Case Study

You are the newly hired Safety Manager at ABC Pte Ltd, which specializes in manufacturing synthetic rubber. Your responsibilities are to manage the plant’s Safety Management System and address all environmental, health and safety (EHS) aspects of the plant during the manufacturing process.

ABC Pte Ltd is Singapore Standard, SS651:2019 certified. The company is due for re-certification in December 2022. The steps below outline the general steps involved in processing and manufacturing a typical synthetic rubber.

The plant stores and uses hazardous chemicals and flammable materials (naphtha) during the manufacturing processes. Storage tankers are equipped with secondary containment to contain spillages or leakages that could occur through the whole manufacturing process.

The company operates in 3 shifts, 7 days a week, and employs 200 employees working in various departments. Fifty employees are in the main office, in departments such as finance, human resource, quality, facilities and environment, health and safety. There are 50 employees in each shift and the company has outsourced facilities management to a third party vendor to support day to day facility services.

During several of the walk-through safety inspections, the following were noted:

1. A number of power driven tools (grinders, hammer drills, chain saws) did not come with a Licensed Electrical Worker (LEW)’s inspection sticker.
2. Chemicals kept in containers were not labelled in accordance to the Global Harmonized System (GHS). Chemicals were transferred to plastic drinking bottles instead of appropriate secondary storage containers.
3. When a technician was interviewed, he highlighted that there was a “rotten egg” smell in the chemical storage area.
4. Safety Data Sheet (SDS) of certain chemicals were either found missing or dated more than 5 years.
5. One of the facility management technicians was performing maintenance on a process equipment and no barricades were installed to prevent any unauthorized access to the work-area.
6. One of the sub-contractors (who was engaged by the facilities management team) was observed to be standing on the top rung of an A-frame ladder with both of his hands on his work and he was not wearing any safety harness.
7. When a worker who performed Work-At-Height was interviewed, he said that he is trained and permitted to work at height. However, his actual work practices were unsafe and risky.
8. Self-contained breathing apparatus (SCBA) and chemical suits for Emergency Response Team (ERT) were faulty.
9. CPR pocket masks in the first aid boxes had expired. Used and opened triangular bandages were found.
10. Several of the lifting equipment (webbing sling, shackle and chain block) were expired and a few of them did not have any lifting tags.
11. Tools and materials were scattered on the floor in the maintenance room. Damaged T5 fluorescent light, metal piping and plastic casing were found in the waste scrap bin. When the facility supervisor was interviewed, he mentioned that scrap materials were consolidated and would be disposed when the waste bins were full.
12. A sample size inspection of the fire protection system revealed that three ABC type of fire extinguishers were not charged with enough pressure and two ABC fire extinguishers were found to be obstructed. Further inspection revealed that four hose reel casings were dented.
13. Liquid stains were found on the floor within the perimeter of the storage tankers where hazardous chemicals were stored.

There were many lagging indicators that contributed to unsafe conditions or unsafe acts in the plant, such as:

• Lack of control of the usage and storage of chemicals
• Human factors such as the behaviour of the supervisor, operators and sub-contractors
• Inadequate training of the users on the chemicals
• Insufficient preventive maintenance and inspection of critical equipment (emergency response kits and fire protection system)

External audit by the certification body is due to commence in three months’ time. To prepare for the SS651:2019 audit, the ABC Pte Ltd management team had tasked you to lead a team of internal auditors to perform management system audit on the entire plant.

Question 1

ABC Pte Ltd management team had tasked you to form an audit team. You will lead the audit team to audit the SS651:2019 Safety and health management system for the chemical industry.

Describe how you will form the audit team in a table format. Clearly examine the reasons for each of the following.

(a) Selection of the internal audit team representatives (b) Roles and responsibilities of the selected representatives (c) Type of training that the representatives are required to attend (d) Knowledge and skills the members must have prior to the internal audit

Question 2

You are assigned to lead the audit team to conduct a two-day audit. Develop the schedule for the internal audit. Show the schedule in a table format and discuss the activities to be audited, members of the audit teams to be involved, etc.

Question 3

Prepare an audit checklist based on the scenario given. Show the checklist in a table format. Analyse at least TEN (10) observations identified during your inspection. Propose preventive actions to address the SS 651:2019 Clause (e) of 9.2.2 Internal audit programme, that is “Take action to address nonconformities and continually improve its Safety and Health (S&H) performance.”

Question 4

The internal audit team has completed the two-day audit. You, as the lead auditor, are required to conduct the closing meeting with ABC Pte Ltd management team.

Appraise the monitoring with a report developed in a table format. Your report should address all of (but not limited to) the following elements.

(a) Definition of the audit criteria and scope of audit (b) Results of the audit findings (c) Acknowledgement of the auditee’s management representative (d) Audit report (e) Corrective Action and Preventive Action (CAPA) form (f) Others