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Can a functioning OHS management system help prevent fires at your factory?



And that’s not all. This week we also heard of the fire at a paper factory in Kya Sands:


Condolences to the families and friends of the victims


These are tragic incidents. My heartfelt condolences and prayers go to the families and friends of the deceased.


Why I am writing this article


During the past few months, I have been busy with Occupational Health and Safety Management Systems (OHSAS 18001 & ISO 45001 implementation).


I couldn’t help think how an OHS management system could have potentially prevented the September 2018 fires.


The basis of assertion is the initial statements made by the top management of the affected facilities.


The statements indicate a gaps on their existing OHS management system.


Let me show you what I mean


  1. Kya Sands factory manager response

“…I said I will rush to get to the factory and I will try to pull out the fire extinguisher. But getting closer to the factory I saw it was beyond my expertise. The flames were just large and I would never be able to put it out…” – Factory management

It is a paper factory, right!? The major hazard would be the paper catching fire.


So, you would think that there would be provision for fire detection and extinguishing systems/devices.


And you would think the persons at site know how to operate these systems/devices. So, why did they have to wait for the factory manager to come and make a decision on using the fire extinguisher on site? And, shouldn't the factory have a central firefighting system?

“…large rolls of paper inside the factory and low water pressure in the area made it difficult for firefighters to fight this massive blaze…” – Reporter at the scene

Shouldn't there be fire and smoke detectors installed? And, how long did has the low water pressure in the area been an issue?


  1. Gauteng Provincial Government building

“…Gauteng Infrastructure Development MEC Jacob Mamabolo said a recent inspection had found the building’s safety compliance rate stood at 21 percent. The acceptable rate is above 85 percent…” – Daily Maverick

Thixo.


“We found that the buildings were not compliant with occupational safety. On this building we discovered non-compliance.” – MEC Jacob Mamabolo

“We can’t speculate on the causes of the fire at this stage because we don’t have feedback from qualified people. As the City of Johannesburg we’ll get a report as to what caused the fire.” – MEC Jacob Mamabolo

“We are not in denial about that. That’s the same reason we commissioned the investigation.” – MEC Jacob Mamabolo

“Let’s wait for the report before we can speculate on who should be held accountable.” – MEC Jacob Mamabolo

Un. be. live. able…


The one aspect I love about ISO 45001 is its emphasis on leadership.


I think Mr. Mamabolo thought he was showing leadership by admitting that there were problems on the building and they knew about them.


Let me leave my comments there before I get into trouble.


Let’s just say I am extremely disappointed that such a senior official can come to National television and speak in this manner.


“…they conduct inspections on the buildings every year…” - Premier Makhura

I think it is highly unlikely to go from a 85 - 100% compliant building to 21% compliant building in a space of 12 months.


If it is possible, then there is a serious leadership problem and the OHS management system is decapitated.


And lastly, can I certainly state that the Gauteng Provincial Government did not comply with their duties in terms of Section 8 of the OHS Act!?


This is because the head of infrastructure knew about the 21% OHS compliance of the building and the Department continued to house its employees on the building.


Sigh.


Rheinmetall Denel Munitions Factory response


“We are investigating the matter…” – Rheinmetall Denel Munition

I think a better response that would indicate a functioning OHS management system would be:

“The explosion happened on building X. We can confirm that the building met the legal and other requirements. We can also confirm that our fire detectors and control systems were last inspected on day X. They were found to be satisfactory. We are investigating this matter further to determine which systems failed.” - Mr. Nkululeko Thusini sample response

Not a one liner – “We are investigating the matter.”


Sigh.


Five OHS management system steps that could assist in preventing fires at your factory


Ok, enough of my rant.


Let me help you with some tips on how an OHS management system can help prevent fires at your factory.


Let’s look into the common causes of fires at a factory. I took three articles which I thought were spot-on with this regard:

Conclusion: The common cause of fires in a factory are as a result of hazards occurring.


Step 1: Hazard Identification and Risk Assessment (HIRA)


The common theme on these articles and other similar articles is that factories need to firstly identify the hazards and determine control measures to mitigate risk associated with the hazards.


Hazard identification and risk assessment (HIRA) forms the basis of a good OHS management system.


You can make use OHSAS 18001 (OHS Management System Guidelines – Requirements) and ISO 45001 (OHS Management System – requirements) to assist you with HIRA.


Remember, a hazard is defined as the:

"source, situation, or act with a potential for harm in terms of human injury or ill health, or a combination of these." - OHSAS 18001

And, a risk is defined as the:

"combination of the likelihood of an occurrence of a hazardous event or exposure(s) and the severity of injury or ill health that can be caused by the event or exposure(s)." - OHSAS 18001

Step 1 conclusion: Identify hazards identification associated with all activities and sources at your factory. Evaluate the likelihood and impact of the occurrence of these hazards


Step 2: Determine control measures


Next, you need to determine and implement control measures.


The control measures need to eliminate or reduce the risk associated with a hazardous event or exposure(s).


The control measures hierarchy needs to be as follows:

  • Elimination e.g. The Gauteng Provincial Department could have spent all their efforts to have the building 85 – 100% safety compliant. This way, you would have eliminated some of the hazards associated with the non-compliance.

  • Substitution e.g. the Kya Sands factory could have installed a fire water reticulation system with on-site pumps to substitute the use of fire extinguishers to fight fires.

  • Engineering controls e.g. the Kya Sands factory could have installed fire and smoke detectors which would activate the firefighting system at specified set points.

  • Signage, warnings and administrative controls e.g. The Gauteng Provincial Department could have condemned the 21% compliant building and move all persons out of that building as a matter of urgency before this incident could occur.

  • Personal protective equipment e.g. making provision of breathing apparatus in the building. - I am just grasping on straws on this example :)

This means that you have to first seek to eliminate the risk before you can use substitution, engineering controls, administrative and/or personal protective equipment.


Step 2 conclusion: Determine control measures that will eliminate or reduce the likelihood and impact of the hazards associated with activities and hazard sources at your factory.


Step 3: Determine and comply to legal and other requirements


The number one legal requirement for most factories is the Occupational Health and Safety Act.

"Every employer shall provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to the health of his employees" - OHS Act Section 8(1), General duties of employers to their employees

Other requirements can relate to specifications, standards and engineering best practices.


You would have to at least determine the following for your factory:

  • The standards and specifications your machinery and systems need to comply with,

  • The agreed safe operating values for your machinery and systems,

  • The safe work procedures,

  • The checklists and forms to be used for audits, maintenance checks, operation checks etc.,

  • The routine inspections and maintenance that need to be done on machinery and the system etc.

Step 3 conclusion: Determine the legal and other requirements you need to comply with. Ensure that you take action to ensure compliance.


Step 4: Establish the OHS objectives and programmes


You need to establish the OHS definition of success.


This will mean that you must determine matrices and indexes that will measure the OHS performance.


This may include:

  • Lost time injury

  • Total man hours

  • Recordable incident frequency rate

  • System availability indicators

  • Incident and non-compliance investigation indicators

  • Incident and non-compliance corrective action indicators

Step 4 conclusion: Determine the OHS key performance indicators. Develop a programme or system that will ensure you can measure the performance and take corrective actions where there is none or poor performance.


Step 5: Implement and control


Implementing the OHS management system is the most critical part.


You will need to get commitment from the top management and all persons at the organisation to achieve successful implementation.


The top management needs to:

  • determine and make available, in a timely and efficient manner, all the resources needed to prevent injuries and ill health in the workplace.

  • identify who needs to do what with respect to the management of OH&S and make sure they are aware of their responsibilities and what they are accountable for.

  • ensure that those members of the organisation’s management with OH&S responsibilities have the necessary authority to fulfil their roles.

  • ensure there is clarity of responsibilities at the interfaces between different functions

  • appoint one of its members as the person responsible for the OH&S system and reporting on its performance.

Step 5 conclusion: Implement your control measures, and legal & other requirements. Ensure that you continuously measure performance and implement operational controls that will assure compliance and performance. Ensure you have support from top management at all times.


Conclusion


The fires that occurred so far during September 2018 make me very angry.


Putting simple systems in place and ensuring implementation of these systems could have prevented the loss of lives.


The lack of understanding and care by top management on their duties in terms of Section 8 of the OHS Act is very worrying.


In this article, I gave a high level summary of some of the OHS management system requirements.


You can follow these five steps to ensure that you prevent fires at your factory:

  • Step 1: Identify hazards identification associated with all activities and sources at your factory. Evaluate the likelihood and impact of the occurrence of these hazards (aka Risk Assessment).

  • Step 2: Determine control measures that will eliminate or reduce the likelihood and impact of the hazards associated with activities and hazard sources at your factory.

  • Step 3: Determine the legal and other requirements you need to comply with. Ensure that you take action to ensure compliance.

  • Step 4: Determine the OHS key performance indicators. Develop a programme or system that will ensure you can measure the performance and take corrective actions where there is none or poor performance.

  • Step 5: Implement your control measures, and legal & other requirements. Ensure that you continuously measure performance and implement operational controls that will assure compliance and performance. Ensure you have support from top management at all times.

Remember, you can make use of OHSAS 18001 or ISO 45001 to develop or improve the OHS management system at your factory.


NOTE: ISO 45001 published in March 2018 and will be replacing OHSAS 18001 in the next three years.

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