a. Is every place and activity in the company subject to a scheme of active monitoring (safety inspections, safety tours, safety surveys and safety management audits)?
b. Is responsibility for active monitoring clearly allocated?
c. Have those responsible for carrying out active monitoring been properly trained?
d. Is there provision for assistance with active monitoring?
e. Are there set frequencies for active monitoring?
f. Do the systems of active monitoring provide for the recording of results?
g. Is there a system for taking action on the results of active monitoring and checking on action taken?
• Depending on the size and complexity of the
organisation there should be arrangements for active monitoring
and comparing the results of such monitoring, checking that
appropriate actions are being taken. It is at this point that
decisions may be required on resources (e.g. investment in a
new machine which does not spill oil) and priorities, and that
consultation with employees and/or their representatives is
desirable (see also section on Consultation). It is important
that all places and activities are included because it is often
at the margins of responsibility that hazards are
• Active monitoring is a means of verifying the adequacy of, and the degree of compliance with, the risk control measures that have been established. It is intended to identify deficiencies in the safety management system for subsequent remedial action, and thus prevent accidents by eradicating their potential causes. It also enables a company to gain a picture of its health and safety performance and chart the progress of improvement.
• Active monitoring employs several complementary methods which address differing aspects and areas of the organisation These methods may be usefully categorised as follows:
(i) The SMS Audit is a major exercise, typically carried out every 2 - 4 years, as a means of assessing the adequacy of the whole organisation's SMS. It addresses all aspects of safety management in a structured manner, using written questions e.g. this textile audit with answers being confirmed by a review of records, staff interviews, and observation of workplaces and operations. The SMS Audit may benefit from being undertaken by a person or persons independent of the organisation and should, where practicable be carried out in real time.
(ii) The Safety Survey is usually a detailed assessment of one aspect of an organisation's SMS e.g. the organisation's training arrangements.
(iii) The Safety Inspection consists of a formal
assessment of workplace safety, and the identification
of hazardous conditions or practices, for subsequent remedial action. It is normally carried out by first line managers referring to, and completing a checklist.
(iv) The Safety Tour addresses the "people" aspects of workplace safety, and by discussions with a range of staff, establishes their familiarity with safety procedures and requirements. It is normally carried out by middle and senior management, as one means of demonstrating their commitment to safety. A questionnaire is frequently used.
• Staff involved in carrying out monitoring activities should be suitably qualified and experienced. Training may be in-house or external, depending on the identified needs of the person concerned. In additional to individuals, monitoring teams may also be employed. These might include an accredited safety representative (who has the right to conduct 3 monthly inspections under the Safety Representatives and Safety Committee Regulations), another departmental supervisor, or the company safety adviser if one is appointed. Persons responsible for active monitoring should be named.
• There should be a programme that identifies monitoring frequency for the different methods and for of the results. These will be requirements of the appropriate company safety standards.
• Action will range from matters capable of immediate rectification to those requiring engineering or maintenance work, procedural or staff changes that may involve major decisions on expenditure. Action plans should be developed, which will be linked to the review requirements. A distinction is drawn between local review e.g. equipment, workplace and procedures, and the SMS review.
a. Is there a requirement for all incidents and accidents (harm to people, harm to the environment, damage to plant/property and process) to be investigated?
b. Is there a procedure for incident and accident investigation and the recording of the results?
c. Is responsibility for investigation clearly allocated?
d. Have those responsible for investigation been properly instructed and/or trained?
e. Is there a system for taking action on the results of investigations and checking on action taken?
• Several studies of occupational accidents have demonstrated that for every serious accident there are many more minor accidents and an even larger number of damage-only or near miss incidents. Most of these represent a loss to the company and recent work by HSE has shown that losses from damage-only incidents far outweigh the losses from accidents. The causes are the same but the results are different. Whether a particular incident (e.g. the dropping of a bale of wool from a loading opening) leads to fatal injury, minor injury, damage-only or simply a near miss is often a matter of luck. It is therefore important to ensure that all incidents are properly investigated and lessons learned.
• For most incidents this should be the person responsible for routine inspections and/or the supervisor if this is a different person. For more serious incidents more senior management and/or external consultants should be nominated.
• Induction and training should include the purpose of investigations and the information to be recorded. Persons responsible for reactive monitoring should be named.
• Investigations are wasted if the organisation does not learn from them and take preventative action. The system should include review at an appropriate level of management. Where a safety committee exists, the results of investigations are a useful item for discussion.
1. Managing Health and Safety: Five Steps to Success, INDG275
2. Successful Health and Safety Management, HS(G)65, HSE 1997, ISBN 0 7176 1276 7.
• Every employer must have arrangements for monitoring the health and safety arrangements (MHSW Regs.). Distinction is drawn between regular pro-active monitoring (safety inspections, surveys and management tours) and less regular SMS audits. The Policy should refer to such systems and incident or accident investigation and recording.
• The results of all monitoring need to be collated and evaluated to determine whether immediate, short term or long term (see Part 5 Reviewing the SMS) corrective actions are required and to implement those actions. We are concerned here with improvements to plant, procedures and infrastructure to meet the objectives of the policy and the requirements of the SMS standards. The policy should refer to systems that use monitoring results.