Firstly, after finishing my 1st degree, coming back to serve my country, I recall a government official from the Ministry of Education, highlighting the fact that for every scholarship student that is sent overseas to study, the same budget used to sponsor a scholarship student could be used to sponsor 4 students at our local university, Universiti Brunei Darussalam. This knowledge gave me a sense of responsibility to return to Brunei at least 4 times as much work, effort and energy towards the development of Brunei.
Secondly, during my interview for the Fulbright Scholarship, I made a promise to the panel that interviewed me, that upon coming back to Brunei, I would share the knowledge that I had learned from my Masters with the rest of Brunei, to the best of my ability.
The above 2 points is part of the main reason why I would like to share with you my comments on the above mentioned article.
Firstly I would like to congratulate Justina Liew Vun Ching, the Head of Public Works Department's Safety Unit, for taking on board an extremely challenging task ahead. Identifying the need for a HSE policy is certainly a step in the right direction.
So as to not re-invent the wheel, I would like to share with everyone a good reference website for HSE related material: International Association of Oil and Gas Producers. I'll provide the link at the end of this blog. One particular publication:
Guidelines for the Development and Application of Health, Safety and Environmental Management Systems;
is a guideline that identifies the main elements in the development of a Health, Safety & Environmental Management System.
I'll briefly describe the main contents of the above mentioned guideline with the hope that it will assist everyone and anyone interested to better understand HSE management.
1. Leadership and commitment
It is essential that top leadership themselves practice HSE related behavior and shows commitment towards the HSE policy. Otherwise without leadership and commitment, those who expected to implement HSE behavior (such as the safety foremen, workers on site etc) will question, why should they practice a HSE culture when top management themselves does not practice such behavior. Hence part of the reason why I salute Justina, not only will she have to practice the HSE behavior, but will have the daunting task of getting top management commitment towards HSE behavior.
2. Policy and strategic objectives
According to the OGP guideline, policy and strategic objectives should / be:
a. Consistent with those of any parent company;
b. Relevant to its activities, products and services, and their effects on HSE;
c. Consistent with the company’s other policies;
d. Of equal importance with the company’s other policies and objectives;
e. Implemented and maintained at all organisational levels;
f. Publicly available;
g. Commit the company to meet or exceed all relevant regulatory and legislative requirements;
h. Apply responsible standards of its own where laws and regulations do not exist;
i. Commit the company to reduce the risks and hazards to health, safety and the environment of its activities, products and services to levels which are as low as reasonably practicable;
j. Provide for the setting of HSE objectives that commit the company to
continuous efforts to improve HSE performance.
The above statements are in principle what any organization should consider when developing a HSE policy. We can adopt and adapt the statements to meet existing conditions. Allow me to share with you suggestions on how to adapt the above statements to the situation in Brunei.
a. Consistent with those of any parent company;
Taking into consideration that the Public Works Department is under the Ministry of Development, I would suggest that the policy tie in with Vision and Mission of the Ministry of Development, to ensure alignment and synergy.
b. Relevant to its activities, products and services, and their effects on HSE
HSE spans occupational health, occupational safety and environmental management. Activities, products and services would need to be tied into their respective health, safety and environmental component. In principle, occupational health is about identifying potential hazards that a worker is exposed to. Occupational health would amongst others take into consideration, the type of exposure, duration of the exposure, route of exposure etc. For example in the construction industry workers of an industrial plant maybe exposed to certain hazardous / toxic substances. Information relating to such substances should be contained in reputable Material Safety Data Sheets (MSDS) which should contain relevant information for Safety Practitioners to take into consideration when addressing Occupational Safety.
Occupational Safety should identify the appropriate safety measures in order to address the hazard. Safety measures include a plethora of options, subject to the hazard. Some include the requirement of a Job Hazard Analysis (also known as Job Safety Analysis), Permit To Work (for cold and hot works) etc.
Environmental aspects should consider the disposal of construction material, waste segregation, life cycle assessment etc.
Above is merely a glimpse of the issues that need to be considered.
c. Consistent with the company’s other policies
The Public Works Department is under the Ministry of Development. Other agencies such as the Department of Environment, Parks and Recreation (Pollution Control Guideline for Industrial Development), Town and Country Planning Department,Water Services Department (water catchment concerns), Drainage and Sewage Department etc
There are other agencies outside of the Ministry of Development that need to be considered such as but not limited to:
i. Occupational Health Division, Ministry of Health (for Occupational Health guidelines)
ii. Labor Department, Ministry of Home Affairs (for compliance issues with the Workplace Safety and Health Order, 2009).
Subject to the development of the Environmental Impact Assessment Order as announced by the Minister of Development during this year's National Environmental Conference, subject to site specific conditions, certain other agencies should also be considered such as:
i. Museums Department, Ministry of Culture, Youth and Sports (threatened, endangered and protected species; etc)
ii. District Office, Ministry of Home Affairs (if the construction affects livelihood of surrounding community)
iii. Any other potential agency
d. Of equal importance with the company’s other policies and objectives
This is subject to policy - makers input. Certain conditions may effect the priority of certain policies. As a suggestion, with Wawasan Brunei 2035, I would propose that Vision, Mission and policies are aligned with the Wawasan Brunei 2035 to ensure synergy. This would also require alignment with the agencies within the Ministry and outside the Ministry where applicable.
e. Implemented and maintained at all organisational levels;
This requires consistent clarity vertically and horizontally, within and across all levels that are within control. Otherwise, for agencies beyond control, influencing measures can be put in place. Tools such as Facebook, e-mail, intranet and internet facilities can help to maintain controlled, clear and consistent policies across the organization at all levels.
f. Publicly available
Public tools such as Facebook, Twitter, websites, mass media etc can help to ensure all policies are publicly made available. This is important to ensure that all relevant stakeholders are informed, updated and knowledgeable regarding policies from the Public Works Department and relevant agencies.
g. Commit the company to meet or exceed all relevant regulatory and legislative requirements;
Firm statements with principles of 'Continual Improvement' will commit an organization towards a continuous direction of ensuring progress is maintained. This prevents complacency setting in and keeps safety practitioners looking for ways to always improve the system.
h. Apply responsible standards of its own where laws and regulations do not exist
As a developing country, it is understood that laws and regulations maybe not complete or not in existence. Nevertheless neighboring countries have established construction related guidelines and other developed countries also have guidelines. At the onset, generic standards such as 'As Low As Reasonably Practicable - ALARP' can be introduced as a start. But should be revisited to understand the issues and develop appropriate guidelines once reference standards are available.
i. Commit the company to reduce the risks and hazards to health, safety and the environment of its activities, products and services to levels which are as low as reasonably practicable;
Commitment as mentioned above needs to come from all levels - especially top level commitment.
j. Provide for the setting of HSE objectives that commit the company to
continuous efforts to improve HSE performance.
Providing the setting involves amongst others the empowerment of individuals to implement HSE objectives. Empowerment includes assigning appropriate authority, responsibility and hence accountability. Establishing mechanisms to monitor, record and document HSE issues etc.
3. Organisation, resources and documentation
Amongst others the publication describes the need for:
i. Organizational structure and responsibilities
ii. Management representatives
iii. Resources
iv. Competence
v. Contractors
vi. Communication
vii. Documentation and its control
4. Evaluation and risk management
Amongst others the publication describes the need for:
i. identification of hazards and effects
ii Evaluation
iii. Recording of hazards and effects
iv. Objectives and performance criteria
v. Risk reduction measures
5. Planning
Amongst others the publication describes the need for:
i. Planning to support all of the above issues
ii. Asset integrity
iii. Procedures and work instructions
iv. Management of change
v. Contingency and emergency planning
6. Implementation and monitoring
Amongst others the publication describes the need for:
i. Activities and tasks
ii. Monitoring
iii. Records
iv. Non - compliance and corrective action
v. Incident reporting
vi. Incident follow-up
7. Auditing and reviewing
Amongst others the publication describes the need for:
i. Auditing
ii. Reviewing
The publication continues to offer definitions to terms that are commonly used in the HSE field.
Another useful reference publication from OGP (International Association of Oil and Gas Producers) is:
A guide to selecting appropriate tools to improve HSE culture
This particular publication describes a list of tools that helps to improve the HSE culture along. The progressive nature of HSE culture is described as:
1. Pathological (who cares as long as we're not caught)
2. Reactive (Safety is important - we do a lot every time we have an accident)
3. Calculative (We have systems in place to manage all hazards)
4. Proactive (Safety leadership and values drives continuous improvement)
5. Generative (HSE is how we do business around here)
Hopefully the above mentioned publications from the International Association of Oil and Gas Producers can serve as a reference document for policy-makers and the general public to better understand how to establish and implement a Health, Safety and Environment Management System.
Highlighting a learning point from one of my past blogs regarding Chapter 7 from 'The Sustainability Handbook'. It should be noted that when setting objectives/ goals to support policies, the SMART approach should be considered. (Simple, Measurable, Achievable, Relevant and Time-based).
Finally I end this blog with links to websites which might be of interest for HSE practitioners.
Link to International Association of Oil and Gas Producers
