This section addresses how activities are to be performed and monitored, and how corrective action is to be taken when necessary.
Procedure Requirement
HSE performance targets shall be set to ensure progression towards the long-term goals of no harm to people and no damage to the environment.
Performance indicators shall be established, monitored and results reported in a way that can be externally verified.
All HSE incidents and near misses with significant actual or potential consequences shall be thoroughly investigated and reported.
Performance Monitoring
Activities and tasks shall be conducted according to the procedures and work instructions of the organisation (Refer 5.2 Procedures and work instructions). HS3 Limited shall ensure that there are systems in place to verify that the tasks and activities are carried out in accordance with these procedures and work instructions.
The HSE-MS shall include documented and maintained procedures to monitor the implementation of the HSE-MS (proactive e.g. progress on close out of audit action items) and HSE performance (reactive statistics e.g. incidents, deviations) on a regular basis.
HSE critical activities with their performance indicators shall be specified in the HSE-MS Manual. Each critical activity shall be assigned to the correct accountable party who shall monitor and regularly report the performance of their activity(s) using the indicators.
Proactive measures of performance shall be put in place to measure the implementation of the HSE-MS and the evaluation of stakeholder concerns. Proactive measures such as ‘unsafe act auditing’ and ‘site inspections’, shall be in use to monitor performance and identify shortcomings.
A documented procedure for the periodic evaluation of compliance with relevant HSE legislation and regulations shall be maintained.
The company shall regularly measure, record, track and report HSE performance against targets set in the HSE Plan and in maintaining control (Refer 4.2.3 Maintain effective control measures).
Where monitoring equipment is required for performance measurement and monitoring, the organisation shall establish and maintain procedures and retain records for the calibration and maintenance of such equipment. Procedures shall be established for data handling and interpretation (including the calibration of equipment).
The progress of individuals in undertaking their HSE Critical Activities and also in meeting planned HSE targets shall be monitored through the staff appraisal system.
The organisation shall establish and maintain procedures for the identification, maintenance and disposition of HSE records. These should include:
- Reports of audits and reviews
- Audit tracking data
- Register of or a means of identifying and accessing legislation applicable to the organisations activities
- Legally required documents
- Situations of non-compliance with HSE policy, and of improvement actions
- Any incidents and follow-up actions
- Any complaints and follow-up actions
- Appropriate supplier and contractor information
- Inspection and maintenance reports of HSE critical equipment e. equipment providing a control and recovery function
- Product identification and composition data
- Data obtained from monitoring as input to performance records
- Results of emergency drills and exercises
- Training records which include HSE competency requirements which include HSE
HSE records shall be legible, identifiable; traceable to the activities involved with retention times defined. They shall be stored and maintained to prevent loss and unintended use.
Records supporting the performance data provided to HS3 Limited on an annual basis shall be kept in an auditable form.
Records shall be maintained, as appropriate to the system and to the organisation, to demonstrate conformance to the HSE Management System, regulations and standards and are used in HSE improvement planning.
Non Compliance & Corrective Action
HS3 LIMITED shall maintain procedures for defining responsibility and authority for:
- the handling and investigating of non-conformances with legislation, regulations, HSE-MS policies, procedures and standards
- identify root causes and taking action to mitigate any consequences arising from such non conformances
- the initiation and completion of corrective and preventative actions
- confirmation of the effectiveness of corrective and preventative action taken
Any corrective or preventative action taken to eliminate the causes of actual and potential non-conformances shall be appropriate to the magnitude of problems and commensurate with the HSE risks encountered.
HS3 LIMITED shall implement and record any changes in the documented procedures resulting from corrective and preventative action.
To prevent non-compliance with standards and procedures a documented system for variance/change control shall be in place. Employees shall be aware of the system. (Refer 5.3 Management of Change).
Incident Reporting & Follow Up
HS3 LIMITED maintains procedures for the reporting and investigation of hazardous situations, near misses and incidents, which are compliant with its policies, procedures and standards.
Incidents shall be investigated in a timely manner, with accountabilities assigned, and progress on recommended actions monitored until close out.
HS3 LIMITED shall foster a culture of openness in reporting all incidents and near misses.
Employees shall be aware of the near miss and incident reporting procedures and participate in incident investigations.
Any corrective or preventative action taken to eliminate the causes of potential incidents shall be appropriate to the magnitude of problems and commensurate with the HSE risks encountered.
Training shall be provided in incident investigation to appropriate staff throughout the organisation.
HS3 LIMITED shall implement and record any changes in the documented procedures resulting from corrective and preventative action. Lessons learnt from accidents and incidents shall be disseminated to relevant personnel and contractors.