How to Develop a Safe Operating Procedure · Definition: Critical Task A critical task is a task or...

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How to Develop a Safe Operating Pr ocedure A guide to researching, creating and issuing safe operating procedures in your workplace from start to finish. simplify your business portnerpress.com.au Michael Selinger Partner, Holding Redlich Lawyers

Transcript of How to Develop a Safe Operating Procedure · Definition: Critical Task A critical task is a task or...

How to Develop a Safe Operating ProcedureA guide to researching, creating and issuing safe operating procedures in your workplace from start to finish.

simplify your businessportnerpress.com.au

Michael Selinger Partner, Holding Redlich Lawyers

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

Are you the right person to develop the safe operating procedure? ............................. 2

What is a safe operating procedure? ....................................................................................... 2

Why do you need safe operating procedures? ...................................................................... 3

Who do safe operating procedures apply to? ........................................................................ 4

Step-by-Step: How to develop a safe operating procedure .............................................. 4

Template: Hazard Register ....................................................................................................... 15

Sample: Safe Operating Procedure ........................................................................................ 16

Template: Document Control Register ................................................................................. 17

Template: Training and Induction Record .............................................................................. 18

CONTENTS

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

ARE YOU THE RIGHT PERSON TO DEVELOP THE SAFE OPERATING PROCEDURE?

The person who will develop and write safe operating procedures

for your business should be experienced at performing the type of

work for which the procedure is being developed. Therefore, you may

find it beneficial to have different staff members develop the safe

operating procedures in different tasks and areas of your business,

and then have one person oversee the development of all the safe

operating procedures to ensure consistency, e.g. the health and

safety coordinator.

The person developing the safe operating procedure will also need to

consult with other workers who are familiar with the task and draw on

observations, knowledge and experience to identify hazards effectively.

Important: If the work is particularly complex, or involves specialised

knowledge, the safe operating procedure should be written by (or

with the assistance of) a technical expert.

WHAT IS A SAFE OPERATING PROCEDURE?

Definition: Safe Operating Procedure

A safe operating procedure is a written document that provides step-

by-step instructions on how to safely perform a task or activity in the

workplace.

A safe operating procedure should be used for tasks and activities

in your workplace that are undertaken on a regular basis and require

workers to follow step-by-step procedures to ensure the task is carried

out safely, e.g. cleaning a deep fat fryer (see page 16 for a sample).

Caution: A safe operating procedure should not be a generic

document, but one specific to the work you carry out. It should

be created after undertaking a risk assessment for the task.

Safe operating

procedures should be

developed by someone experienced

in the task

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

To develop your safe operating procedure, you need to:

� undertake hazard and risk identification for the particular work task;

� choose and implement control measures for those risks; and

� document the step-by-step procedure for carrying out the work and incorporate the control measures to

minimise the risk.

Important: Make sure you have procedures in place to regularly

monitor and review the safe operating procedures you have developed

to ensure that the procedures remain effective.

Once developed, the safe operating procedure will demonstrate

that you have taken into account any particular hazards that might

affect the work you carry out and how you control risks associated

with each task.

WHY DO YOU NEED SAFE OPERATING PROCEDURES?

As part of your duty of care under health and safety legislation, you

are required to provide and maintain a safe environment for anybody

who enters your workplace, including contractors and visitors.

Documenting procedures and eliminating unplanned approaches

to health and safety are a vital part of this responsibility.

The benefits of developing safe operating procedures include that

they:

� are regarded by law as an important aspect of complying with an employer’s general duty to protect their workers and others in the workplace;

� result in management having a better understanding of operational risks;

� reduce the risk of illness and injury in the workplace;

� raise awareness of health and safety among workers;

� demonstrate your business’s commitment to improving

safety in the workplace;

Identify hazards and risks for all tasks that are performed

You are required to protect the safety of all people who enter your workplace

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

� help to train workers to consider the steps required to

perform their jobs safely; and

� improve communication among workers and between

workers and supervisors.

WHO DO SAFE OPERATING PROCEDURES APPLY TO?

All workers (including contractors) must be inducted and given

regular training in the safe operating procedures that apply to their

work tasks. You must have evidence that they are competent in

these procedures.

Important: Under health and safety legislation, a workplace is any

place where work is performed. If your workers perform some of

their work from home or on the road (e.g. as a courier), your health

and safety obligations extend to these workplaces and you also

need to create safe operating procedures for those home office

environments and motor vehicles.

STEP-BY-STEP: HOW TO DEVELOP A SAFE OPERATING PROCEDURE

Safe operating procedures should be created for all major work

processes in your workplace that involve risk.

Important: Existing safe operating procedures should be reviewed

and new procedures should be developed whenever a change is

introduced in the workplace, e.g. when a new job or procedure is

adopted or when new equipment or substances are introduced.

Step 1: Familiarise yourself with how a safe operating

procedure should be written

Explanations of the way a work process should be carried out should

outline in a clear and simple way how the user should perform the

task so that the task can be completed in a safe and legally compliant

manner.

Benefits of developing

safe operating procedures

Develop a new safe

operating procedure each time

a change is introduced

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

Important: The safe operating procedure should be written in a way

that gives the person performing the task complete information on

how to safely undertake the task without needing to refer to other

resources.

An effective safe operating procedure must:

� be specific and provide step-by-step instructions;

� be written so that a person who has no prior knowledge of

the job can follow the safe operating procedure without

difficulty;

� use language that is clear and appropriately adapted to

the likely user (i.e. the worker who will undertake the task),

opting for simplicity wherever possible; and

� if necessary, use photographs or diagrams to provide

clarity or identify particular components in the safe

operating procedure.

Caution: If there are discrepancies between levels of literacy or

different native languages among your workers and contractors,

you must communicate your safe operating procedures in

appropriate ways so that they are understood by everyone. This

may require the safe operating procedure to be written in a number

of languages or by using additional diagrams or photographs

where appropriate.

Step 2: Identify all critical tasks in your workplace

Identify all critical tasks and activities carried out in the operation of your

business. Each of these tasks may require a safe operating procedure.

Definition: Critical Task

A critical task is a task or activity that the business performs on a regular

basis and is fundamental to the business’ s operation.

Critical tasks can be identified through observation and knowledge

of workplace operations.

How to write effective safe operating procedures

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

Tip: If you are not confident in identifying critical tasks and developing

appropriate safe operating procedures for your business, you can

engage an independent consultant to assist you with this process.

Step 3: Conduct a risk assessment to determine which

critical tasks need to be prioritised

Once you have identified the critical tasks in your workplace, you

need to determine which of these tasks have the highest level of

risk and this will determine the order you prioritise the development

of your safe operating procedures.

To do this, you need to conduct a risk assessment of each critical

task to determine:

� the likelihood of a risk occurring; and

� the seriousness of any possible outcomes.

When determining which critical tasks need a safe operating procedure

developed as a priority, focus on the most hazardous activities, e.g.

critical tasks that involve working with mobile plant such as forklifts,

working at heights or operating machinery. If there is a high chance

of a hazard causing an injury or illness, and the injury or illness is likely

to be serious or even fatal, that hazard should be addressed first.

When reviewing critical tasks to determine priorities, you must consult

the affected workers and supervisors who work in the area you are

assessing. These people often have greater knowledge of the task

and can help identify activities that carry greater risk.

Tip: Reviewing work injury and illness statistics (in the injury register)

and looking at incident investigation reports can help determine which

critical tasks in your workplace have the highest risk of injury.

Caution: Any change in the task or plant will require you to develop

additional safe operating procedures to identify and address any

new hazards that have been introduced.

Prioritise hazardous

tasks when developing

safe operating procedures

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

Important: Address the most serious risks first.

Step 4: Break up each critical task into operational steps

For each critical task you identify, you need to divide the task into

a number of operational steps. Doing this will assist you in drafting

step-by-step instructions so that the task can be performed safely.

Within each of these operational steps there may be a number of

separate steps required to ensure the task is safely performed.

Example

There may be a risk to a picker working in the warehouse floor of being

struck by a forklift, as well as manual handling risks if too many items are

picked up. The steps involved in that process may require the worker to:

1. Keep a proper look out for mobile plant before entering the

factory floor.

2. Approach the picking site by a designated walkway.

3. Only pick two items at a time.

4. Move the items to the packaging section of the warehouse

by placing the items on a pallet.

Additionally, each critical task may have associated tasks that will

require a safe operating procedure. For example, operating and

maintaining machinery may have a number of associated tasks which

require separate safe operating procedures, such as:

� cleaning processes;

� breakdown issues;

� maintenance; and

� quality inspection.

These separate documents will form part of the overall safe operating

procedure for the critical task. See the sample on page 16.

Example: Breaking up a task into operational steps

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

Step 5: Identify all the hazards associated with each

operational step

A detailed hazard identification process for each operational step is

the foundation for developing a safe operating procedure.

At this point, you should also review accident history (including near

misses) related to the operational step and conduct a review of the

task, consulting workers who regularly perform work of that kind.

For each operational step, make records of the associated hazards

– direct and indirect – these may need to be controlled separately.

For example, an operational step might include a direct hazard of

amputation when the equipment is operating, but also involve an

indirect hazard caused by noise exposure from the equipment that

also needs to be controlled.

Tip: Make records of the hazards and risk control measures and base

the operational steps in the safe operating procedure around these to

ensure that you develop an effective procedure. See page 15 for a

template hazard register.

To determine the hazards associated with an operational step, you

need to ask questions that are relevant to the task, such as:

� Could the worker trip or fall?

� Could the worker be struck by a falling object?

� Could the worker fall from a height?

� Is lighting adequate?

� Could clothing or a body part get caught in the moving parts of a machine?

� Could debris fly out from the machinery?

� Are there any live electrical hazards in the vicinity?

� Is there excessive noise or dust in the work area?

� Could the worker come into contact with chemical or biological hazards?

A single task may require

separate controls for each hazard

Consider these

questions in relation

to each operational

step

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

� Is ventilation adequate, particularly if the worker is in a confined or enclosed space?

� Are employees wearing suitable personal protective equipment (PPE) for the work?

� Could employees come into contact with moving vehicles, such as forklifts?

� Does the job involve hazardous manual handling, such as lifting heavy boxes?

� Does the body position or location create a hazard?

� Will interaction with surrounding activities create a hazard?

Definition: Personal Protective Equipment (PPE)

Personal protective equipment is equipment used or clothing worn

by workers to reduce the risk of illness or injury from exposure to

workplace hazards.

Tip: When identifying the hazards associated with each operational

step, consider the different ways that hazards may arise. These

could include mechanical hazards (e.g. rotating parts, sharp edges,

etc.), environmental hazards (e.g. noise, temperature and terrain)

or ergonomic hazards (e.g. awkward working postures, strains from

lifting, etc.).

Step 6: Choose risk controls for the identified hazards

Each identified hazard must be accompanied by the precautions and

control measures which, when carried out by the operator, will either

eliminate the hazard or reduce the hazard to an acceptable level.

After you have listed each hazard, determine whether the job can

be performed in another way that eliminates the risk. If this is not

possible, use the hierarchy of control to determine control measures

to reduce the risk of injury or illness.

Consider questions such as these to determine what hazards exist

Can the job be performed in a way that eliminates risk?

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

To use the hierarchy of control, consider each hazard and ask, in this

order:

1. Can the hazard be removed completely (e.g. by modifying

equipment, choosing a different process or removing

people from the hazard)?

2. Can the hazard be isolated (e.g. by only cleaning the

machine when it’s switched off and tagged)?

3. Can risk controls be engineered (e.g. safeguarding)?

4. Can you think of ways to reduce exposure to the hazard

(e.g. by using protective equipment and/or performing

the task for shorter periods of time)?

Tip: If you are considering a new procedure for performing a job,

discuss it with relevant workers. Their feedback and recommendations

will be invaluable for fine-tuning the safe operating procedure.

Important: Safe operating procedures are specific to particular tasks

and pieces of machinery in the workplace. A different safe operating

procedure should be drawn up for every task and piece of machinery,

even if there are only small differences between them.

Any change in the job process should also involve a review of the

adequacy of any existing safe operating procedure.

Tip: Warnings about performing particular tasks provide further

information to enable workers to perform the task safely. For example,

when working in a noisy environment, a general caution about wearing

ear protection should be included in your safe operating procedure.

Additionally, mandatory safety matters should be referenced at the

start of any safe operating procedure document, such as the need

for the operator to be:

� licensed; or

� wearing correct PPE, e.g. a seatbelt and a safety vest.

Using the hierarchy

of control to reduce risks

Include information

about mandatory

safety matters

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

Step 7: Create and review the draft safe operating

procedure

Once you have collated all this information, develop a draft safe

operating procedure and distribute it to all relevant workers to review

the procedure and provide feedback. The aim of this is to ensure that

the content is accurate and without gaps.

Show drafts of the safe operating procedures to all workers who are

likely to be involved in or affected by the task, including:

� operators;

� maintenance personnel;

� cleaners;

� supervisors;

� health and safety representatives (HSRs); and

� health and safety committee members.

Make notes about any suggestions for how the safe operating

procedure can be improved.

Assess the feedback and adapt the draft by:

� collating all comments; and

� consulting further about suggested improvements.

Step 8: Approve and issue for use

Prior to a safe operating procedure being issued for use, all relevant

staff members need to approve the final draft.

Relevant staff members can include:

� the department manager or supervisor;

� an HSR;

� the health and safety committee; and/or

� a health and safety coordinator.

A copy of the safe operating procedure should be:

� displayed in the work area where the procedure or task

is undertaken, e.g. posted on the relevant piece of

machinery;

Obtain feedback on the safe operating procedure to ensure it is accurate and complete

Make sure the safe operating procedure is displayed and easily accessible

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

� stored in a suitable place for reference; and

� kept somewhere that all workers can access, e.g. on the

company intranet.

Step 9: Maintain control of documents

To maintain control of documents, each safe operating procedure

must be:

� dated; and

� assigned:

� a procedure number;

� a version number;

� a review date; and

� a copy number.

Definition: Copy Number

A copy number is a number allocated to the department where a safe

operating procedure will be used.

Important: Set up a document control register so that you know:

� which safe operating procedures have been issued;

� the date of issue; and

� who they have been issued to.

The register should state how often the procedure will be reviewed

and set out the next scheduled review date. See page 17 for a

template document control register.

Step 10: Train your workers in the safe operating procedure

All workers must be instructed, trained and educated on the hazards

of the tasks they are required to perform and how to follow the safe

operating procedure. This instruction, education and training regime

needs to be tested to ensure it has been effective.

Ensure that documents

are adequately maintained

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

Workers who are likely to perform a critical task in the future, and not

just those who currently perform it, should be provided with training

about the task’s safe operating procedure. All new workers likely to

perform the task must be instructed about the procedure as part

of the induction process.

Important: Under the WHS Act, it is not enough to train workers

(including contractors) on the safe operating procedures. You

must also be sure they are competent and make records of their

competency. A training and testing register that makes a record of

when training and testing has been conducted should be kept in the

safe operating procedure folder.

Tip: Retain a record of the training and regularly test your workers’

knowledge of safe operating procedures to ensure the training has

been adequate. You should keep a record of all test results. See page

18 for a template training and induction record.

Step 11: Supervise workers and enforce safe operating

procedures

Regular supervision is necessary to ensure everyone who undertakes

the critical task complies with the approved and documented safe

operating procedure.

Higher levels of supervision are required when:

� the task is initially assessed;

� the task is complex and involves multiple risks; and

� inexperienced workers are expected to follow the safe

operating procedure.

Important: If an employee deviates from the written procedure, their

supervisor should take immediate action to counsel or discipline

them and show them the correct method of carrying out the task.

Re-training may be required.

Test your workers to ensure they understand how to safely perform tasks

Supervise workers to ensure compliance

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

Step 12: Review your safe operating procedures

You should review your safe operating procedures if:

� you receive a request to do so from your workers or contractors, e.g. if there is a gap in the procedure which did not become apparent until later;

� you notice there is repeated non-compliance with the documented safe operating procedure – this may indicate an error in content or a need to revise the procedure or re-train workers;

� there is a change to a task, process, plant or environment;

� there has been an incident involving the task, process or plant (whether it resulted in an injury or a near miss);

� there is fresh information about a hazard – this information could come internally from a worker or externally from the safety regulator, manufacturer or industry association; or

� you have reached the time period specified by your document control register (typically every 1–2 years).

When should you review a

safe operating procedure?

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

HAZARD REGISTER

[Insert description of critical task]

Company name: ……………………………………………

Site name:……………………………………………………

Procedure no:………………………………………

Version no:…………………………….

Copy no:……………………………..

Review date:………………………………………………………….

Critical Task:…………………………………………………………

Basic steps Hazards Risk controls

TEMPLATE: HAZARD REGISTERClick title to

download

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HOW TO DEVELOP A SAFE OPERATING PROCEDURE

SAMPLE: SAFE OPERATING PROCEDURE

SAFE OPERATING PROCEDURE

Critical task: Cleaning the deep fat fryer

Document no: 072

Date: 17/05/15

Personal protective equipment

Wear the following personal protective equipment during all steps:

� goggles and face shield;

� elbow-length rubber gloves;

� a rubber apron long enough to cover your lower legs; and

� non-slip, closed-toe shoes.

Task: Draining the hot oil from the deep fat fryer into a container

1. Allow the oil to cool as much as possible before removing it from the deep fat fryer. Turn off the fryer 3 hours ahead of time.

2. Use the designated metal container marked “For Hot Oil Use”. It has a metal lid, a handle at the base and is fitted with clasps.

3. Ensure that the container is dry.

4. Fit a hose to the drain spout of the fryer and carefully direct the oil into the container.

Task: Transporting the oil through the kitchen and out to the oil dump drum

1. Make sure aisles and pathways are clear of tripping hazards and that the outdoor path to the drum is not slippery.

2. Make sure the container is closed properly.

3. Use a dolly to move the container. Make sure the container is securely fastened.

Task: Transferring the oil from the container to the oil dump drum

1. Check that your personal protective equipment is properly adjusted to protect you from spills or splashes.

2. Grasp the handle at the base of the container as you pour the oil into the drum.

Caution: Handle and dispose of hot oil safely.

Many metal buckets have metal lids with clasps and a tight seal to prevent splashing.

Newer fryers incorporate automatic draining systems that minimise the risk to workers. In addition, a variety of specialised equipment is available for safe handling and disposal of hot oil.

Contact your local restaurant equipment supplier for more information.

Source: WorkSafe ACT, www.worksafe.act.gov.au.

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17

HOW TO DEVELOP A SAFE OPERATING PROCEDURE

TEMPLATE: DOCUMENT CONTROL REGISTER

DOCUMENT CONTROL REGISTER

Document name and

numberLocation

Initial

issue date

Current

version

issue date

Review

date

Person

responsible

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18

HOW TO DEVELOP A SAFE OPERATING PROCEDURE

TEMPLATE: TRAINING AND INDUCTION RECORD

TRAINING AND INDUCTION RECORD

Name of trainee: ...................................................................................................................................................

Name of trainer/s: ................................................................................................................................................

Induction

Date and time completed: ..........................................................................................

Signature of trainee: .....................................................................................................

Signature of trainer: ......................................................................................................

Notes: ...............................................................................................................................

............................................................................................................................................

Operation of Machinery

Date and time completed: ..........................................................................................

Signature of trainee: ....................................................................................................

Signature of trainer: ......................................................................................................

Notes: ...............................................................................................................................

............................................................................................................................................

Accident and Emergency Procedures

Date and time completed: ..........................................................................................

Signature of trainee: ....................................................................................................

Signature of trainer: ......................................................................................................

Notes: ...............................................................................................................................

............................................................................................................................................

Personal Protective Equipment

Date and time completed: ..........................................................................................

Signature of trainee: ....................................................................................................

Signature of trainer: ......................................................................................................

Notes: ...............................................................................................................................

............................................................................................................................................

First Aid Facilities

Date and time completed: ..........................................................................................

Signature of trainee: ....................................................................................................

Signature of trainer: ......................................................................................................

Notes: ...............................................................................................................................

............................................................................................................................................

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