INTEGRATED SHE MANAGEMENT/AUDITING SYSTEMS –
PRACTICAL GUIDELINES (ESPECIALLY FOR SME´S)
Anders Jacobsson a and the Association of Swedish Chemical Industries b
a
AJ Risk Engineering AB, Kihlmans väg 6, 444 48 Stenungsund, Sweden
b
Box 5501, 114 85 Stockholm, Sweden
Abstract
Guidelines for an Integrated Safety/Health/Environment (SHE) management
system and for a SHE auditing system have been developed by the author for the
Association of Swedish Chemical Industries, in the following referred to as the
Association. Some of the characteristics for both systems are:
- Safety, Health and Environmental aspects are integrated;
- Basis is the natural activities of process industries or chemical handling industries;
- Highly concrete and practical approach;
The tools are mainly meant for the small and medium-sized enterprises, but could
also be used and have been used in bigger enterprises with success.
The main purpose of the Guideline for Integrated SHE management system is
that the enterprises should be able to build effective SHE management systems with
the help of the concrete sample procedures, which are provided. To make the
procedures concrete, they have been written for a sample company with typical
chemicals handling. The set of procedures and their concrete contents shall
”guarantee” that the requirements of legislation in the area of SHE are fulfilled (e.g.
Seveso II) and also the requirements of ISO 14001, EMAS, BS 8800, Responsible
Care and other codes to enable a certification or approval according to these
systems. Translation keys to other systems are provided. The guideline also gives
advice on how to develop and implement SHE management systems.
As a mirror of the SHE management system a Guideline for internal auditing of
Safety/Health/Environment has also been developed. Besides the use to verify and
judge a SHE management system it could also be used for an initial assessment or
just for a general auditing versus good operations and engineering standards. The
model could be used both for self-assessment and for independent auditing.
In the model over 140 various company activities are assessed in a semi-quantitative
way on a 10-grade scale. By giving in the assessment tool, key requirements for
various level of performance it is easy to assess the actual performance. The model
has been used extensively in Sweden and also internationally and found very
efficient. The SHE audit method is already published in an English version, whereas
the SHE management system is going to be published shortly by the European
Process Safety Centre. There is also an Responsible Care verification tool, so far
only in Swedish.
1. GUIDELINE FOR INTEGRATED SHE MANAGEMENT SYSTEM
1.1 Objectives of the guideline
With this guideline we want to show a simple and at the same time efficient way to an
integrated management system comprising Safety, Health and Environment (SHE). It
is primarily targeted at the Small and Medium-sized Enterprises (SMEs). The
emphasis in the guideline lies primarily on the suggestions for procedures which have
been worked out. The process to develop a SHE management system is also treated
but relatively briefly.
The objective is that the company shall be able to build its own efficient SHE
management system, which is natural to the company, based on the methodology
and the procedures which are contained in the system. Every company will of course
have to make adjustments, additions and deletions to the template which is
presented, but we think that a great deal of the contents would be generally
applicable.
By supplying a simple and flexible model for a management system this could easily
be adjusted and developed. The company can thus be one step ahead of the
external requirements and would not need to develop new systems in response to
new requirements in the legislation or pressure from the market side. We further
believe that the companies can do this work to a large extent using their own
resources and with a minimum of costs for external assistance. However, one should
be aware of the fact that the work as such will require big efforts, resources and
commitment.
Finally we want to emphasise that if a SHE management system, just as any other
management system, shall be successful it needs full commitment and involvement
from the top management. The management must give it full support in the form of
resources and actively participate in the development and implementation of it.
1.2 Objectives of a SHE management system
Managing SHE issues in a company in a professional way should be as natural as
managing questions of production, marketing, personnel and economy and finance.
Therefore formal systems and tools are needed for this among the other general
management systems of the company.
Among other reasons for a formal management system, are:
• Regulatory requirements, especially the EU directive, Seveso II 96/82/EU
• Management questions are often the root cause of accidents
• A need to explain and make clear norms and principles
• Marketing driven requirements, like the ISO 14001 standard
• Need for increased credibility
Besides the fact that a SHE management system regulates and makes the SHE work
more effective there will also be:
- more efficient production and maintenance by fewer operational disturbances;
fewer releases, less absenteeism etc;
- more effective project activities and simplified start up by taking into account SHE
questions at an early stage;
- better relationship with customers and suppliers.
The introduction of a SHE management system leads to a more structured and
simplified SHE work in the spirit of Responsible Care. This also leads to the goal to
achieve continuous improvement, at the same time securing that the company fulfils
the legislation in the area and on top of that lays the basis for applying a formal SHE
standard and to become certified. The certification, however, should not become a
task of its own. Properly used a SHE management system will pay off economically.
1.3 Scope of the management system
The management system comprises the areas of Safety, Health and Environment in
an integrated concept. The Responsible Care program has been used as a basis for
the work, which automatically will give a broad coverage within SHE.
The system shall also cover the requirements of
- ISO 14001 (Environmental management systems - Specification with guidance
for use).
- EMAS (Eco Management and Audit Scheme regarding environmental
management system).
- BS 8800 (British Standard ”Guide to Occupational Health and Safety
Management Systems”)
A SHE management system shall of course be built to regulate the factors which can
have a decisive influence on the SHE effects which could arise in the operations,
especially so called significant SHE aspects.
1.4 Structure of the SHE management system
The system is built around the normal activities of the enterprise
The SHE management system starts from an analysis of the normal activities of a
chemicals handling enterprise. The activities, which are of importance for SHE
questions are thereafter regulated in the form of SHE procedures.
The proposed system therefore deviates in its structure from e.g. that in ISO 9001/2
and ISO 14001. The latter starts from more general activities like ”planning”,
”implementation”, ”follow-up” etc. Our system instead covers these generic points
under each activity.
General structure
A SHE management system should be structured according to the following
hierarchical principle
1. Policy
2. Procedures
3. Instructions
The policy gives the overall view and objectives within the area. The procedures give
a clear opinion on what should be done and in general also when, where, how and by
whom. In some cases the procedures need to be complemented with detailed
instructions on primarily how and by whom the activities shall be performed. In some
cases it could be suitable to describe the system in a summarised way in a so called
manual or to assemble all the procedures in a handbook.
Our model contains proposals for policy and a large number of procedures. The
procedures have been made concrete, so a regulation at the procedure level should
be adequate for most companies.
Procedures
The model contains almost 40 SHE procedures to regulate important activities from a
SHE point of view. The procedures have been arranged in a number of chapters. The
structure and contents can be seen in the index in Attachment A.
Each procedure has a standardised structure with fixed headlines comprising of
- Objectives
- Scope
- Principles and methods
- Responsibility
- References
The procedures should be seen as examples. Each enterprise has to adjust them to
its reality and its SHE aspects as well as the ambition level that it wants to work with.
In many cases the text is relatively comprehensive to clearly show the scope of the
suggestions, ambition level etc.
Model company
In order to illustrate the system and make the procedures concrete we have written
them for a fictitious model company called ”Chemicals Handling Inc”. This is a
smaller company with a relatively general organisation.
We believe that every company, smaller as well as bigger and also with other forms
of organisation, shall be able to easily adjust the procedures to its own activities.
Document control
A well functioning document control system is important to get a living and effective
system. This guideline does not contain details of document control systems - each
company chooses its own model. The heads of the procedures could serve as
examples of the most important aspects that shall be controlled.
Ambition level
By expressing specific requirements in the procedures we have given a hint to what
could be a reasonable ambition level to achieve. For some companies this level
might be self-evident, for others it will cause some extra efforts to achieve. The
companies are of course free to chose their own ambition level of their SHE work.
The legislation is setting a minimum level as usual.
We consider that a level corresponding to the requirements for 7 points according to
the auditing method of the Association, ”SHE-AUDIT A guideline for internal
auditing of SAFETY/HEALTH/ ENVIRONMENT”, could be a reasonable level to
achieve. This would correspond to good industrial standard.
It is important that the companies will chose a level which they can meet. Too high
demands, which the organisation will not cope with, could ruin the whole effort. Then
it is better to begin with a somewhat lower ambition level, which is possible to meet,
and after that successively increase it.
Auditing tool
To be able to control that the management system of the company fulfils the basic
requirements and above all that it works in practice it must be audited regularly. The
guideline of the Association ”SHE-AUDIT A guideline for internal auditing of
SAFETY/HEALTH/ENVIRONMENT” is recommended for this purpose. The structure
of the SHE management system and that of the auditing method is very similar.
Integration with other management systems
We suggest that the company as far as possible should integrate the SHE
management system into other existing management systems.
Adjustment of model to other formal systems
In order for the system to fulfil the requirements according to ISO 14001, EMAS, BS
8800 and of course the requirements of Responsible Care, also these demands have
been built into the system. To facilitate a check versus these other systems the
model has been supplied with a number of reference keys. These also ought to be of
great assistance in a certification process.
Certification/registration
One of the objectives of this guideline is that SHE management systems based on
the recommended procedures should be able to lead to certification/registration
according to the systems which are available, at present primarily ISO 14001 and
EMAS. For certification (ISO 14001) and registration (EMAS) respectively, all the
requirements of the standard, respectively, the Directive shall be fulfilled.
1.5 Further contents of the guideline
In the guideline there are also chapters dealing with:
- SHE as an integrated concept
- Relationship between SHE and quality
- Developing a SHE management system
- The involvement and support of the management;
- Involvement of the whole organisation;
- Project organisation and ”prime mover”;
- Time schedule;
- Build on existing systems - start with initial assessment of current situation;
- Paper or electronic systems;
- Implementing a SHE management system
- Stepwise implementation;
- Follow-up;
- The line organisation responsibility to follow the system;
- Training;
- Keeping the SHE management system running
- Responsibility for managing the system
- Independent audit and certification/registration
2. GUIDELINE FOR INTERNAL AUDITING OF SAFETY/HEALTH/ENVIRONMENT
The model for audit of the SHE area that has been developed by the author for the
Association reflects the integrated view on Safety, Health and Environment. The core
of the audit model is a performance guide.
A majority of the questions that are dealt with have been assembled under the
heading SHE-GENERAL. Some questions are specific for the area HEALTH and
ENVIRONMENT respectively and are to be found under the respective headings.
"Safety" has no title of its own. The reason for this is that the concept of safety has
been integrated into the above mentioned headings. In most cases safety relates
both to the life and health of people and to the environment.
The audit model is also adapted to be a tool for controlling that a company is living up
to the requirements in the guidelines for Responsible Care.
The performance guide has been divided into the following chapters:
1 SHE-GENERAL
1.1 Management and Organisation
1.2 Legislation and Permits
1.3 General SHE information
1.4 Chemicals Control
1.5 Training, Motivation and Internal Communication
1.6 External Communication
1.7 Operations and Maintenance Procedures
1.8 Procedures for Design, Construction and Projects
1.9 Auditing and Inspection
1.10 Emergency Response
1.11 Accident/Incident Reporting and Follow-up
1.12 Fire Protection
1.13 Technical Design, Engineering and Construction
1.14 Transport
2 HEALTH
2.1 General
2.2 Control of Exposure
2.3 Medical Checks
2.4 Miscellaneous, health
3 ENVIRONMENT
3.1 General, Programme, Investigations
3.2 Emissions to Air
3.3 Emissions to Water
3.4 Wastes
3.5 Soil, Ground water, Miscellaneous
In total, the performance guide includes more than 140 points or activities, of which
90 are under SHE-GENERAL, 25 under HEALTH and almost 30 under
ENVIRONMENT. Each company chooses individually the scope of the audit
according to its requirements and objectives. The audit can comprise the whole SHE
area, in which case all the parts of the performance guide are used. Points can be
deleted as not relevant and others can be added. Some companies can choose to
make a Safety and Health audit according to the chapters of SHE-GENERAL plus
HEALTH, while other companies can choose to make only an Environmental audit
according to the chapters SHE-GENERAL plus ENVIRONMENT.
Basically, the model is intended for auditing of the administrative systems for SHE
and their applications and not for technical reviews of plants and process equipment.
However there is not always a sharp borderline. In the model there is under SHE-
GENERAL a section on Technical Design, Engineering and Construction. This is
meant to form a basis for an overview assessment of the basic technical systems.
The issues in this section can be regarded as borderline topics between a technical
survey and an administrative audit.
Performance guide
To simplify the practical performance of a SHE audit a performance guide has been
developed. The guide has two main objectives:
1) It should be regarded as a checklist of relevant points and activities which are part
of the SHE work.
2) It should form the basis for a semi-quantitative rating of the quality of the
status of each point or activity.
The performance guide has been designed to give a rating from 0 to 10 for each
point.
A simple way of quantifying the assessment at a SHE audit is of great value for many
reasons. A quantification probably improves the quality of the audit by increasing the
requirements to obtain enough and relevant information on every point. A quantitative
assessment also forms a more defined point of reference for the next audit. It will be
easier to measure the development and changes between the audit occasions.
However, the rating by points must not become an end in itself, a chasing of points
for the sake of the points. The rating shall primarily be a support for identifying
weaknesses and strengths and to give recommendations in areas which would need
improvements.
The performance guide has a 10 grade scale, where 0 is equal to "total lack of
activity within the area" and 10 corresponds to "a perfect system, also working 100 %
in practice; best in business".
On this scale 5 points should be regarded as "well acceptable". The actual demands
can, however, vary from enterprise to enterprise. Observe that some points can have
less or even none relevance for a particular kind of enterprise. The purpose and
objective should be that every point should reach at least "well acceptable". Weak
points can thus not be compensated for by stronger points within a sector.
To assist in the rating assessment we have given for four levels of performance a
description of the demands of goal attainment in the form of some key phrases. The
following levels were chosen:
2 = Poor and inadequate
4 = To be improved (Not quite acceptable)
7 = Good (well developed and documented system with good practical
implementation; good industry practice)
10 = Excellent (in all aspects a perfect system with full practical implementation;
industry leader on an international basis).
The complete performance guide is intended to be used for a full SHE audit of bigger
enterprises or of medium sized enterprises at single occasions.
When auditing smaller enterprises or departments or smaller units within bigger
companies the scope of the performance guide can look somewhat large. It is then
possible to select certain parts or points from the total guide or to make a simpler
performance guide but of similar appearance.
Attachment A
SAFETY/HEALTH/ENVIRONMENT MANAGEMENT PROCEDURES
CHEMICALS HANDLING Inc.
INDEX OF PROCEDURES
0. SHE-management system, general
1. SHE-policy
2. Organisation and Management
2.1 Organisation
2.2 SHE objectives and action plans
2.3 Management review
3. Legislation and Permits
3.1 SHE legislation
3.2 SHE permits
4. General SHE information
4.1 SHE effects
4.2 SHE reporting
5. Personnel, Training and Communication
5.1 Health care
5.2 Training
5.3 Internal communication
5.4 External communication
6. Purchasing
6.1 Purchasing activities
7. Operations and Maintenance
7.1 General site rules
7.2 Instructions
7.3 Plant integrity and maintenance
7.4 Work permits
7.5 Contractors
7.6 Handling of chemical products
7.7 Handling of wastes
7.8 Soil and ground water protection
7.9 Non-process hazards
8. Engineering and Projects
8.1 Engineering standards
8.2 Process safety (SHE) information
8.3 Investment projects
8.4 Modifications (management of change)
8.5 Manufacturing methods/R&D work/Scale-up
8.6 Technology sale
9. Auditing and Inspection
9.1 SHE audits
9.2 Risk analysis
9.3 SHE rounds
9.4 Occupational health
9.5 Environmental control
10. Emergency response
10.1 Emergency response
11. Accidents, incidents and disturbances
11.1 Accidents, incidents and disturbances
12. Fire protection
12.1 Fire protection
13. Transports
13.1 Transports
14. Product control
14.1 Product control
