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1.0 PURPOSE
This procedure is developed to establish effective HSE risk assessment / mitigation processes throughout operations including production processes as well as support operations and ensure that the same is kept up to date reflecting any change in the processes / operations.
2.0 SCOPE
When considering the hazards at the site, the following are taken into account:
- Routine and non-routine activities.
- The activities of all persons having access to the workplace (including contractors and visitors).
- Human behavior, capabilities and other human factors (i.e. cultural differences, ergonomics, sex, attitudes to HSE etc).
- Hazards originating outside the workplace that may affect the XXXXX (i.e. fire at a neighboring site or sand storm).
- Hazards created in the vicinity of the workplace as a result of activities under the control of the management (i.e. a fire or spillage at XXXXX that adversely affects our neighbors).
- Infrastructure, equipment and materials used within XXXXX whether provided by XXXXX or not. (i.e. Fork lift trucks or contractors ladders)
- Changes or proposed changes in the organization, its activities or materials (i.e. hardware changes such as installing new capital equipment, or changes to procedures such as changing the role of operators)
- Modifications to the HSE Management system.
- Any applicable HSE legislation relating to the organization
- The design of work areas, processes, installations, machinery & equipment, operating procedures and work organization.
3.0 RESPONSIBILITY
3.1 The MR is responsible for overseeing the process of risk assessment and tracking for its updating.
3.2 Identified Core Team members from each department are responsible for informing / notifying the MR regarding any change in the processes, procedure or activities subsequent to the initial risk assessment.
3.3 Core Team / competent personnel along with the MR conduct the risk assessment for respective department once in 12 months.
3.4 Relevant departments (Sales, Purchase, Operations, Maintenance, Quality Assurance & Control, HR, Administration and Finance) will join the risk assessment process or will be consulted.
3.5 Project manager and Safety officers is responsible for risk assessment at onsite.
4.0 HSE RISK ASSESSMENT / MITIGATION PROCESS
The framework provided herein provides an HSE risk assessment / mitigation process that:
4.1 Operates on a continuous and systematic basis;
4.2 Addresses HSE hazard / Aspect identification, risk / Impact assessment and risk control;
4.3 Analyzes and prioritizes those risks / Aspects;
4.4 Serves as a vehicle for risk/aspect control, management and communication and has utility for all parts of the site.
However, there are two (2) additional considerations that warrant attention:
4.5 Regulatory Requirements: The process described herein includes the consideration of HSE risks associated with legal non-conformance and identify the applicable regulatory requirements.
4.6 Risk Control: This process provides for risk / Aspect identification, risk assessment and mitigation decision-making.
5.0 KEY DEFINITIONS
5.1 HSE Risk
The most important definition associated with the process is HSE risk.
For the purpose of this process HSE risk is defined as the unique combination of an Activity, Product or Service plus a relevant aspect / Hazard plus the resultant impact /Risk. In short:
HSE Risk = [Activity, Product or Service] + [Aspect/Hazard] + [Impact/Risk]
Definitions for each of the HSE risk components are as follows:
- Activity / Product / Service: XXXXX operational practices, the company’s products and services that are offered to customers worldwide.
- Aspects- Any element of XXXXX activities, products and services, which can interact with the environment or human health.
- Impacts – any change to the environment or human health, whether adverse or beneficial, wholly or partially resulting from XXXXX activities, products and services.
- Hazards -Source or situation with a potential to harm in terms of human injury or ill health.
- Risk: combination of the likelihood of an occurrence off a hazardous event(s) or exposure (s) and the severity of injury or ill health that can be the event or exposure (s)
- Routine Activities (R): Regular jobs carried out under Normal operating condition of the plant.
- Non Routine Activities (NR): Irregular and periodic jobs carried out during start up/ shutdown etc. e.g.: Oil / Coolant spillage, Leakages of water from pipes. Preventive Maintenance activities.
- Emergency: Activities which may lead to emergency situations or Severe Environmental/Occupational health Impact. e.g. Fire, explosion, Earthquake, sabotage, Collapse of structure, Release of Toxic gases, Leakage in acid pipelines etc.
- Interested Party Concern (IPC): Concerns from person or group, inside or outside the workplace, affected by HSE Performance.
6.0 PROCEDURE
6.1 Risk Assessment
6.1.1 The list of HSE Core team members is maintained by MR. HSE Core team members are imparted training to conduct Risk Assessment to evaluate significant risks.
6.1.2 The initial risk assessment is carried out for all the processes, procedures and activities concerned with production process and as well as in support functions and the same are documented.
6.1.3 The relevant department shall join the risk assessment process or will be consulted for the risk assessment.
6.1.4 Risk assessment for onsite activities during starting of any new project is carried out as per HSE requirements of the customer and documented as HSE Plan and the approvals are obtained. Controls for significant Onsite HSE risks are identified and implemented as per the customer requirements throughout the completion of the project.
6.1.5 The concerned department personnel are informed about the hazards/ aspects in their work area pertaining to their activities and processes.
6.1.6 The personnel are trained on risk mitigation programs as a measure to control risks in the work area.
6.1.7 Any change in the process, procedure, equipment or activity in a particular department, is to be informed to the MR and a prior consent taken for the specified change after carrying out a risk assessment for the proposed change.
6.1.8 The risk assessment of the proposed change or consent from MR is required to / shall be documented.
6.1.9 After the change has been made, a follow up risk assessment shall be done and documented.
6.1.10 The documents pertaining to the risk assessment shall be kept with MR and a copy (in soft or hard) each with the relevant department.
6.1.11 While identifying Occupational, Health, Safety and Environmental (HSE) hazards and risk during initial HSE review, the following criteria shall be considered:
- Change, including planned or new developments, new or modified activities, products and services
- Abnormal conditions and reasonably foreseeable emergency situations.
- All activities where previous records of incidents occurred.
- Inputs from regular safety audits.
- All activity routine & non routine, where substantial / potential hazards and risks are involved.
- Evaluation of feedback from investigation of previous incident.
- Examination of all existing HSE procedures and practices.
- Activities of all personnel having access to the work place (including subcontractors and visitors)
- Facilities at the work place, whether provided by the organization or others.
- Inputs from Medical Records
- Inputs received from external interested parties
- Inputs received from any employee
- Emission to air
- Release of waste water
- Waste Management and conservation of natural resources
- Contamination to land
Based on the above, final list of activities of occupation health, safety & environmental (HSE) hazards and associated risks is documented.
6.2 Risk Assessment & Determining Significance
6.2.1 Criteria for risk assessment, developed through brain storming & discussion by core team and the Management Representative is using the tables here below:
| Frequency of Occurrence | Score |
| Very likely – High probability of HSE accident to occur. | 5 |
| Likely – Strong Probability that an HSE impact / dangerous occurrence will occur | 4 |
| Moderate – Reasonable probability that an HSE incident / near-miss may occur. | 3 |
| Low – Low probability, Have heard about this few years / months ago | 2 |
| Remote – Very unlikely | 1 |
| Severity | Score |
| Severe – Fatality / Very harmful to HSE, Complex long term effect. | 5 |
| Serious – Harmful – difficult to correct but recoverable over a period of time | 4 |
| Moderate – Somewhat harmful, short term loss | 3 |
| Minor – Little potential for harm, easily correctable, clearable | 2 |
| Not likely to effect | 1 |
| Time to notice the HSE incident / accident | Score |
| After Long time (1 month to 12 months) or Fatality / Damage noticed on the same day / Domino effect | 5 |
| Detected after one day | 4 |
| Detected beyond 12 hours | 3 |
| Detected beyond 4 hours | 2 |
| Detected beyond 2 hours | 1 |
6.2.2 Risk Assessment should be carried out using the form XXXXX/HSE/R 10
6.2.3 Identify all the Activities, Hazards and associated Risks in the cell contained in column (d) of the Risk Assessment Form XXXXX/HSE/R 10
6.2.4 Ensure that multiple hazards / aspects are not mentioned in the form.
6.2.5 For every activity the core team should document whether the activity is a Routine (R), Non Routine (NR), Column (e).
6.2.6 Document the associated Hazard/ Aspect and Risk / Impact in the column (f), (g).
6.2.7 if Activity which has a risk of life or risk of fire or severe environmental impact should be considered as an Emergency by denoting Y in the column 1
6.2.8 For the identified activity gather information from interested parties if the activity has any concern with respect to HSE.
6.2.9 If any concern is raised, document it as Yes () in column (2).
6.2.10 If the activity has a legal concern, document as Yes (Y).
Examples of Legal concern could be in the form of:
- Storage of LPG Cylinders
- Storage of Hazardous waste
- Working at heights
6.2.11 Evaluate if the Hazard in the work process has a Legal implication. If yes, indicate by denoting “Y” in the cell contained in the column (3)
6.2.12 If there is a potential for significant reduction / saving of natural and other resources, then please indicate RSP (Resource Saving Potential) as “Y” in column (4) and treat the aspect as a Significant aspect.
| Sl. No | Date of Entry (mm/dd/yy) | Areas/ Location | Activity | Activity Type R/ NR | Aspects / Hazards (Enter only one aspect or hazard in one row for any particular activity) | Impacts / Risk (Enter only one risk in one row for any particular activity) |
| Column (a) | Column (b) | Column (c) | Column (d) | Column (e) | Column (f) | Column (g) |
E(Emergency) (Yes / No) | IPC(Interested PartyConcern) (Yes / No)) | LC (Legal Concern) (Yes / No) | RSP(Resource Savingspotential) (Yes / No) | Present / Existing Controls | Severity(A) | Frequency of Occurrence (B) | Time to notice (C) |
| Column (1) | Column (2) | Column (3) | Column (4) | Column (h) | Column (i) | Column (j) | Column (k) |
Emergency , IPC, LC , RSP are the overriding criteria
| Present risk factor (ABC) | Calculated significance S/NS | Justification for converting Significant (S) to Non Significant (NS) | Final significance after justification S/NS | Link to Objective / Program, OCP |
| Column (l) | Column (m) | Column (n) | Column (o) | Column (p) |
6.2.13 Should there be an instance where any of the columns of Emergency (E), Interested Party Concern (IPC) / Legal Concern (LC) /RSP is applicable and is denoted by “Y” then these concerns will be an Overriding Criteria and not be evaluated further. But will be identified as a Significant risk by denoting “S” in the column (m).
6.2.14 Risks which do not have Emergency / Interested Party Concern (IPC) / Legal Concern (LC) should be denote by indicating “N” (No)
6.2.15 Risks where overriding criteria viz. Interested Party Concern (IPC) / Legal Concern (LC) are not applicable should be considered for Risk Assessment.
6.2.16 Any activity which is having Present / Existing controls, mention the same in column (h).
6.2.17 The risk criteria for severity (column(i)), Frequency of occurrence (column(j)) and Time to notice (column(k)) is applied to HSE risks as per the table 1 and present risk factor is calculated and mentioned in column (l)
6.2.18 Any HSE risk having a risk factor above or equal to 27 is considered significant and gradually lowered to cover all the HSE risks stages such that at one state all risks will be suitably addressed.
6.2.19 Any activities which are not listed in any regulation and have no existing control, the severity is rated as 3 and the risk is considered as Significant.
6.2.20 If the Risk has appropriate controls in the form of Engineering or Process control, justification for converting Significance into non-significance is recorded in column (n).
6.3 The Risk assessment register also contains control or reaction plan viz. the operational control measures/procedures, management program, emergency preparedness and response against all significant risks specified in column (p).
6.4 Significant HSE aspects are communicated to various levels and functions within XXXXX.
7.0 RECORDS
- Risk Assessment (XXXXX/HSE/R 10)
- HSE Plan for onsite activities.
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