SCENARIO

You are an experienced health and safety manager (HSM) working for a small chemical organisation.
The organisation makes one product, a paint, that is available in different colours. On site are the
purchasing, sales, product quality control, maintenance, warehousing, and production departments.

You have implemented a health and safety management system that includes internal auditing.
There is a team of internal auditors from the different departments. This enables the auditors to be
independent of the department being audited. One auditor recently left the organisation, and
Worker A has volunteered to fill their role. As part of their training, Worker A will accompany you on
your next health and safety audit. You look at the audit timetable and see that the next scheduled
audit is in a month’s time, for the production department processes.

The production department is led by the production manager (PM), who reports directly to the
senior management team. There are 3 supervisors and 15 workers in the production department.
The product is selling well, and the production team is working at full capacity, often having to work
extra shifts. They also use temporary workers from an employment agency when the workforce is
unable to keep up with demand.

Audit planning
You meet with Worker A, explain the organisation’s written audit procedure, and plan the audit. You
begin by sending an email to the PM to inform them of the audit and suggest suitable dates. To carry
out the audit, you plan to observe the different stages of the production process:

1. Delivery and storage of raw materials (chemicals) in the production area.

2. The production process: filling, mixing, quality control testing, and dispensing.
3. Moving of finished goods to the warehouse.

A week later, you have not had a reply from the PM about the planned audit. When by chance you
meet them in a corridor, you remind them of the audit, and you suggest dates again. They tell you
to “go ahead and schedule it; any time is good for me.” You schedule the audit for two weeks’ time.

Gathering information
On the day of the audit, you arrive with Worker A in the production department and go directly to the
supervisor’s office. Supervisor B is on duty. They are surprised to see you, so you explain that you
are there to begin the audit. Supervisor B tells you that the PM did not inform them about the audit.
They explain that they are very busy but “there will never be a good time, so go ahead, and we will
try to fit it in around production.”

While in the office you ask Supervisor B if you and Worker A can review the necessary paperwork.
They have difficulty finding some items, but eventually locate them in a filing cabinet. Risk
assessments have been completed, but are dated three years ago. You also notice that a first-aid kit
is kept on top of the filing cabinet.

You then ask Supervisor B to show you the production area. On the way, you pass a notice board
that displays a ‘no eating or drinking in the production department’ sign, and a copy of the
organisation’s health and safety policy. The policy is signed by the previous managing director, and
is also dated three years ago.

In the production area you find five workers, all wearing the correct personal protective equipment
(PPE) - gloves, goggles, and disposable dust masks - as described in the risk assessment. There
are 5 one-tonne mixers in the area. At the side of each mixer is a stairway for workers to access the
funnel at the top for loading raw materials. The ingredients are mixed with a metal stirrer that is
driven by a motor. The finished product is then passed through a valve at the bottom of the mixer.
You can see that full, partly full, and empty drums of chemicals are piled up around the mixers and
you notice spillages on the floor.
You watch one batch of the product being made by Worker C. The liquid raw materials are stored in
a nearby warehouse in 25-litre drums. You see a worker using a forklift truck (FLT) to deliver full
drums from the warehouse to the production area. The most direct route is to bring the drums in
through the emergency exit door of the production area. However, this door is too small for the FLT
to enter, so the drums are left outside of the emergency exit door until they are needed. You can see
that some of the drums are currently blocking part of the doorway. You also notice a ‘no authorised
persons beyond this point’ sign on the exterior of the door.

Worker C finds the raw materials they need outside the emergency exit door and carries the drum up
the stairs to the mixer. They open the drum, and as they tip it into the funnel, you see some of the
chemical splashing over the edge. They leave the empty drum in the production area and repeat the
filling process with the remaining raw materials. They then turn on the mixer to blend the raw
materials.

You examine the mixer and see evidence of previous spillages. There is some corrosion on the
motor that drives the stirrer, and the seals look worn. A maintenance log is kept by the mixer, and
you notice that routine maintenance has not been recorded for six months.

While the product is mixing, you speak to Worker C. They remove their gloves and show you that
they have mild dermatitis from skin contact with the spilled chemicals and their hands get hot in the
heavy gloves. They also complain that the work is tiring, and the dirty production area is
unacceptable. They tell you that they have reported these issues to the PM, but nothing has been
done.

A sample of the product is then tested in the quality control laboratory, which takes 30 minutes.
Once approved, the finished product is poured into clean 25-litre drums, labelled, and driven back to
the warehouse using an FLT.

You discuss the chemical storage and handling with Supervisor B, and they agree that it is a
problem. In addition to the health and safety issues of spilt chemicals, they tell you that some of the
ingredients are very expensive and there is a high level of waste. Supervisor B also tells you about
issues with moving the chemicals. They explain that one worker is currently off work because they
injured their back from carrying the 25-litre drums. They add that, on another occasion last month, a
worker slipped on spilt chemicals and fell down the mixer stairs. This worker was injured from the fall
and had three weeks off work to recover. You check in the accident book and confirm that this
accident was correctly recorded, but that no investigation took place, and it has not been reported to
the Regulator. The number of accidents and near misses recorded in the production department is
high.

Audit analysis and report

You discuss information gathered during the audit with Worker A. According to the organisation’s
audit procedure, the findings are classified as: Good Practice (GP), Opportunities for Improvement
(OFI) and Non-Compliance (NC). You decide to raise three findings:

• GP: correct use of PPE;

• OFI: document retention and accessibility;
• NC: chemical storage and handling.

You use the standard template from the organisation’s audit procedure to write the audit report. You
raise an action to improve chemical storage and handling, and make the PM responsible, with a
timescale of two months. You then email the audit report to the senior management team. The PM
telephones you to thank you for the audit report, and for highlighting the chemical storage and
handling issues.
The project
The PM tells you that they are under pressure to increase production capacity. Last month they
attended a trade fair and were interested in information on systems enabling the bulk movement and
storage of raw materials. There are only three raw materials used in large volumes at the
organisation. Instead of the 25-litre drums, the raw materials could be delivered by tanker and stored
in dedicated bulk storage tanks, then pumped directly to the mixers as needed. This would remove
the need for manual handling of raw materials, speed up production, and increase production
capacity.

You tell the PM that there will be health and safety issues resulting from this change. You both agree
that, if approved, you will need to be part of the change management process for this project. To
convince the senior management team that this change is needed, you write a proposal setting out
the financial arguments for improving health and safety.

Your proposal is successful, and the resources required for the project have been provided. The PM
starts a change management process to implement the bulk delivery, storage, and transfer of raw
materials.

One year later

The project is complete. The three raw materials are now delivered by tanker and pumped into new
storage tanks. Pipework has been installed between the storage tanks and the existing mixers. The
time it takes to produce one batch of product has reduced from two hours to one hour.

You review the impact of the change on health and safety performance. The accident book shows
that the number of accidents and near misses recorded in the production department has greatly
decreased. You visit the production area and find that the level of housekeeping has improved.
Supervisor B says that production volume has increased. Additionally, the reduction in manual work
means that it is less tiring for the workers, and they are generally happy with these changes. They
can plan production more easily, and no longer need to use temporary workers for rush orders.

At the monthly management meeting, where health and safety is always reviewed, the senior
management team are happy with progress. The targets for a reduction in incidents and accidents,
and increased production capacity, that were set last year, have been achieved.
Task 5: Financial arguments to improve health and safety

5 Your proposal to senior management convinced them to provide resources for

improving health and safety in the production area.

What financial arguments could have been used in this proposal? (15)
Note: You should support your answer, where applicable, using relevant
information from the scenario.
Task 6: Obligations of employers to workers

6 Employers have obligations under Recommendation 10 (a, b, c, d, e and g) of

the International Labour Organisation’s (ILO’s) R164 – Occupational Safety and
Health Recommendation, 1981 (No. 164).

Comment on how these employer obligations may not have been followed at
the time of the audit of the production department. (15)
Note: You should support your answer, where applicable, using relevant
information from the scenario.

Task 8: Good practice within a health and safety management system

8 How has the organisation demonstrated good practice within a health and
safety management system? (10)
Note: You should support your answer, where applicable, using relevant
information from the scenario.

End of examination

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