application and process steps outlined in this section are illustrated in Appendix 1, JSEA Flow Chart. 5.1 When to Use a JSEA A JSEA must be completed: (i) (ii) (iii) (iv) (v) (vi) (vii) (viii) (ix) for any work that is assessed with a residual risk rating as moderate, significant or high (following the outcomes from a TRA; refer to CS-OHS-46, Procedure for Conducting a 2X2 Task Risk Analysis); for any work requiring a PTW and prior to the issue of the PTW; before introducing any new plant, machinery, equipment, hazardous substances or work practices; prior to making design changes or modifications to plant or equipment that will affect the way the plant is used, the procedures associated with the plant or the location of the plant; when work activities or modifications to any plant or equipment has the potential to release a contaminant to the environment or storm water or to exceed site license conditions; prior to removing or installing safety features (guardrails, machinery guards, interlocks, covers, flooring); prior to conducting live electrical work; prior to performing work in proximity to or with bonded asbestos containing materials and friable asbestos; or prior to working with or adjacent to areas or plant with explosive atmospheres, excessive temperatures, vibration and flammable substances. 5.2 When to Modify a JSEA A JSEA shall be modified in consultation with personnel involved in the work: (i) (ii) (iii) (iv) when changes to work are identified and additional hazards are introduced needing further control measures to be implemented; after an incident or near miss to review/modify control measures to satisfy a safe system of work; when information becomes known about a hazardous workplace environmental condition, hazardous work activity, process or behavior; or where a control measure is changed to improve its effectiveness. 5.3 Completing a JSEA To effectively conduct a JSEA, the following key steps and criteria are to be applied and documented on Form S1878, Job Safety and Environment Analysis. This process adheres to the CS Energy Risk Management Procedure. A form is detailed in Appendix 2, Sample JSEA Form. 5.3.1 Identifying the Tasks for the Work Being Assessed The work to be undertaken must be analysed and broken down into the individual tasks. Each of these tasks is recorded on the form in sequence of doing the work. Job Safety and Environmental Analysis, CS-OHS-11 5
Sufficient detail should be provided so that other people can understand and follow the work. Where possible, discuss the job tasks and activities with another person (i.e. work party member) who is familiar with the job to validate the tasks and sequence to efficiently and safely perform the work. Also, the JSEA must include: specific people and skills required for each step e.g. licensed person, rigger, crane driver etc; tools and equipment e.g. scaffolding, slings and crane etc; personal protective equipment required e.g. fall restraint harness etc; drawings e.g. P&ID, etc; and MSDS, e.g. chemicals. 5.3.2 Identifying Hazards and Environmental Impacts Potential hazards and environmental impacts are to be identified for each task and recorded on the JSEA form. The first page of the JSEA form provides a list of typical hazards and the relevant hazards can be documented against the relevant task. 5.3.3 Assess the Risk Initial Use the CS Energy 6x5 Risk Matrix (detailed in Appendix 2) to assess the risk for each task by determining the likelihood and consequence. This is the initial risk score to initiate what control measures are to be implemented. The risk matrix is detailed on Form S1878, Job Safety and Environment Analysis. 5.3.4 Determine the Control Measures Where a hazard has been identified, the preferred method to control the hazard is by eliminating the hazard. However, this is not always possible and risks associated with the hazard must be reduced so far as reasonably practicable. While there is no definite level of what represents reasonably practicable, it is essentially where the organisation has applied reasonable controls to reduce the risk to a safe level given the conditions present. CS Energy follows the hierarchy of controls 1 in determining the most appropriate manner in reducing risk. 5.3.5 Assess the Risk with the Control Measures Residual Apply the CS Energy 6x5 Risk Matrix (detailed in Appendix 2) to assess the risk for each task with the identified control measures implemented. This new risk score is the residual risk for the work. This determines the level of authorisation required for work to proceed ensuring a safe system of work is followed. 1 Workplace Heath and Safety Act 27A Managing exposure to risks (2) To properly manage exposure to risks, a person should consider the appropriateness of control measures in the following order - (a) eliminating the hazard or preventing the risk; (b) if eliminating the hazard or preventing the risk is not possible, minimising the risk by measures that must be considered in the following order - (i) substituting the hazard giving rise to the risk with a hazard giving rise to a lesser risk; (ii) isolating the hazard giving rise to the risk from anyone who may be at risk; (iii) minimising the risk by engineering means; (iv) applying administrative measures; (v) using personal protective equipment. Job Safety and Environmental Analysis, CS-OHS-11 6
5.3.6 Checking, authorisation and sign-off After the JSEA has been completed, and all details are recorded on the form, the JSEA must be checked by a second person. This may be a peer, supervisor or site specialist (e.g., Health and Safety / Environmental Coordinator, Chemist, Engineer etc.) dependant on the complexity and risk level of the work. The following authorisations are required: (i) (ii) (iii) if the residual risk is moderate; authorisation by the Supervisor; if the residual risk is significant; authorisation by the Site Manager; and if the residual risk is high; authorisation by the General Manager. Once authorisations are complete, all personnel working on the job specific to the JSEA are to sign on to the JSEA form before they commence work, i.e. before the initial commencement of the job. Note: The hazards and risk shall be monitored/reviewed periodically throughout the job typically at the start of each shift using either the TRA or by updating the JSEA as determined by the conditions/risks. 6 RECORDING Completed JSEA forms shall be maintained by the PTW Officer for all JSEAs associated to a PTW. All other JSEAs are maintained by the relevant supervisor. These are to be available for review and monitoring purposes. Records shall be kept and maintained for at least 5 years 7 MONITORING AND REVIEW Periodic monitoring and review of JSEAs shall be conducted to determine and maintain the quality and effectiveness of JSEAs. Monitoring and review shall be conducted at each site: at a frequency nominated by the site manager; and by senior staff nominated by the site manager. This will also be supplemented with periodic monitoring and review by CS Energy health and safety. A checklist to qualify monitoring and review performed on JSEAs is detailed in Appendix 3. Additionally, CS Energy Health & Safety will conduct a formal review of this procedure every two years. The review will evaluate the effectiveness of the Job Safety Analysis Procedure, to prioritise, identify, assess and control risks. 8 TRAINING All personnel, both employees and contractors, are to be appropriately trained in the risk management process including hazard identification and risk assessment, i.e. JSEA process. All personnel shall be given basis risk management training during their induction. The level of training required for personnel with the functions within the roles of the PTW process is to follow the requirements outlined in: CS Energy PTW Manual, CS-PTW-01; and Training and Authorisation of Roles in the PTW System, CS-PTW-SOP-02; refer to Section 5, Training and Competency Matrix The CS Energy preferred training is the Hazard Identification Risk Assessment (HIRA). Job Safety and Environmental Analysis, CS-OHS-11 7
Refresher training for those people trained to the HIRA or equivalent level is required at least every 2 years. Refresher training shall cover any changes/improvements to the JSEA and/or TRA process and be a forum for discussion about the process. 9 REFERENCE DOCUMENTATION All applications of these guidelines incorporate the requirements of the following: Workplace Health and Safety Act 1995 Electrical Safety Act 2002 Code of Practice Risk Management AS/NZS 4360 Risk Management CS Energy Health and Safety Manual, CS-OHS-M-01 CS Energy PTW Manual, CS-PTW-01 CS Energy Risk Management Framework CS Energy Job Safety Environmental Analysis Form, S1878 CS Energy Procedure for Conducting 2X2 Task Risk Analysis, CS-OHS-46 10 DEFINITIONS Hazard Office in Charge (OIC) Permit to Work Officer (PTWO) Person in Charge of Work (PICW) Principal s Site Representative Risk Risk Assessment Risk Matrix Work Party A source of potential harm to personnel, plant or the environment An authorised person who has successfully completed all appropriate OIC training and is deemed competent. They coordinate the work and where applicable, a workgroup which is operating within a specific PTW. The OIC carries the responsibility for the PTW once issued. An authorised person who has successfully completed all appropriate PTW training and is deemed competent to isolate the plant and issue a PTW allowing work to safely proceed, then on return close the PTW and restore the plant An authorised person who has successfully completed the required training and is authorised as competent to coordinate and manage work under a PTW. This role is responsible for managing the work party signed onto the PTW to complete work within the isolation boundary. A site based person representing the Principal for the overall management of technical / commercial aspect of the contract for the Principal. Effect of uncertainty on objectives Overall process of risk identification, risk analysis and risk evaluation. A table to analyse risk resulting in the magnitude of risk expressed in terms of the combination of consequences and their likelihood. All persons who perform specific work activities as coordinated by an Officer In Charge under a Permit To Work. Job Safety and Environmental Analysis, CS-OHS-11 8
11 APPENDIX 1 JSEA FLOW CHART Job to be performed Risk Assessment Process - JSEA Is a JSEA required for work? Yes Identify individual Tasks If conditions change or control measures are ineffective No Conduct a Task Risk Analysis Identify Hazards Assess the RISK (Initial) Determine Control Measures Assess the Risk (Residual) Acknowledgement and Authorisation Process JSEA Check (by another person) Authorisation Perform Task Sign off by work party Monitor Conditions (use TRA) Records (PTW Office or supervisor) JSEA PROCESS FLOW Job Safety and Environmental Analysis, CS-OHS-11 9
12 APPENDIX 2 SAMPLE JSEA FORM Job Safety and Environmental Analysis, CS-OHS-11 10
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13 APPENDIX 3 JSEA QUALITY CHECKLIST AND SCORE Checklist against CS Energy Procedure for a Job Safety and Environmental Analysis, CS-OHS-11 Effectiveness Measure: 1 = Not established, not effective 5 = Fully established, fully effective JSEA Quality Elements 1. Supervisor conducted JSEA review and provided for feedback/input from all workers. Effectiveness (1 to 5) Comments 2. All workers participated in the JSEA review before starting work. 3. JSEA is readily visible and appropriately maintained at job location. 4. JSEA includes all job steps for specific task. 5. JSEA identifies and records all actual or potential safety/health hazards. 6. JSEA identifies that all associated hazards are eliminated or mitigated. 7. Required PPE is listed on JSEA and all PPE properly used by workers. 8. JSEA signed by OIC/Supervisor 9. JSEA has been authorised by appropriate person. 10. All nominated personnel have signed onto the JSEA. 11. Field observations at job location indicate all workers are following JSEA. 12. JSEA records all modifications when the work scope or job conditions change. 13. Steps and work instructions for job task are provided to all workers. 14. JSEA training has been completed by all work party members on task. Score : % Effectiveness : (100 x Score / 70) Job Safety and Environmental Analysis, CS-OHS-11 14