HSE Management Systems and Auditing
Not publishedof exam
Risk Assessment and Change Control
Not publishedof exam
Permits, SIMOPS and Emergency Response
Not publishedof exam
Environment, EIA and Spill Response
Not publishedof exam
Nigerian Law and HSE Performance
Not publishedof exam
Quick Facts
- Exam
- ISPON HSE Level 3
- Body
- ISPON, Nigeria
- Tier
- Supervisory HSE
- Course fee
- N150,000 listed by ISPON
- Format
- Not published by ISPON
- Pass mark
- Not published by ISPON
- Weights
- Not published by ISPON
- Booking
- ISPON branch office
- Used for
- GISPN membership route
- Blueprint
- None published
PDCA in ISO 45001
Plan 4-6, Do 7-8, Check 9, Act 10
Plan: context, leadership, planningDo: support and operationCheck: performance evaluationAct: improvement
Correction vs Corrective Action
Correction
- Fixes the outcome
- Clean, replace, re-brief
- Event can recur
Corrective action
- Removes the cause
- Requires cause investigation
- Checks elsewhere too
Symptom versus cause
Grading an Audit Finding
- Required process absent→Major nonconformity
- System-wide breakdown→Major nonconformity
- Many minors, one clause→Major nonconformity(Clustered lapses)
- Isolated single lapse→Minor nonconformity
- Risk seen, no breach→Observation
- Better method available→Opportunity for improvement
ISO 45001 Clause Map
- Clauses 1-3
- No auditable requirementsNot audited
- Clause 4
- Context, interested parties, scope
- Clause 5
- Leadership, policy, worker participation
- Clause 6
- Hazards, legal duties, objectives
- Clause 7
- Resources, competence, communication, records
- Clause 8
- Controls, change, procurement, emergency
- Clause 9
- Monitoring, internal audit, review
- Clause 10
- Incident, nonconformity, corrective action
Why Shortcuts Win
Soon, Certain, Positive beats Late, Uncertain, Negative
Shortcut pays immediatelyInjury stays uncertainChange the consequence
Internal Audit vs Management Review
Internal audit
- Clause 9.2
- Independent sampling
- Conformity and implementation
Management review
- Clause 9.3
- Top management decides
- Suitability, adequacy, effectiveness
Audit feeds the review
Clause 8 Sub-Clauses
- 8.1.1
- Operational planning and control
- 8.1.2
- Eliminate hazards, reduce risks
- 8.1.3
- Management of change
- 8.1.4.1
- Procurement control, general
- 8.1.4.2
- Contractor coordination and criteria
- 8.1.4.3
- Outsourced function control
- 8.2
- Emergency preparedness and response
Consultation vs Participation
Consultation
- Seeking workers' views
- Before the decision
- Views may be declined
Participation
- Involvement in deciding
- Non-managerial workers emphasised
- Barriers must be removed
Asked versus involved
Audit Evidence Chain
- Criteria
- Standard, law, own procedure
- Evidence
- Records, statements, observations
- Finding
- Evidence judged against criteria
- Conclusion
- Outcome of whole audit
- Major NC
- Required process absent or collapsed
- Minor NC
- Isolated lapse, system works
- Observation
- Risk flagged, no breach
- OFI
- Suggestion, no action compelled
Prequalification vs Bridging Document
Prequalification
- Before contract award
- Capability and record
- Screens the bidder
Bridging document
- After contract award
- Whose procedure governs
- Activity by activity
Select versus integrate
ISO 19011 Audit Principles
- Integrity
- Basis of professional conduct
- Fair presentation
- Report truthfully and accurately
- Due professional care
- Diligence and sound judgement
- Confidentiality
- Protect information obtained
- Independence
- Impartial, no conflict of interest
- Evidence-based
- Verifiable, reproducible conclusions
- Risk-based
- Added in 2018 revisionNew 2018
Contractor HSE Control
- Prequalification
- Screen capability before award
- HSE award criteria
- Required by clause 8.1.4
- Bridging document
- States whose procedure governs
- Kick-off meeting
- Agree scope, controls, interfaces
- Site induction
- Before any work starts
- Interface hazards
- Yours, theirs, third parties
- Performance review
- Measured during the contract
- Close-out rating
- Feeds the next prequalification
Behavioural Safety Terms
- ABC model
- Antecedent, behaviour, consequence
- Strong consequence
- Soon, certain and positive
- Observation card
- Records behaviour, never names
- Bradley Curve
- Reactive to interdependent, four stages
- Hudson ladder
- Pathological to generative, five rungs
- Just culture
- Separates error from violation
Change Triggers: Four Ps
Plant, Process, People, Procedure
Each triggers risk reviewTemporary change needs expiryName a restoring owner
HAZOP vs Task Risk Assessment
HAZOP
- Design or process deviations
- Team, nodes, guide words
- Applies to the plant
Task risk assessment
- One crew, one job
- Today's actual conditions
- Applies to the work
Plant versus task
Risk Assessment Review Triggers
- Incident or near miss
- Same task reassessed
- Plant change
- New or modified equipment
- Process change
- New method, chemical, sequence
- People change
- New crew or competence gap
- Procedure change
- Revised instruction or permit
- Control failure
- Barrier found not working
- Legal change
- New law or standard
- Review date
- Stated expiry already reached
Assessor vs Risk Owner
Assessor
- Signs the method
- Applied the technique
- No budget authority
Line manager
- Accepts residual risk
- Owns the actions
- Controls people and money
Method versus accountability
Bow-Tie Anatomy
- Threat
- Cause on the left
- Top event
- Loss of control
- Consequence
- Outcome on the right
- Preventive barrier
- Left of top event
- Recovery barrier
- Limits consequence severity
- Escalation factor
- Defeats a chosen barrier
- Escalation control
- Protects that barrier
HAZOP Guide Words
- No or none
- Design intent not achieved
- More
- Higher flow, pressure, temperature
- Less
- Lower than design intent
- Reverse
- Opposite of design intent
- As well as
- Intent plus something extra
- Part of
- Only some intent achieved
- Other than
- Completely different result
Emergency Exercise Picker
- Test decisions cheaply→Tabletop exercise
- Plan never exercised→Tabletop first(Cheapest failure)
- Test one system live→Functional drill
- Prove muster timing→Timed evacuation drill
- Test whole response→Full-scale exercise
- After real emergency→Review and revise plan(Clause 8.2)
Permit System Audit Checks
- Live permit sample
- Compare against actual work
- Isolation cross-reference
- Permit names isolation certificate
- Register reconciliation
- Office list versus field
- Expired permits
- Closed without handback signature
- Gas test timing
- Retested after breaks, changes
- Role separation
- Issuer never the holder
- Display at worksite
- Permit present where work happens
- SIMOPS clash matrix
- Reviewed at daily meeting
Emergency Preparedness Elements
- Planned response
- Written, role-specific actions
- Training
- Everyone knows their duty
- Periodic testing
- Exercises on a schedule
- Post-event revision
- Update after test, emergency
- Communication
- Workers, contractors, visitors, authorities
- Mutual aid
- External resources agreed beforehand
- Rescue plan
- Non-entry retrieval planned first
- Receiving hospital
- Named and capability confirmed
Incident Command Basics
- Span of control
- Three to seven reports
- Optimal span
- Five direct reports
- Unity of command
- One supervisor per responder
- Command post
- Single agreed control point
- Muster roll call
- Named list, not headcount
- Media handling
- Never the on-scene supervisor
Nigeria EIA Sequence
Screen, Scope, Study, Review, Decide, Monitor
Screen: ten working daysPublic review: 21 daysCertificate before constructionAudit after commissioning
EIA Category I vs II
Category I
- Full EIA mandatory
- Mandatory study list
- Highest impact potential
Category II
- Partial EIA normally
- Sensitive area reassigns it
- Then full EIA required
Location can upgrade category
Nigeria EIA Process Stages
- Project proposal
- Submitted to the Ministry
- Screening
- Category I, II or III
- Screening report
- Ten working days
- Scoping
- Terms of reference agreed
- Draft EIA report
- Full study submitted
- Review method notice
- Fifteen working days
- Public display
- Twenty-one working days
- Certification
- Certificate, then post-commissioning audit
EIA Minimum Content
- Proposed activities
- Described in the report
- Affected environment
- Baseline conditions described
- Impacts and alternatives
- Direct, indirect, cumulative, long-term
- Mitigation measures
- Identified and assessed
- Knowledge gaps
- Uncertainty stated explicitly
- Transboundary effects
- Other states or countries
- Non-technical summary
- Brief, plain-language overview
Oil Spill Tiers Nigeria
- Tier 1 inland
- 25 barrels or less
- Tier 1 land/coastal
- 250 barrels or less
- Tier 2 inland
- 25 to 250 barrels
- Tier 2 land/coastal
- 250 to 2,500 barrels
- Tier 3 inland
- 250 barrels or more
- Tier 3 land/coastal
- Over 2,500 barrels
- Tier 1 resources
- Operator's own equipment
- Tier 2 resources
- Mutual aid, Clean Nigeria Associates
- Tier 3 activation
- NOSDRA National Commander
- Spill notification
- Within 24 hours, writtenNOSDRA
Waste Duty of Care
- Classify at source
- Where the waste arises
- Segregate
- Separate streams, no mixing
- Transfer note
- Tracks each consignment
- Permitted carrier
- Licence checked and copied
- Permitted destination
- Named facility, current permit
- Returned copy
- Proof of lawful disposal
- Aspect
- Activity touching the environment
- Impact
- Resulting environmental change
Scene Evidence: Four Ps
People, Position, Parts, Paper
People: witnesses firstPosition: photograph before movingParts: components and damagePaper: permits, logs, handovers
Improvement vs Prohibition Notice
Improvement notice
- Section 37
- States the danger
- Work may continue
Prohibition notice
- Section 38
- Stops the process
- Revoked after rectification
Fix it versus stop
Investigation Method Picker
- Single obvious causal chain→5 Whys(Fast, one branch)
- Cause genuinely unknown→Fishbone diagram(Spreads candidate causes)
- Barrier failure suspected→Bow-tie analysis(Exposes single barriers)
- Sequence unclear→Timeline and causal factors
- Equipment failure logic→Fault tree analysis
- Repeat organisational event→Tripod Beta or ICAM
Factories Act Duties
- Section 23
- Instruct, then train or supervise
- Section 51
- Death or over 3 days
- Section 53
- Notify occupational disease forthwith
- Section 58
- General register of accidents
- Section 59
- Keep records seven years
- Section 60
- Post abstract, inspector address
- Section 61
- Workers must not misuse safeguards
- Section 73
- Agent liable as the occupier
- Section 74
- Occupier defence, three days notice
TRIR vs LTIFR
TRIR
- Base 200,000 hours
- All recordable cases
- OSHA convention
LTIFR
- Base 1,000,000 hours
- Lost-time injuries only
- ILO and IOGP convention
Different bases, never compare
Who to Notify in Nigeria
- Death at work→Factory inspector, forthwith(Factories Act section 51)
- Disabled beyond three days→Factory inspector, forthwith(Factories Act section 51)
- Occupational disease suspected→Nearest factory inspector(Factories Act section 53)
- Any employee injury→Board within 7 days(Compensation Act section 5)
- Oil spill occurs→NOSDRA within 24 hours(Written notification)
- Hazardous substance discharged→NESREA(NESREA Act section 27)
- New project, significant impacts→Federal Ministry of Environment(EIA Act)
Enforcement and Liability
- Section 37
- Improvement notice, work continues
- Section 38
- Prohibition notice, work stops
- Section 39
- Appeal Minister, then Federal High Court
- Section 71
- Penalty when death, injury
- NESREA section 27
- Hazardous discharge is prohibited
- NESREA 27(4)
- Person in charge deemed guilty
- Due diligence defence
- Prove no knowledge, full diligence
- ISPON Act 2014
- Holding out unregistered is offence
HSE Performance Metrics
- TRIR
- Recordables per 200,000 hours
- LTIFR
- Lost-time injuries per 1,000,000 hours
- Severity rate
- Days lost per event
- Leading indicator
- Audits, observations, actions closed
- Lagging indicator
- Injuries, illnesses, spills, losses
- Exposure hours
- Denominator includes contractors
Compensation Act Clocks
- Employee notice
- 14 days to employer
- Employer report
- 7 days to Board
- Death report
- Immediately to the Board
- Claim window
- One year from occurrence
- Special circumstances
- Extended to three years
- Employer contribution
- Minimum 1.0 per cent payroll
- Fund administrator
- NSITF Management Board
- No employee notice
- Bars the compensation claim
Common Traps
Correction vs cause
Correction fixes the outcome ≠ Corrective action removes cause
Audit vs review
Audit samples for conformity ≠ Review is top management
Improvement vs prohibition
Improvement notice: work continues ≠ Prohibition notice: work stops
Injury rate bases
TRIR uses 200,000 hours ≠ LTIFR uses 1,000,000 hours
Consultation vs participation
Consultation seeks views only ≠ Participation shares the decision
Category II is not safe
Category II normally partial ≠ Sensitive area forces full
ILO-OSH is not certifiable
ISO 45001 certifies ≠ ILO-OSH is voluntary guidance
Spill tiers differ by water
Inland thresholds are lower ≠ Land and coastal ten-fold
Who owns residual risk
Assessor signs the method ≠ Line manager accepts risk
Filed permits prove nothing
Files prove forms completed ≠ Field sampling proves control
Last Minute
- 1.Clauses 4-10 = auditable requirements
- 2.Correction = outcome; corrective = cause
- 3.Major NC = required process absent
- 4.Audit samples; management review decides
- 5.Clause 8.1.4 = contractor HSE criteria
- 6.Untested plan fails clause 8.2
- 7.Inspector notified: death, over 3 days
- 8.Occupational disease: notify inspector forthwith
- 9.Oil spill: NOSDRA within 24 hours
- 10.Employer reports injury within 7 days
- 11.Employee notifies employer within 14 days
- 12.Section 73 = supervisor personally liable
- 13.Improvement notice continues; prohibition stops work
- 14.TRIR = 200,000; LTIFR = 1,000,000
- 15.EIA screening report: 10 working days
- 16.Public EIA display = 21 working days
- 17.Tier 1 inland = 25 barrels
- 18.Every temporary change needs expiry
- 19.ISPON format and weights: not published
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