ELEMENT NO. 1.

- EXAM-STYLE QUESTIONS

Long Questions

Q1 Explain the purpose and key of each stage of the safety management model described in
the UK HSE document Management for Health and Safety (HSG65). (20)

Q2 A multi-site business has a quality management system compliant with ISO 9001. It
also has a health and safety management system that operates independently. The
Board of Director is now considered the possibility of developing an integrated
management system encompassing all three elements. In order that a decision can be
made objectively, prepare a brief for the board that outlines the key potential benefits of
a) An integrated management system. (10)
b) Retaining the existing system of separate management systems. (10)

Q3 A financial review within your organization has resulted in a proposal to the Board of
Directors to cut its health and safety budget and to cancel a capital project that was
designed to lead to significant improvements in the working environment.

As the organisation’s Health and Safety Manager, explain why this proposal should be
rejected and justify your opinion. (20)
Model Answers

Question 1

Answer Plan

 Plan – what you want to achieve, who will be responsible for what, how you will
achieve your aims, and how you will measure your success.
 Do – identify your risk profile; organize your activities to deliver your plan.
 Check – measure your performance, assess how well the risks are being controlled and
investigate the causes of accidents, incidents or near misses.
 Act – review your performance and take action on lessons learned, including from audit
and inspection reports.

Suggested Answer

The diagram of the HSG65 Plan, Do, Check, Act model would be useful to include in your
answer to this question.

The model starts with Plan, where we need to think about where we are now and where we
need to be. What do we want to achieve, who will be responsible for what, how sill we
achieve our aims, and how will we measure success? We will need to write down this
policy and the plan to deliver it. We also need to decide how we will measure performance,
using leading and lagging indicators (active and reactive indicators) rather than just accident
figures. Planning should also consider fire and other emergencies and the need to co-operate
with anyone who shares the workplace, future changes and any specific legal requirements
that apply to the organization.

The Do stage starts with identifying the organisation’s risk profile, assessing the risks,
identifying what could cause harm in the workplace, who it could harm and how, and what
needs to be done to manage the risk. From this, priorities can be identified (i.e. the biggest
risks). Activities need to be organized to deliver the plan, including involving the workforce
and providing adequate resources and competent advice. To implement the plan we need to
decide on the preventive and protective measures and put them in place. These can include
providing and maintaining the right tools and equipment to do the job, training and
instruction to ensure competence and supervision to make sure that the arrangements are
followed.

Check involves measuring performance to make sure that the plan has been implemented.
We need to assess how well risks are being controlled and investigate the causes of
accidents, incidents or near misses. In some circumstances formal audits may be useful.

The final Act stage requires review of performance and learning from accident and
accidents, ill-health data, errors and relevant experience, including experiences of other
organisations. We can then revisit plans, policy documents and risk assessments to see if
they need updating and take action on lessons learned, including those from audit and
inspection reports.
Question 2

Answer Plan

a) Integration – consistency of format, avoidance of duplication of procedures, record-

keeping, auditing, software. Holistic solutions rather than just optimizing for quality or
environment. Synergy (benefits from one area applied to other areas), encouraging
interaction between specialists, etc.
b) Existing system – flexibility, safety standards set by legislation, quality set internally.
May not need such a complex system in one area compared to another; why fix what
isn’t broken? Integration may be a costly exercise; may encourage more detailed
auditing, if kept separate, specialists stay specialists.

Suggested Answer

The business has a quality management system compliant with ISO 9001. It also has a
health and safety management system (SMS) and an environmental management system
(EMS) that operates independently. The business is now considering the possibility of
developing an integrated management system encompassing all three elements. This report
has been prepared in order that a decision can be made objectively. In it, the key potential
benefits of integrating the three management systems and also of retaining the existing
independent management systems will be outlined.

The benefits of integration

There are many benefits that might potentially flow from integration of these three
independent management systems. These are outlined below:

Consistency of format – integration will require that a consistent format is applied to all
three areas. The same basic philosophy underpins each area (conformance to a standard)
and therefore the same management process and language can be applied to each.

Avoidance of duplication of procedures – consistency of approach reduces duplication,

leading to efficiencies. These efficiencies might show in terms of indirect labor costs,
productivity increases and reduction in direct labour paperwork.

Record-keeping – (as referred to above) since systems are integrated, personnel will look at
three areas of concern once rather than looking at three separate areas of concern
independently. This should lead to improved record-keeping and a reduction in the amount
of paperwork generated by the three independent systems.

Auditing – once integrated, all three management areas will be audited together. Certainly
from an internal audit perspective this should lead to improved auditing across three areas
and may lead to a reduction in the time taken to audit. In short one audit will look at one
management system rather than conducting three separate audits to look at three separate
management systems.

Software – the integration of management systems will require the integration of software
systems. Again this should lead to efficiencies in time spent interacting with the system.

Holistic solutions rather than just optimizing for quality or environment – one of the major
benefits of integration is that a holistic approach is adopted. Unlike current arrangements,
where one system (and therefore the personnel who run that system) is looking at one area
of improvement and has little interest in improving other areas, the integrated system given
ownership of all three areas to all personnel. Therefore it is in everyone’s interest to see
improvement that enhances quality but is detrimental to environmental performance is not
seen as worth making. One that enhances health and safety (H&S) and has no negative
impact on environment and quality is worth making.

Synergy – another key benefit of the integrated system approach is synergy; i.e. the idea
that benefits from one area can be applied to other areas and that when this happens the
whole becomes greater than the sum of the parts.

One final benefit of integration is that it encourages interaction between specialists and will
require specialists to branch out into other areas of knowledge. Though specialists may
retain a higher level of competence in a chosen area, they will have to develop their
competence in other areas. This can be of great benefit since cross-pollination of ideas
should then flow within the organisation; there is greater sharing of knowledge and practice
and less ring-fencing of know-how.

The benefits of retaining the existing system of separate management systems

Flexibility – current arrangement are highly flexible. This is especially the case with the
SMS and EMS since these are not in compliance with an external system and can be
operated as we see fit. The QMS is less flexible since it is ISO 9001 compliant and therefore
must meet external standards in order to retain certification. It must be recognized that in
order to retain this certification; any integration of systems would have to remain ISO 9001
compliant. This complicates the integration process.

Safety standards set by legislation, quality set internally –while the general philosophy of all
three systems is the same (conformance to standard) both H&S and environmental systems
are driven by the need to comply with the law. Quality, however, is driven by our own
internal need to meet customer expectation. Current arrangements allow internal standards
to carry equal weight with legal standards. Integration may lead to more weight being given
to legal standards and a dilution of quality standards as a consequence.

May not need such a complex system in one area compared to another–integration
inevitably leads to complexity because the need to achieve compliance in one area ripples
out across all three areas of concern. This can lead to an over-complication of systems. The
QMS is driven by the requirements, of ISO certification. This might therefore drive
complexity into the SMS and EMS.

Why fix what isn’t broken? All three management systems are functioning acceptably
across the multi-site operation and look to be working well. Any attempt to change these
systems may lead to disruption (at least in the short term) for little benefit.

Integration may be a costly exercise-inevitably there are costs associated with integration.
An IMS will have to be selected, tailored to our needs and then implemented across the
whole operation. Personnel, both specialists and others, will require re-training in new
systems. The potential for business disruption exists, which may have unforeseen cost
implications.
May encourage more detailed auditing if kept separate-current audit arrangements require
detailed focus on the three areas of concern independently. This separate focus does mean
that greater scrutiny is applied to each topic area.

Specialists stay specialists – the current system requires that QMS staffs are specialists in
quality management only. The same applies to EMS and SMS staff. This staffs have
developed their competence over years of practice and study. Retaining the current system
allows these people to stay specialist, rather than requiring them to move into other areas
where they have little or no experience or knowledge and therefore no competence.
Question 3

Answer Plan

 Moral, legal and economic arguments.

 Moral – policy obligation to staff. Personal impact of accidents and ill-health.
 Industrial relations and PR implications of moral failure.
 Directors’ personal values. (Put last).
 Legal – compliance with legal requirements, enforcement notices, prosecution,
avoidance of legal action against directors and/or managers, compensation.
 Economic – costs of failure; direct costs, indirect costs. Uninsured losses, hidden nature
of losses. Financial benefits of good standards, especially working

Suggested Answer

This report has been prepared following the proposal to the Board to cut the health and
safety budget and cancel the health and safety capital project. The report will argue for the
rejection of this proposal based on three basic principles: the sound economic argument that
underpins good health and safety management within this organisation, the legal
implications of failing to manage health and safety effectively, and the moral imperative.
Each of these arguments will now be discussed in detail.

The Economic Argument

Health and safety (H&S) failings cost money; in fact they can cost a lot of money. And
while it is true that putting good H&S standards in place also costs money, the costs
associated with failures far outweigh the costs of implementation. There are two ways in
which this organisation may fail to ensure H&S – one is a failure to ensure safety. This
leads to accidents. The other problem is failure to ensure health; this leads to ill-health,
sickness and chronic disease. Both accidents and ill-health have direct costs associated with
them. For example, a workplace accident leads to production downtime, damage to
equipment, plant and premises, and loss of product. Damaged equipment and premises must
be repaired or replaced. This in turn usually leads to indirect losses to the organisation –
losses that do not stem directly from the event itself, but flow from it as inevitable
consequences. Lost product must be re-made, which incurs overtime to additional labour
costs.

Personnel who have been injured remain absent from the workplace; they are paid full
salary during their absence and at the same time the organisation has to employ temporary
labour to cover their work. In some instances this temporary labour solution cannot be
applied and then other workers in the workplace have to pick up the work of their absent
colleague. This leads to overworking, fatigue and stress which in turn lead to an increase
inhuman error and higher absenteeism.

While some of the costs highlighted above are quite apparent, some may be hidden to the
organisation; others are non-discoverable in nature. If industrial relations are severely
damaged by a workplace accident, that reflects in poor productivity, higher absence rates
and reduced efficiency. But how could that be exactly costed out? The answer is it cannot
be. If bad publicity were to result from a workplace accident, that might have a direct effect
on our customer’s willingness to do business with us. Again, this could be a very significant
cost that would be difficult to quantify and discover.
The above arguments relate to workplace accidents and ignore the cost implications of
work-related ill-health. Occupational ill-health often results from poor working conditions
and poor working environments. It almost invariably leads to workplace absence and, in
some instances, may be severe enough to warrant dismissal on medical grounds. There are
costs associated with the worker absence, the management of that absence and the legal
action that often results from such ill-health and dismissals, not to mention the poor
industrial relation and PR that can accompany such illnesses.

Studies which have analysed workplaces looking for the costs associated with workplace
accidents suggest that the uninsured losses to an organisation are greater than the insured
losses by a factor of 8x as a minimum. In other words, our insurance company cannot be
approached to fund the vast majority of losses that we incur when we injure people at work
or make them sick. We fund those losses ourselves

None of the above included any comment about the financial implications of legal actions,
which this report will now move on to consider.

The Legal Argument

There are legal standards that we must comply with and failure to comply can lead to
enforcement action being taken against us in the form of legally binding notices that require
us to carry out such improvements or to stop certain activities. This enforcement action
invariably carries with it the costs associated with carrying out the improvement to the
enforcement officer’s timescale, or stopping an activity that we find to be financially
beneficial. This is not to mention the bad IR and PR that is usually associated with these
enforcement notices. In other instances, failure to achieve legal compliance may result in
prosecution. Directors may also face personal liability for legal failing of the organisation
that they direct. Needless to say, all of the above legal actions carry with them the risk of
incurring huge legal fees in mounting a defence (and paying the prosecution legal fees in
the event of the case being lost).

In addition, injure a worker, or cause ill-health, and we may well be sued by the injured
party. These cases may result in the payment of compensation to injured victims. Though
this money may come from our insurers in the first instance, it invariably leads to higher
insurance premiums in the short–and long-term as those insurers attempt to claw back their
losses from us.

The Moral Argument

We have a clear policy obligation to our staff to ensure their ongoing health, safety and
welfare. That has been made clear in the statement of intent signed by our Managing
Director as the headline of our H&S policy. Aside from the legal and financial arguments
discussed above, we must also consider the huge personal impact of accidents and ill-health
that can and do occur as a result of our H&S standards. One worker may be injured or made
ill, but that one person has a family, friends and colleagues. The impact of a serious
accident or case of ill-health has wide-ranging implications. We must reflect on our own
personal values and decide whether we would wise to see the unpleasant and sometimes
tragic consequences of poor H&S standards occurring in our organisation.

On conclusion, I would state that cutbacks cannot be made to the H&S budget, or to the
capital project, on the basis of the three arguments described above. We owe it to ourselves,
to our workforce and to our shareholders to retain our H&S budgets so that we are best able
to avoid the losses that workplace accidents and ill-health might cause.