The KBR Swindon warehouse facility is responsible for the receipt, storage, maintenance and out-loading of equipment in support of KBR global contracts. It is also the long-term storage and logistic facility for UK KBR based projects. The Warehouse Manager has overall Health and Safety responsibility for all the projects working out of this facility. The Swindon Safety Management System is based on 'BS OHSAS 18001:2007' certification. As part of KBR Management System review, the Swindon Warehouse completes quarterly Project Status Review (PSR) to feed information in to the overall KBR management system review.
The aim of this report is to ensure that all projects working in this facility are in compliance with the KBR Health and Safety management system and is meeting legal requirements. This report will also provide an opportunity to review the effective communication and cooperation between different projects sharing one facility and identify the effectiveness of the management system, conclusions, recommendations and an action plan if improvements are required.
The methodology of this audit is to review the policies, objectives and management system of the KBR Swindon warehouse facility for the safe receipt, storage and maintenance of equipment. This will entail reviewing the implementations of risk assessments, communications between the management and the workforce which includes compliance with current legislation, KBR Instructions and Procedures, various safety meetings and the KBR Safety Policy.
The documentation that will be used in the audit will include:
The warehouse Health and Safety plan to ensure that there is management commitment to health and safety in the warehouse.
Emergency procedures to ensure suitable and sufficient procedures are in place in case of an emergency.
Minutes of meetings to review whether Health and Safety concerns are being discussed and review the outcome and corrective actions.
Accident records to assess whether there are any trends and significant near miss incidents.
Risk assessments to ensure that all risks has been assessed and that mitigation measures put in place is suitable and sufficient to control the risk as low as reasonably practicable.
Method statements to ensure that the tasks are being conducted in a safe manner.
Training records to ensure that all employees and visitors are aware of the Health and Safety arrangements.
The building is a large 240,000ft2 open-plan warehouse containing two-storey offices on the North end of the warehouse. The warehouse also has 2 integral two-storey offices, welfare and canteen units. The warehouse is a rented facility and the Warehouse Manager has regular meetings with the landlord representative to deal with issues regarding the fabric of the buildings, services and surrounding hard standing within the tenanted estate. The occupancy of the warehouse consists of six KBR staff including the warehouse manager. Approximately five agency employees are used dependant on the activities scheduled for the week. Main work patterns for the warehouse staff are to move the equipment in to the testing area, test the equipment, clean and fix any defective equipment to ensure the readiness for deployment. The main risks to the warehouse staff include forklift truck operations, manual handling and mechanical hazards working with power tools.
In addition, the offices at the warehouse are used as a call centre which is completely separate from the work being conducted in the storage facility. This is a secure access area and is set up in an open-plan office environment with approximately 30 desks. This call centre is manned 24 hours a day and will always have a minimum of 2 occupants. However, occupancy could increase to 30 for training days, interviews and meetings. The main risks to the call centre operators are Work Related Upper Limb Disorders as a result of poor ergonomics and lone working hazards.
There is no Health and Safety Executive (HSE) or Environmental Agency (EA) censures or improvement notices placed on the site by the HSE or EA. Pertinent hazards addressed by risk assessments at this facility are categorised below.
There is a duty on the Warehouse manager to ensure that adequate arrangements are in place for work equipment as described in The Provision and Use of Work Equipment Regulations 1998 (PUWER). A lot of different types of machinery will be used in the warehouse area which the warehouse manager will need to ensure complies with the PUWER before they are commissioned for use. Regulations 4 to 10 sets out the management duties of PUWER covering the selection of suitable equipment, maintenance, inspection, specific risks, information, instructions and training. Seeing as the equipment has been bought second hand, it will need to be inspected by a competent person, producing a risk assessment and providing information, instruction and training to all warehouse staff on the use of the machinery. Regulations 11 to 24 of PUWER cover guarding of dangerous parts of work equipment, the provision of appropriate stop and emergency stop controls, stability, suitable and sufficient lighting and suitable warning markings or devices. The inspection of machinery will identify dangerous parts of the equipment and the warehouse manager will need to ensure that the guards are fitted to the machines before the machines are commissioned.
The Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) apply in relation to all work activities undertaken by KBR where lifting equipment and operations as defined by the regulations are used. This legislation expands on the general requirements of the Health and Safety at Work etc. Act 1974 and complements the requirements of the Provision and Use of Work Equipment Regulations 1998 (PUWER). KBR has a duty under these regulations in situations where lifting equipment is used by employees at work, to ensure that the lifting equipment and associated lifting operations are carried out safely. In addition, persons who have any control of lifting operations, or who supervise or manage the use of lifting equipment also have a duty under the Regulations, but only to the extent of their control. LOLER requires the Warehouse manager to conduct a risk assessment on the forklift trucks which will be used inside the warehouse and the measures needed to eliminate or control the risks.
Regulation 6 of the Workplace (Health, Safety and Welfare) Regulations 1992 and its supporting Approved Code of Practice (ACOP) provides the warehouse manager with general requirements about ventilation of the warehouse and equipment used to ventilate the warehouse.
Regulation 7 of The Control of Substances Hazardous to Health Regulations 2002 (COSHH) requires the warehouse manager to prevent or control the exposure of employees to substances hazardous to their health. Compliance with this Regulation is particularly important as incident reports from the warehouse has indicated a near miss incident where an employee took receipt of a delivery and spilled a chemical due to poorly packaged bottles.
If any of the risk assessments identifies that personal protection is required, then the Warehouse manager will need to ensure that personal protection equipment (PPE) is provided in accordance with the Personal Protective Equipment at Work Regulations 1992. The Warehouse manager needs to ensure that a stock of PPE is available for visitors and employees who do not have the right PPE when entering the warehouse.
The Warehouse manager also has a duty under The Regulatory Reform (Fire Safety) Order 2005 (RRFSO) to conduct a suitable and sufficient Fire Risk Assessment and to ensure that Fire safety arrangements are in place to elimination or reduction of risks from dangerous substances. The warehouse manager faces the challenge to manage both the warehouse and the call centre employees during an emergency. Under the same regulations the Warehouse manager should ensure means are available for fire-fighting and fire detection and that there are adequate emergency routes and exits from the warehouse. KBR will have generally assessed fire evacuation routes, means of detection and raising the alarm at all of its sites. Details of these arrangements are usually contained in the fire risk assessments kept at each site. KBR managers are required to do the following to maintain fire prevention measures:
Ensure that a suitable fire risk assessment is in place.
Ensure that any actions arising from external inspections are acted upon in an appropriate and timely manner. Often this will mean monitoring improvements to be carried out by the client, and in all cases will require the addition of information to local health, safety and environmental plans.
Carry out regular housekeeping checks to ensure that items are not being stored inappropriately, especially near hot or electrical equipment, that escape routes are not blocked and that fire safety equipment has not been interfered with.
Ensure employees do not increase the fire risk at an office or similar by using faulty electrical goods, smoking in a non-designated area or storing refuse inappropriately.
Ensure that records are completed whenever there have been any checks or maintenance of fire safety equipment/fixtures using Fire Equipment Inspection Sheet.
Ensure fire prevention measures are communicated to staff, contractors and visitors.
The Health and Safety (Consultation with Employees) Regulations 1996 (HSCER) requires the Warehouse manager to consult employees on the information required about risks to their health and safety and preventative measures in place.
All management and staff in a working environment need to follow the KBR First Aid guidance as a minimum standard in order to ensure the health, safety and welfare of KBR employees and other persons who may be affected by our undertakings. First Aid at work covers the initial management of any injury or illness suffered at work. First Aid can save lives and prevent minor injuries becoming major ones. Under the Health and Safety (First Aid) Regulations 1981 (as amended 2009), all workplaces must make provisions for first aid, to be readily available at appropriate times.
The Control of Asbestos Regulations 2012 requires KBR to prevent the exposure of its employees to asbestos so far as is reasonably practicable. To achieve this KBR must ensure perform suitable and sufficient assessments in accordance with HSG 264 Asbestos: the survey guide that determines whether asbestos is present on the premises. This was arranged by the premises' owner prior to KBR occupying the premises and Asbestos areas were identified within the warehouse. KBR must ensure that the warehouse's owner:
Ã¢ÂÂ¢ Determines the risk from the asbestos.
Ã¢ÂÂ¢ Prepares a written plan identifying the area of the premises concerned and the measures necessary for managing the asbestos risk.
Ã¢ÂÂ¢ Implement the measure in the plan.
Ã¢ÂÂ¢ Record the measures taken to implement the plan.
These measures should include adequate means for:
Ã¢ÂÂ¢ Monitoring the condition of any asbestos or suspected asbestos.
Ã¢ÂÂ¢ Maintaining the asbestos or its safe removal.
Ã¢ÂÂ¢ Providing information identifying the location and condition of identified asbestos to any person likely to disturb it and making this information available to the emergency services.
The Control of Noise at Work Regulations 2005 will need to be considered for a backup generator placed inside the warehouse where Warehouse staff will be working during their normal working day. The Control of Noise at Work Regulations 2005 places the following duties on to the Warehouse manager:
Ã¢ÂÂ¢ Carry out a suitable and sufficient assessment of the risk to the health and safety of employees who are liable to noise exposure at or above any Lower Exposure Action Levels.
Ã¢ÂÂ¢ Record the significant findings of the assessment and ensure that it is reviewed regularly and revised as required.
Ã¢ÂÂ¢ Record any measurements taken.
Ã¢ÂÂ¢ Ensure that the risk assessment has been carried out by a competent person.
Ã¢ÂÂ¢ Reduce noise exposure to as low as is reasonably practicable, by means of organisational and technical measures other than personal hearing protectors, where any employee is likely to be exposed above any Upper Exposure Action Levels.
Ã¢ÂÂ¢ Hearing protection is to be available on request for any employee exposed above the lower exposure action value, and must be provided to any employee exposed at or above the upper exposure action level.
Ã¢ÂÂ¢ Designated areas where employees are likely to be exposed to or above the upper action level as hearing protection zones.
Ã¢ÂÂ¢ Ensure that no employee enters designated hearing protection zones unless they are wearing ear protectors.
Ã¢ÂÂ¢ Provide employees with information, training and instruction about risks, control measures, hearing protection and safe working practices.
Warehouse staff will be conducting manual handling activities during their normal working day so the warehouse manager will need to ensure compliance with the Manual Handling Operation Regulations 1992. The Warehouse manager need to ensure a suitable and sufficient assessments of all such manual handling operations are undertaken and have taken into account all foreseeable risks.
In addition to the legal environment in the warehouse, the Warehouse manager needs to ensure compliance with The Health and Safety (Display Screen Equipment) Regulations 1992 to minimise to eliminate or reduce possible eyesight or musculoskeletal disorders due to the effects of continual display screen equipment use.
The KBR Swindon Safety Management System is based on 'BS OHSAS 18001:2007' Standard and follows the Plan-Do-Check-Act methodology.
The general requirement of the Planning stage is to define and document the scope of the management system. This information is captured in the KBR Corporate HS&E Policy which is a global document and is written in a very general and broad manner in an effort to comply with all possible projects on a global level. The management system has a process in place for hazard identification, risk assessment and determining controls covered in various work methods. The HS&E Risk Assessment work method provides guidance on the specific duty placed upon KBR to carry out a suitable and sufficient assessment of all risks to the health and safety of employees and others, arising at or from a work activity. The "Identification and Evaluation of HSE Legislative and Other Requirements" process map identifies relevant HSE legislative requirements applicable and is recorded in the HSE Requirements Register.
The KBR Swindon HS&E Plan contains an organisation charts which clearly identifies roles, responsibilities and accountability for everyone working at the warehouse. KBR needs to ensure that everyone working in the warehouse is competent and experienced for the work that they are doing. The KBR Swindon Training Strategy contains a Training matrix to ensure appropriate level of competence at different levels of authority. The HS&E Management system is available to all employees on the KBR intranet and regularly reviewed, updated and communicated via the intranet. KBR operates a three-tiered emergency response procedure whereby all projects and locations will ensure a Local Emergency Response Plan (LERP) is in place to manage low level emergencies. The KBR warehouse can then escalate the emergency to a Level 2 Incident Commander if it is deemed necessary and the Level 2 Incident Commander can escalate to a Level 3 global status in severed circumstances.
KBR operates an integrated management system so the "Audit Management System" process required by the Quality Management System is used to conduct audits to determine the effectiveness of the controls in place.
Health and Safety performance is measured using incident and accident statistics and completing monthly project reviews. Each project is set a target, usually a 10% reduction from the previous year's incident rate, and is monitored against this target. This information is then discussed in a management review meeting on a quarterly basis.
BS OHSAS 18001:2007
Plan / Do / Check / Act
4.1 General Requirements
Plan - Policy
This is a global document and does not take in to account the nature and scale of the scope of work being conducted at the Swindon Warehouse facility.
This policy is also dated 30/05/2007 so it has not been reviewed periodically.
Review and update the policy to take in to account the current scope of work and legal framework of the work being conducted at the Swindon Warehouse.
4.3 Hazard identification, risk assessment and determining controls
Plan - Risk Assessments
The current work method in place covers general risk assessments which might not always be suitable for specific risks. E.g. Asbestos.
Design and implement work methods for specific hazard identification, risk assessment and control measures.
4.3.2 Legal and other requirements
Plan - HSE Requirements Register
The register does not display a revision date so unable to ascertain review date. However, it is clear that it has not been updated as the Control of Asbestos Regulations still refers to 2006 rather than the updated 2012 regulations.
Review and update the register and add a revision date to ensure a regular review takes place.
4.4.1 Resources, roles, responsibility and authority
Do - Organisation Chart
There is no full time Health and Safety resource identified on the organisation chart for the warehouse facility.
A full time Health and Safety resource based at the warehouse will be beneficial to maintain and improve the Management System.
4.4.2 Competence, training and awareness
Do - Training Matrix
A training matrix has been identified for the KBR Swindon Warehouse but this has not been updated with new starters so not completed.
Review training matrix on a regular basis to ensure all employees are suitably trained.
4.4.3 Communication, participation and consultation
Do - Management System Folder
Even though the Management System is available to all employees on the KBR intranet, the employees working in the warehouse does not all have access to computer systems so unable to access the information.
Make a hard copy of the HS&E Management System available in a general area where everyone working in the warehouse would be able to access the information.
4.4.7 Emergency preparedness and response
Do - LERP
Currently no LERP in place for Swindon Warehouse facility even though Fire and First Aid arrangements has been implemented at the facility.
Record all emergency information on a LERP. This will then need to be updated on the KBR intranet and hard copies placed on the notice boards.
4.5.1 Performance measurement and monitoring
Check - Audit Register
There is currently no audit register in place to record non-conformities and corrective actions.
An audit register will need to be implemented to ensure continual improvement.
4.6 Management review
Act - Project Review
Currently the projects operating out of the warehouse conducts individual project reviews but there is no overall review available for the warehouse as a whole.
Implement a project review for the warehouse as a whole to provide a true reflection of the HS&E performance at the facility.
Review date / format
BS OHSAS 18001:2007. Occupational health and Safety management systems - Requirements