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Health Risk Assessment

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Health Risk Assessment

اسلاید 1: Health Risk AssessmentControlling health risks at work

اسلاید 2: What is HRA ?

اسلاید 3: Identifying and Assessing Health HazardsSelection of teamIdentifying and assessing Health HazardsIdentifying Control StandardsIdentifying nature and degree of ExposureEvaluating Risk to HealthDeciding on Remedial Action

اسلاید 4: Selection of teamThe selection and expertise of the Health Risk Assessment Team will be dictated by:Size and complexity of the Assessment Unit or activity being assessed e.g. Platform, Gas PlantNature and severity of of the hazards and risks involvedFamiliarity of the activities

اسلاید 5: Selection of teamTeam Leader / Asset owner–Line manager such as OIM, plant manager or representative of facility being assessedTeam Member – Individuals such as operational staff, line supervisor familiar with plant operation and processLocal Advisor – Individuals such as medic/OH nurse, HSE advisor, who can advise on the HRA process and exposure controlsSpecialist Staff – Occupational hygienist, OH physician, toxicologist, ergonomist

اسلاید 6: Selection of teamTo gather necessary information team members must be able to:Observe the activity being performed Predict any potential departure from observed practiceAsk supervisors, staff etc. the relevant questionsUndertake simple diagnostic testsIdentify and review relevant technical literatureGather the information systematicallyForm valid, justifiable conclusions about exposures and risks

اسلاید 7: Selection of teamTo gather necessary information team members must be able to:Follow up fundamental questions about any exposures to occur.Appreciate the range and limitations of possible control measures and their relative reliabilityLook critically at existing arrangementsSpecify the type of control measures neededAsk for specialist assistance if required

اسلاید 8: Selection of TeamThe required level of skill and level of competency for the team:Team LeaderAwareness - Working knowledgeTeam MemberWorking knowledge - SkilledLocal AdvisorSkilledSpecialistMastery

اسلاید 9: Competent Persons ‘ .. a man who has the knowledge to know what he is looking for and the experience to recognise it when he sees it ...’ Competence is a function of: Knowledge Skill Experience

اسلاید 10: Gathering Information How to select Assessment Units Identify Health Hazards Identify harmful effects Assign Hazard Rating (RAM Consequence)

اسلاید 11: How to select Assessment UnitsThe assessment unit is what is within the boundaries of the HRAAssessment units should be self-contained, either physically or as a processIt should cover all aspects of the working environmentThe nature and the severity of the hazards and risks involved, the familiarity of the task, available resources and country-specific requirements should be taken into account

اسلاید 12: Organisation and PreparationDo not forget to: Set a realistic time frame to actually carry out an HRAConduct an HRA according to a mutually agreed programUse standardized HRA formatsProvide sufficient time for report writing, sharing comments and feedbackKeep ownership of HRA with the Business Unit

اسلاید 13: Organisation and PreparationCollect pre reading material and references such as: Plans and drawings for plant specificationsIncident / injury reports (incl. occupational illnesses) and incident investigationsPlant and equipment fault reports Maintenance records for control measuresRecords of health surveillance and sickness absenceOccupational hygiene surveys, health and safety surveys Minutes of health and safety committee meetings

اسلاید 14: Additional sources of informationCollect pre reading material and references such as: Relevant Shell HSE publicationsBusiness Health Hazard InventoriesCompany standardsNational legal standardsLocal health regulations(Inter)national guidelines and standards (WHO, ISO)Industry standards, manufacturers/suppliers data

اسلاید 15: What are Health HazardsA Health Hazard has the potential to cause harm to healthHealth hazards may be divided into the following groups: chemical biological physical ergonomic psychological

اسلاید 16: Health hazards of primary concern Cause fatalities in the short or long term e.g. infectious diseases (short term), carcinogenic substances (long term) Expose the company to substantial future social and monetary liabilities e.g. noise induced hearing loss, repetitive strain injury, psychological stress Cause minor health effects which could cause severe business disruption e.g. major food poisoning outbreak

اسلاید 17: How to identify Health HazardsWalk through surveys Looking, smelling, talking, listening; use your senses!Refer to Health Hazard InventoriesUse HRA Yellow Guide, appendix 2Look at Recordsincident/fault reports, inspections, maintenance, sickness absence, hygiene surveys, operating proceduresUse experience from elsewhere

اسلاید 18: Practical Exercise Identify Health HazardsChemicalPhysicalBiologicalErgonomicPsychological

اسلاید 19: Identify Harmful EffectsThe harmful effects potentially caused by a hazard need to be identifiedExamples of harmful effects:DeathAcute or chronic illnessesDisabilityReduced job performanceReduced healthConcern

اسلاید 20: Types of EffectsAcute, immediateLung, skin or eye damage from corrosive liquidAcute, late onsetSick building syndrome Chronic, intermittent / on-offRepetitive Strain InjuryChronic permanentLung cancer

اسلاید 21: Datasheets, labels, manualsGuidance material, e.g Health Hazard InventoriesOccupational health advisorsJournals and reference literatureNational competent bodies and institutesGovernmental bodiesNGOsIdentification of Effects

اسلاید 22: Identify Health Hazards and their Harmful EffectsHazardSourceRouteHarmful Effect

اسلاید 23: Identify Health Hazards and their harmful EffectsAgentSilica dust (crystalline)Used mineral oilsNoise HeatLegionella bacteriaRepetitive movementsSourceRefractory bricksEngine oilProcess noise above 85dB(A)Plant heatSpray cooling towersWorkplace designRouteInhalationSkinHearing Whole bodyInhalationWhole or part of bodyHarmful EffectLung disease (silicosis)Dermatitis, cancerHearing Loss Heat stress, heat strokeLegionnaire’s DiseaseMusculo-skeletal disorders

اسلاید 24: Cumulative exposureIndividual susceptibilityThreshold levelsKnowledge gapsWorkstyle changesReal world practicesFactors influencing the Relationship between Hazard and Risk

اسلاید 25: Assigning Hazard Ratings

اسلاید 26: Hazard RatingsConsider Harm to:PeopleAssetsReputationSelect the category with the highest consequence rating!

اسلاید 27: Practical Exercise - Assigning Hazard Ratings Assign hazard ratings to the selection of health hazards identified Discuss in open forum

اسلاید 28: Risk Assessment MatrixThe Risk Assessment Matrix (RAM) is the tool which allows assessment of the risk to the business from each identified health hazardIt will assist you in prioritizing potential health risks and determine which risks need documented demonstration of controlsEnsure that health risks are assessed properly by taking into account acute and chronic harmful health effects

اسلاید 29: ConsequenceEstimate of what could happen (acute and chronic)LikelihoodAcute - Estimated on the basis of experience and or evidence that a certain outcome has previously occurredChronic - Estimated based on the historical evidence that excess exposure has occurredHealth Risk = Consequences X Probability (Likelihood)

اسلاید 30: Manage for continuous improvementIncorporate risk reduction measuresIntolerable – investigate alternativesRisk Assessment Matrix

اسلاید 31: Health HazardExamples of situations or activities in which the health hazard may occurHarmful health effects from over exposure (Consequences) Consequence Category (harm to people) - CLikelihood - LRAM Risk Rating (C x L)Chemical HazardsAsbestos Materials containing asbestos, for example, gaskets, ceiling tiles, partitians, insulationAcute: Mildly Irritating to eyes and respiratory tractChronic: Category 1 carcinogen Cat 1 Carcinogen: 4/5 C 5C - HighBenzeneProcessing, handling and distribution of benzene containing process streams and products, e.g. naphthas, platformate, condensate, gasoline.Acute: Irritant to eyes and respiratory tract; narcotic to CNS.Chronic: Category 1 carcinogen Cat 1 Carcinogen: 4/5 B 5B - MediumEthylene oxideShell chemicals marketed product and process materialAcute: cold burns to skin and eyes. Shortness of breath, dizziness and drowsiness on inhalation. May cause pulmonary oedema. Chronic: Category 2 carcinogen and mutagen Cat 2 Carcinogen: 4/5 B 4B - MediumEpoxy ResinsContained in some adhesives (maintenance)Acute: Irritant to skin and eyesChronic: skin sensitiser Sensitiser: 3 C 3C - MediumHydrogen sulphideWaste gas stream; sour crude oil; condensates; bitumen and fuel oil tank head spacesAcute: Chemical asphyxiant causing respiratory paralysis.Chronic: n/a Chemical asphyxiant: 5 C 5C - HighGeneric RAM HRA outcomes

اسلاید 32: Low RAM Ratings Manage for continuous improvementvia standard procedures and competences in HSE-MS (ensure these are adequate)ensure Exposure Limits and other control standards are met

اسلاید 33: Medium and High RAM Ratings Detailed review of controlsStandards of controlWho is exposed and whenEstimate or measure exposureCompare existing controls against standards (are OELs met and risks As Low As Reasonably Practicable - ALARP?)Consider need for routine exposure monitoring and/or health surveillance For risks assessed as Highgive serious consideration to alternative ways of carrying out the operation

اسلاید 34: Control and RecoveryIdentify exposureHierarchy of controlsControl standardsUse of control chart for individual riskApply ALARP principleExposure measurementsHealth Surveillance

اسلاید 35: What is exposure?Exposure is defined as:The amount of the hazard to which a person has been exposed(dose). This is a combination of the magnitude, frequency and duration of exposure

اسلاید 36: ExposureDurationFrequencyMagnitude (extent of exposure) is affected by:Concentration/intensity of the agentWork practicesAgent’s physical characteristic impacting on the exposure routeExisting controls

اسلاید 37: LungEarEyeSkinNoseMouthMusculo-skeletalWhole bodyExposure routes

اسلاید 38: Hazards and Exposure routes

اسلاید 39: LungHeartDigestive tractLiverKidneysEarEyeSkinNoseMouthCentral nervous systemMusculo-skeletal systemReproductive systemTarget Organs

اسلاید 40: Hazard, exposure route and target organ

اسلاید 41: Factors Affecting Intake for chemical and biological agentsPhysical form Gas/vapour/liquid/solid Particle size Particle shape Solubility Carriers Breathing rate

اسلاید 42: Identify who is exposed:Divide workforce into groups (Job Types) with expected similar exposuresEstimate the exposure level:Identify and review tasks involving potential exposureBase estimate on a combination of qualitative and quantitative assessments of exposure, as neededEstablish the effectiveness of existing controlsHow to identify exposure

اسلاید 43: Identify who is exposedTypical Job Types Plant Operators - divided by operational group Road Tanker Drivers - divided by product group Maintenance Staff - mechanical, electrical, vehicle etc. Cleaning Staff - plant and/or office Laboratory Technicians - sub-divide as appropriate Administrators - office based with minimal plant exposure Field Staff - geologists

اسلاید 44: Identify tasks:Use workplace experienceReview historical recordsDiscuss with staff involved in doing the taskVisit work area/walk through surveyInclude tasks involved in:Normal operationsMaintenanceAbnormal conditions and foreseeable emergenciesEstimate exposure level

اسلاید 45: Estimate exposure levelWhat is a ‘task’ ? An activity which a competent person can be instructed to do in a single sentence A plant operator could be asked to take a process stream sampleA plant cleaner could be asked to deal with a spillage A fitter could be asked to take a pump out of service A laboratory technician could be asked to analyse a sample for benzene content

اسلاید 46: Estimate exposure levelReview tasksFrequency, duration and estimates of concentration/intensity of exposure Work practices and existing controlsEffectiveness of existing control measuresCompare existing controls against relevant control standardsWho else is exposed?Employees, contractors, third parties

اسلاید 47: Exposure may be acceptable when: evidently so operations are in accordance with suppliers’ documented procedures previous measurements under similar or worst case conditions indicate low exposure process operated in accordance with recognised guidance on good practiceEstimate exposure level-without exposure measurement

اسلاید 48: Exposure may be unacceptable when: there is evidence of fine dust deposits fume or particles are visible in light beams there are broken, defective or poorly maintained controls the process is not operated in accordance with recognised guidance on good practice complaints are made of discomfort or excessive odour ill-health related to exposure is detectedEstimate exposure level-without exposure measurement

اسلاید 49: The hierarchy of controls is a list in preferential order of the means by which exposure to health hazards can be controlledEliminationSubstitution (alternatives)Engineering (plant and equipment)ProceduralPersonal protective equipmentHierarchy of controls

اسلاید 50: Types of controlsElimination and substitutionEngineering (plant and equipment):Equipment/processes designed to prevent or minimize release of the hazardExamples: containment (enclosure), exhaust ventilation, remote venting/vapor recovery systems

اسلاید 51: Types of controlsProcedural: Safe systems of work / Permit to work system Record systems Staff Instruction, Information & training Supervision, Emergency arrangementsPersonal Protective Equipment (PPE): Respiratory & Skin Protection as a secondary line of defence or as the only option

اسلاید 52: Effectiveness of ControlsThe types of control vary in their effectiveness according to the control hierarchy:EliminationMost EffectiveSubstitutionEngineeringProceduralPPELeast Effective

اسلاید 53: Control selectionControl selection to achieve ALARP must consider the control effectiveness and cost:consider the most effective controls firstlimit PPE to:infrequent tasks temporary use until more effective controls are in placeas a precaution should other controls fail

اسلاید 54: Maintenance of controlsControls are only effective if they workEngineering controlsPreventive maintenance, inspections and testsProcedural controlsRecord systems, information and trainingEffective supervisionPPERoutine maintenance, inspection and trainingEmergency measuresInspections and realistic exercises

اسلاید 55: Control standardsOccupational Exposure Limits (OELs)Specifications for control:Engineering Control Standards (SES, DEP)Procedural (manufacturer’s/supplier’s info/industry good practice)Personal Protective Equipment National, Company, Group, Industry and International Standards

اسلاید 56: Chemical agentsOccupational Exposure Limits are levels of airborne concentrations of hazardous compounds that are considered safe for the workplaceOEL’s and recommendations are set by competent national authorities OEL’s are normally used for chemical agents, but the concept can also be applied for physical, biological and psychosocial agents and for ergonomicsWhat are exposure limits?

اسلاید 57: Physical Agents, e.g.Shell ‘Noise Guide’ recommended criteria Daily Noise Dose - 85 dB(A) Leq Design Limit - 85 dB(A) at 1 meterCold stressIonising radiationHeat stressLasersVibrationsOccupational exposure limits

اسلاید 58: Biological agentsControl to as low as reasonably practicableErgonomicsInclude ergonomic principles to all work activitiesPsychologicalRefer to specialist for evaluation and treatmentOccupational exposure limits

اسلاید 59: Engineering control standardsFace velocities of Lab Hoods should meet recognized design standardsRotating equipment mechanical seals that do not leak Transfer lines/hoses with disconnect fittings that do not leakCapture velocities for welding hoods meet recognized ventilation standardsEngineering controls are inspected regularlyEngineering controls are on a PM (preventive maintenance) schedule

اسلاید 60: Procedural standardswritten procedures for tasks involving exposure (permit to work system)procedures include work practices that minimize exposurework practices are understood (e.g. training & validated by testing) and followed by employees (supervision, validated by auditing)

اسلاید 61: Personal Protective Equipment respirators gauntlets (gloves) goggles protective clothing foot protection

اسلاید 62: Personal protective equipmentAdequate use of PPE includes an assessment of:PPE requirement for each taskPPE selection to match the hazard PPE is practical & functional for the task PPE requirements are understood by employees (e.g. training & validated by testing)PPE is used correctly (e.g. training & validated by audit))PPE is used when required (validated by audit)PPE is inspected and maintained regularly (validated by audit)

اسلاید 63: Practical Exercise Selecting Control Standards Select a chemical, physical, biological and ergonomic hazard Using available references, identify criteria for each hazard selected, including: Exposure Limit Engineering Control Procedural control Personal Protective equipment Recovery (preparedness) measures

اسلاید 64: Practical Exercise Feedback on Control Standards Each group should give a short description of how they decided on each criteria and what extra information they might require to do the task better.

اسلاید 65: Are controls meeting the control standards?Control chart: tool for decisionsUse of information on exposures and controlsCombining ‘hazard rating’ and ‘exposure rating’Use of Control Chart

اسلاید 66: HAZARD RATINGDEFINITION (Consequence Category: Harm to People)1Slight health effects: Not affecting work performance or causing disability, e.g. non toxic dusts (as an acute hazard)2Minor health effects: Agents capable of minor health effects which are reversible, e.g. irritant agents, defatting agents, many food poisoning bacteria3Major health effects: Agents capable of irreversible health damage without loss of life, e.g. noise, poor manual handling tasks, hand/arm vibration, chemicals causing systemic effects, sensitisers4One to three fatalities or Permanent Total Disability: Agents capable of irreversible damage with serious disability or death, e.g. corrosives, known human carcinogens (small exposed population), sensitisers where the onset of sensitisation threatens continuing employment, heat, cold, psychological stress 5Multiple fatalities: Agents with the potential to cause multiple fatalities, e.g. chemicals with acute toxic effects (hydrogen sulphide, carbon monoxide), known human carcinogens (large exposed population)  Hazard rating categories

اسلاید 67: Exposure RatingExposure BandDefinitiona) Very Low< 0.1 x OELExposures are negligibleb) Low> 0.1 - <0.5 x OELExposure are controlled well below OEL and are likely to remain so in accordance with standardsc) Medium > 0.5 – 1 x OELExposures are currently controlled below OEL to meet standards but control may be reliant on less robust measures such as personal protective equipmentd) High> OELExposure are not adequately controlled to meet standards and continuously/regularly exceed OELe) Very High>> OELExposures are excessive and will almost certainly result in health damage to persons exposedExposure Rating

اسلاید 68: Control Chart

اسلاید 69: Evaluate the Adequacy of Controls What is the nature of the hazard to health ? Use Hazard Rating (RAM Consequence Category) What is the nature and degree of exposure for the task ? Assign Exposure Rating Combine in Control Chart

اسلاید 70: Remedial Action Plan The Remedial Action Plan must cover: Recommendations divided into four levels of action (first, second, third priority and no immediate action required) Is recommendation agreed or not? Responsible person Due date

اسلاید 71: Actions Control Chart (1) To aid priority setting Action 1st priority Stop the exposure; notify management immediately Identify all sources Implement immediate control improvements e.g. PPE Consider need for exposure measurement Identify and implement work practice and control improvements Review HRA, including measurements

اسلاید 72: Actions Control Chart (2) To aid priority setting Action 2nd priority Reduce exposure to below OEL (Hazard Ratings 1-2) Consider reducing to below 0.5 x OEL (Hazard Ratings 3-5) Identify and implement work practice and control improvements (*) Consider need for exposure measurement (*) Review HRA, including measurements (*) Action 3rd priority Actions with asterisk under 2nd priority Action – No Immediate Action Required Normally no need for immediate action to improve controls. Manage for continuous improvement

اسلاید 73: Definitions of ALARP“ balancing the reduction in risk against the time, difficulty and cost of achieving it” This level represents the point, objectively assessed, at which the time, difficulty and cost of further reduction measures become unreasonably disproportional to the additional risk reduction obtained. ALARP Definition

اسلاید 74: ALARP is influenced by the following factors:risk to be avoidedsacrifice involved in taking measures to avoid the risk (money, time and trouble)comparison of the twoALARP

اسلاید 75: List the measures that have been taken to reduce the riskGo on to identify an additional option which might be introduced to reduce the risk furtherGive reasons why this additional control is not adopted ALARP- rule of thumb

اسلاید 76: ALARP

اسلاید 77: A team of specialist working together to identify all possible controls measure through the hierarchy (tiered challenge)Encouragement of good practice within the systemAdhering to the codes and standard of practice with reference to past experienceApplication of engineering judgement and scientific principlesConsultation with stakeholdersApplication of HAZID and HAZOP to assist in ALARP selection.Application of Cost benefit analysis ..ALARP

اسلاید 78: Is risk to health ALARP?Yes, when only a small reduction in risk would require an unreasonable amount of time, trouble, difficulty or cost. OtherwiseSelect appropriate additional controls/barriers consideringHierarchy of controls including recovery preparedness measuresOther measures like: measurements, monitoring, health surveillance, maintenance of controls, instruction & trainingPriorities for implementationWhat remedial action?

اسلاید 79: Identify who may be exposed to health risksIdentify the relevant exposures to individuals in the workplaceAssess your work environment to determine when you need to do exposure monitoring/measurementsExposure measurements

اسلاید 80: ChemicalPhysicalBiologicalErgonomicTypes of exposure

اسلاید 81: Verification of the efficiency of control measuresJustification for additional control measuresChoice of control measures (eg for noise control)To establish and document historical records of exposure levels for all workersTo ensure and demonstrate compliance with regulatory and other exposure guidelinesEpidemiological studies or investigating reported health effectsTo alleviate employee concerns Purpose of exposure measurements

اسلاید 82: Baseline - to define range and distribution of exposure for defined jobsWorst case – to identify potentially high exposureDetailed – when baseline study provides insufficient dataRoutine – periodic exposure monitoring to check that control measures remain effectiveCompliance - to ensure that exposure is below regulatory and other guidelinesObjectives of exposure measurement

اسلاید 83: Personal Monitoringworker exposure with normal work procedurebreathing zone for inhalation exposurenear ear for noise exposurefull shifts / task samplesArea (Environmental) Monitoringcontaminant concentration in work areaplant conditionseffectiveness of controlsMonitoring methods

اسلاید 84: Biological MonitoringDetermine body absorption of potentially hazardous substance from all sourcesMeasure changes in the composition of body fluid, tissue or expired airMay be used to indicated inadequate control, improper work procedureProvides accurate information about the absorbed dose of a substance in the bodyNot all substances have a method or a BLV (biological Limit Value)Monitoring methods

اسلاید 85: Where to SampleWhen to SampleWhom to SampleHow long to SampleHow many samples to takeSampling Strategy

اسلاید 86: Factors to considersampling objectivephysical and chemical characteristics of chemicalpresence of other chemical(s)required accuracytype of samples (personal vs area)duration of samplesEquipment for measuring chemical exposure

اسلاید 87: Appropriate validated methods should be usedAcceptable methods are published by US NIOSH, OSHA, UK - HSE.Exposure records must be complete, traceable and stand up to legal scrutinySampling and analytical methods

اسلاید 88: Sampling train for dusts/fumes

اسلاید 89: Sampling train for hydrocarbons

اسلاید 90: Personal dosimeters (CO, H2S, SO2)

اسلاید 91: Detector tube for Grab Samples

اسلاید 92: Monitoring and health surveillance aims to (periodically) assess exposures and health in order toConfirm the effectiveness of existing control measuresCollect data for the detection and evaluation of hazards to health Confirm compliance with predetermined criteriaRequired by lawHealth Surveillance

اسلاید 93: In order to perform monitoring and surveillance, the following tasks are necessary:Define objectivesIdentify suitable methods (sensitivity, specificity, ethical, non-invasive)Identify norms/ means to interpret the dataPlan and evaluate the programCollect dataAnalyse and interpret dataReport actionsCommunicate with various audiences of surveillance data usersMonitoring and Surveillance

اسلاید 94: Medical Surveillance selection criteriaIs there a risk to health (based on HRA)The prevention/intervention potential (can we do something about it?)Can we detect it?Are the detection methods suitable?Medical Surveillance

اسلاید 95: Identify & document specificationsDetermine adequacyConduct routine inspections/ auditsProvide regular maintenanceConduct regular emergency drillsTrain / retrain staffProvide necessary resourcesEnsure effective communicationIncident investigation - learningCommunicate procedures to staff, visitors, 3rd party etc.Assign responsibilitiesReview risk and existing controlsReview systems, procedures, processes etcPLANNINGIMPLEMENTATIONREVIEWReview drillsReview of Controls

اسلاید 96: Document & Review HRA Appropriate Depth of Records Linked with Medical Records Informing Staff Archiving of Records Reviewing Records

اسلاید 97: Appropriate Documentation Records should: be retrievable Internal/external audits, authorities and review meet legal requirements be detailed enough to ensure audit trail on how conclusions were reached allow traceability from individual name via Job Type to tasks include exposure monitoring and health surveillance

اسلاید 98: Links with medical records Exposure profiles: example of how to link staff to exposuresRequires links between HRA and medical recordUnique identifier needed per individualCapability to record changes in Job type per individual Ensures that: archiving takes place when plant shuts down

اسلاید 99: Informing Staff of Findings Involves staff in HRA process Ensures that: Health risks are understood Control measures are usedStaff can alert assessment teams on changes May be a legal requirement

اسلاید 100: Archiving of Records As required by local law and/or practice 30 - 40 years are typical Allows for re-introduction of old processes

اسلاید 101: Reviewing HRAsSenior management will confirm the status of HRA through HSE annual letter Action Items Short term reviews of action items Against target dates and responsible persons Change in process, hazard, legislation etc Change in controls New information on the effect Incidents, illnesses, complaints, new knowledge On an agreed cycle Between 1 and 5 years dependent on risk

اسلاید 102: Assurance Where health risks are high, consider an HSE audit devoted to the adequacy of HRA Include: Organisation of the system for implementation Resources available Quantity and quality Areas of non-compliance with control standards Remedial actions taken following an HRA Maintenance of controls and recovery measures Demonstration of ALARP Maintenance of employee work history

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