DNI Information - Introduction and Hazards

Unit ID Assignment NEBOSH Student Number: 00061559
2.0 Introduction
2.1 Aims and Objectives
The aim of this report is to critically evaluate Trinidad Power Generation’s (TPG) health and safety
management systems and where opportunities for improvement are identified to propose
recommendations to improve the health and safety performance of the organization. This will be
accomplished by fulfilling the following three key objectives included in this report:
1. Review TPS’s existing Safety and Health Management system and critically evaluate it against
the BS OHSAS 18001:20071 standard in order to establish areas of none or poor conformance
and identify opportunities for improvement.
2. To identify and evaluate the significant hazards which TPG’s employees could be potentially
exposed to during the course of their work.
3. To carry out detailed risk assessments on the three most significant hazards identified (physical
and health & welfare hazards). The purpose of these assessments is to evaluate the adequacy of
the existing controls and where necessary to propose recommendations to further increase the
level of control thereby reducing the risks associated with these high risk tasks.
Recommendations shall be detailed, with each being appropriate to and considering the resources
available within TPG and shall be justified by means of a cost benefit analysis clearly showing the
legal, moral, and financial advantages associated with the action together with the predicted
(estimated) costs of carrying out the action.
2.2 Methodology
This assessment was carried out in over the period March 2018 to June 2018. The first aspect of
the audit was to assess the compliance of the existing Safety and Health Management System to
the BS OHSAS 18001: 2007 Standard. This was achieved through a thorough desktop study
involving review of all TPG’s policies and procedures relating to Safety and health and well as
interviews with key management staff responsible for implementation. Interviews with
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representatives from all sections of the workforce, inclusive of contract and temporary workers
were interviewed and asked to complete a Health and Safety Survey which was used to identify
issues surrounding implementation of the management system. This information was then used to
update the Gap Analysis in section 3 which is based on compliance the OHSAS 18001 standard
the Management. Site tours were conducted throughout the TPG facility in order to identify the
hazards associated with each work activity. Assessing the knowledge of the workforce regarding
the hazards they are exposed to as well as the mitigation measures in place was critical to this
audit and was achieved by interviews with teams working in each area. These groups were also
asked to identify the hazards they were most exposed to during their course of work. Review of
accident data, insurance claims and near miss reports were also used to further identify areas of
high exposure to risks. The significant hazards were identified and evaluated using a simple 3x3
risk rating system based on likelihood and severity of the hazard effect occurring (see appendix A).
Following this, a detailed risk assessment of the two most significant hazards were carried out.
Findings from the management system gap analysis and risk assessment were used to develop
detailed recommendations justified by mean of a cost benefit analysis considering time, money,
expert and in house resources required to address the identified issues. .
2.3 Description of Organisation
Trinidad Power Generation is a 720 MW Combined cycle power plant located in Union Industrial
estate Trinidad W.I. and has been in operation for 10 years.
The power plant has six (6) General Electric (GE) 7EA gas turbines, capable of producing 75
Mega-Watts (MW) of power each for a total gas turbine output of 450 MW. The power plant at La
Brea, Trinidad, is a modern combined cycle plant consisting of six General Electric gas turbine-
driven generators and two steam turbine-driven generators. The gas turbines are rated for a
combined output of 450 MW, the waste heat from which is utilised by six Heat Recovery Steam
Generators (HRSGs) to produce steam. The steam produced by this waste heat is then used to
power the two General Electric steam turbine driven generators. These generators produce an
additional 270 MW of power, without the use of any additional fuel. This process makes TPG the
most efficient and lowest overall cost power producer on the island.
The facility comprises two ‘trains’ in a ‘Three on One’ configuration with three GE7EA gas turbine
generating units each producing 75MW, with HRSGs and one GE Steam Turbine each capable of
150MW connected via a common steam header, sharing common auxiliaries and with an air-
cooled condenser. In total, there are six gas turbines and two steam turbines.
The plant also has a 220 kV switchyard with three transmission lines, which interconnect with the
national grid. Gas for this facility is supplied by the The National Gas Company of Trinidad and
Tobago Limited (NGC) from a separate natural gas network.
It is a medium sized organization employing approximately 100 persons consisting of permanent

staff, long term contracted staff and trainees. For major jobs and jobs requiring specialized skill set,
between 50 and 200 contractors. Running of this facility involves general operational tasks such as
control of plant operations via control screens, adjustment of pumps and control systems, issuing
and controlling permits to work for high risk activities. The plant is manned 24 hours a day on a 12
hour shift system consisting of 4 shifts, with the plant producing electricity continually throughout
the year. The maintenance team is responsible for both routine and breakdown maintenance with
coverage from 7 am -4 pm 5 days a week with a technician assigned to emergency call out after
hours. Support staff which includes Finance, Materials/Stores, administrative support, Information
Communication Technology and support, Legal and Compliance and Health Safety and
Environment teams all work 7am-4pm 5 days a week.
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2.4 Legal Environment
The Occupational Safety and Health Act Chap. 88:08 (“OSHA”) applies to all “industrial
establishments” including such industrial establishments owned by or occupied by the State.
OSHA is the principle piece of health and safety legislation within Trinidad and Tobago is the
closely mirrored to the Health and Safety at Work etc Act 1974 (HSWA)7. This legislation is
extremely broad and far reaching.
OSHA provides for the establishment of the Occupational Safety and Health Authority (“the
Authority”). The Authority has the primary function of policy formulation and is responsible to the
Government for the implementation of OSHA and among other things acts as an advisory body on
policy, standards and matters related to Occupational Safety and Health and makes
recommendations on regulations and the establishment of codes of practice. To date there are no
such regulations or approved codes of practices. It is expected that the employer seek guidance in
accordance to known and suitable and sufficient regulations such as The Control of Substances
Hazardous to Health Regulations (COSHH), Dangerous Substances and Explosive Atmospheres
Regulations 200212 (DSEAR) as TPG plant involves working in areas where the atmospheres
could potentially be explosive, due to the presence of natural gas, as defined by the DSEAR
regulations. The DSEAR regulations aim to protect people who may be affected by substances
which can cause explosions or fires. Areas are classified as either hazardous or non-hazardous
based, and depending on the degree of presence of the hazardous substance in the area are
classified by zones.
The Occupational Safety and Health Agency (The Agency) functions as the enforcing body with
legal powers of access to industrial establishments and to this end OSHA provides for the
appointment of a supervisory body of inspectors, medical inspectors and a Chief Inspector. OSHA
addresses a variety of workplace issues including workplace health, safety, welfare, occupational
diseases. To this end OSHA imposes duties on employers, occupiers, employees and
manufacturers and suppliers of goods. Some of these duties are not only owed to persons working
at the industrial establishment but also to visitors and persons in the environs who might be
affected by the activities carried out at the industrial establishment. There are certain general
duties owed by employers to, among other things, ensure the safety, health and welfare at work of
all employees, so far as is “reasonably practicable”. Although not mentioned in OSHA, employers
should establish “due diligence procedures”, that is, a system that provides for the taking of
reasonable steps to ensure that the duties imposed by OSHA are performed. Other specific duties
pertain in relation to the health and safety of employees, the employment of young persons (16
years or less in age), where hazardous chemicals or substances are present and in relation to the
action to be taken in the event of accidents and occupational diseases.
In addition to employers, occupiers are also specifically identified under OSHA. An “occupier” is
defined for the purposes of OSHA as the person who has the ultimate control over the affairs of an
industrial establishment. Many of the duties of an occupier are owed directly to employees. An
occupier owes certain general duties in terms of formulating general policy on health and safety of
employees and the preparation of various emergency plans, the appointment of a safety
practitioner and also to ensure that no unsafe structures exist at the industrial establishment. In
addition, an occupier is responsible for managing the environment and protecting the public from
dangers created by the operations of the industrial establishment. An occupier also owes other
duties to the safety (including fire safety), health and welfare of employees, and in relation to the
action to be taken in the event of accidents and occupational diseases. Employees are also subject
to certain duties under OSHA. The duties owed by an employee include the duty to: take
reasonable care for the safety of himself and others; to report contraventions of OSHA to his
employer; to use personal protection and clothing devices correctly; to ensure that he is not
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intoxicated at work so as to be a danger to himself and others and to act reasonably in exercising
his discretion (where applicable) to refuse to work.
OSHA provides for a variety of penalties in the event of a person being convicted of a statutory
offence. Directors and/or officers of companies who can be shown to have consented, acquiesced
or connived in such offences can also be held personally liable. Criminal proceedings are handled
by a Court of summary jurisdiction whilst civil proceedings fall under the jurisdiction of the Industrial
Court. Aggrieved persons are also entitled to lodge complaints with the Industrial Court and such
offenders, quite apart from statutorily imposed penalties and terms of imprisonment, also face the
possibility of civil awards in damages being made against them under OSHA. In terms of civil
liability for OSHA violations, there are judgments of the Industrial Court in favour of the Authority
against companies for breaches of OSHA where injury and/or death resulted. The fines in those
cases ranged from US$15,000.00 to US$20,000 for each individual section that was breached,
together with an order for compensation to be paid to the employee or to his estate. There have
also been several high-profile instances of organisations being shut down for offences.
3.0 Review of the Health and Safety Management System

3.1 Description of Health and Safety Management System
The TPG Safety and Health management system (SHMS) is based on BS OHSAS 18001: 2007.
This is a written document developed by the Safety and Health Manager and approved and
endorsed by the Chief Executive Officer, it can be accessed by all employees via TPG’s intranet
system. This standard is comprised of 5 main components as illustrated in figure 1 below with an
underlying theme of continual improvement. It is based on the methodology known as Plan-
Do-Check-Act (PDCA). PDCA can be briefly described as follows;
 Plan: establish the objectives and processes necessary to deliver results in

accordance with the organization’s OH&S policy.
 Do: implement the processes.
 Check: monitor and measure processes against OH&S policy, objectives,
legal and other requirements, and report the results.
 Act: take actions to continually improve OH&S performance.
The structure of TPG’s SHMS is closely aligned with that of the OHSAS 18001 standard as can be
seen in this review.
4.2 S&H Policy(PLAN): TPG demonstrates its commitment to the prevention of injury and ill health
and compliance to applicable legislation by way of its written Safety and Health Policy. It provides a
framework for setting and reviewing it S&H objectives, is supported by TPG’s Chief Executive
Office and made available to all workers via the intranet. It is reviewed annually.
4.3 Planning
4.3.1 Hazard identification, risk assessment and determining of controls; Hazard identification and
risk assessment take place using 3 levels. First the risks associated with the work site is assessed
taking into consideration major processes and hazards, there is a task specific assessment
required for all work taking place ( level 2) then when required, there is means for completing
specific assessments (level 3) requiring specialised risk assessments methods under specific
legislation e.g. when carrying out lifting operations (LOLER 1998). There is an internal Risk
Assessment Committee (RAC) consisting of Project Engineers, HSE Engineers/Officers,
Supervisors and Workmen representative Evaluation is done using a three by three matrix of
likelihood and severity (see Appendix A), which is used to evaluate the risk level with each risk
level (high, medium, low) having a corresponding guidance on how to proceed following the
evaluation. TPG does not allow working with a high risk rating (9), all reasonably practicable
solutions must be put into place to reduce risk to maximum medium (6) acceptable risk rating.
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4.3.2 Legal and other requirements; Relevant legislation is identified when developing procedures.
Legislation made available to all employees via intranet.
4.3.3 Objectives and programs: TPG’s management team has developed a H&S strategic plan
which sets out its objectives. These are set based on both lagging and leading indicators such as
accidents and incidents, findings from audits, trends identified from the company hazard reporting
system (Changing Our Attitude Correcting Hazards, changes in legislation and closure of action
items. A dedicated budget is allocated for accomplishing all H&S projects.
4.4 Implementation and Operation (Do)
4.4.1 Resources, roles, responsibility, accountability and authority: H&S roles and responsibilities
clearly stated in all employees job descriptions including top management and supervisors.
Accountability reemphasized in each person’s performance management charters. Chief Executive
officer responsible overall H&S, duties for implementing H&S objectives delegated to H&S Team
lead, this is communicated to all employees and contractors via inductions and orientations.
4.4.2 Competence, Training and Awareness: TPG has a robust new hire program which ensures
person with the applicable education, training and experience are brought into the organization. An
in depth HSE training program is developed according to the needs of individuals and a continuous
competency evaluation process in used. All persons are made aware of their roles, responsibilities
and accountabilities as it relates to HSE via detailed job descriptions and performance
management charters.
4.4.3 Communication, Participation and consultation
4.4.3.1 Communication; Communications policies are developed and used for both internal and
external communication. There are provisions for communication at all levels throughout the
organization and a grievance process for extenuating circumstances. A three tiered induction
system is in place, level 1 basic induction for visitors, level 2 for contractors which incorporates
safe work systems and job specific hazards and level 3 which is a robust HSE orientation for TPG
employees which further details all TPS’s HSE requirements, information and supervisory training.
4.4.3.2 Participation and Consultation ; TPG ensures worker participation at all levels for hazard
identification and correction, incident reporting and investigation, review of H&S policies and
procedures. This is done through the HSE committee which comprises of worker representatives
for all disciplines and is sponsored by the Chief executive Officer. Contractor input is sort when
matters directly affect them or when specialist advice may be required.
4.4.4 Documentation: There is a documented H&S Strategic Plan which is available to all
employees via intranet. Safe work system is documented and supported by written and approved
procedures such and Permit To Work, Lock Out Tag Out and many more. Legal and Risk registers
are kept up to date and audits (internal and external) documented. All corrective actions from
incidents, risk assessments and audits are tracked via the Action Item Register.
4.4.5 Control of documents; all documents are controlled via a document control database, the
content of which is available to all employees via company intranet. Safety critical procedures are
kept in hard copy at each department in the event of a loss of internet access.
4.4.6 Operational control: Management of Change process used for changes to organization and
process plant, temporary changes to operating instructions and if there is a change of personnel.
All new suppliers and contractors are assessed through an assessment process. A purchase
request will not be processed by the finance department for any supplier not on the approved
suppliers/vendors list.
4.4.7 Emergency preparedness and response; emergency plans developed for natural disasters
and internal emergencies. Plans are robust with some exercises regularly carried out in which
employees routinely take part. Process for coordination with surrounding neighbours in place.
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4.5 Checking (Check)
4.5.1 Performance measurement and monitoring; Performance measurement and monitoring both
reactive and proactive measures are in place to assess the health and safety performance of the
company. Reactive measures record the various levels of injury, near misses, dangerous
occurrences and reportable diseases as defined in schedules 2 and 3 respectively of the RIDDOR
regulations 199522. In addition to the RIDDOR reportable injuries, first aid and medical treatment
injuries are required to be reported under the TTOSH Act. TPG monitors a wide range of proactive
measures which include internal audits, required training completed, the number of outstanding
actions from audits, the number of potential hazards reported, corrective actions overdue, the
number of workplace inspections carried out and the number of behavioural safety observations
carried out. All of the reactive and proactive key performance indicator targets are linked to each
employees year-end bonus.
4.5.2 Evaluation of Compliance: All Audits, internal and external are recorded and analysed for
non-compliance issues including legal issues by the Compliance and Auditing team.
4.5.3 Incident investigation, nonconformity, corrective action and preventive action
4.5.3.1 Incident investigation; All accidents and incidents including near hits are investigated by the
HSE committee. This involves identifying the underlying and root causes of the incident in order to
ensure the correct corrective actions are put in place to prevent reoccurrence. Corrective actions
are put into the Action Item Register database.
4.5.4 Control of records; TPG’s Planning and Document Control department has established a
procedure for, for the identification, storage, protection, retrieval, retention and disposal of records.
4.5.5 Internal Audit; An internal auditing procedure is established which requires audits on different
aspects of the H&S Management System. Different levels of Audits are conducted, quarterly and
semi-annually, results are communicated to the Executive management for immediate action.
4.6 Management Review; (Act)
Management review meeting are held twice a year and chaired by the CEO. Health and safety
performance, results of audits (both internal and external), communications from external
organisations e.g. customer complaints, reviews of changes to relevant legislation, and
opportunities for improvement are addressed.
3.2 Safety and Health Management System - Gap Analysis

OHSAS TPG’s Compliance to requirements in
18001:2007 Present Health and Safety Management Gaps Identified
Section & Clause System
4.2 OH& S Policy Written H&S policy/ statement signed and Fully Compliant with
dated by the Chief Executive Officer. It was requirements.
developed in consultation with the HSE
Committee which comprises of
representatives from all areas and level of
TPS.
The policy is appropriate to the nature and

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scale of the organization’s OH&S risks and
committed to the prevention of injury and ill
health with continual improvement in
Occupational Health and Safety performance
with the ultimate goal of zero injuries and ill
health, it is also supported by the
Environmental Commitment Policy.
Framework for setting and reviewing QH&S

objectives are stated in the policy.
E-copy posted on intranet and hard copies

posted in all notice boards
The Policy is communicated to all levels

within the organization and to sub-contractors
in their respective scope of works.
Policy have been reviewed and updated

annually by Management review Committee
and chaired by the CEO.
4.3. Planning An annual faclilty risk assessment is Risk to works conducted at

completed annually by a competent external heights not fully assessed,
4.3.1 hazard party. There is an internal Risk Assessment Working on heights not
identification, risk Committee (RAC) consisting of Project identified as high risk and
assessment and Engineers, HSE Engineers/Officers, therefore insufficient
risks control. Supervisors and Worker representative .The controls in place
RAC is responsible for preparing risk
assessment for all routine & non-routine No means to assess
activities. Hazard identification and risk psychosocial stresses
assessment take place using 3 levels. within the organisation.
TPG Job Safety Analysis Procedure identifies

hazards created in the vicinity of the
workplace created by work related activities
(assessed as environmental) as well as risks
associated with Infrastructure, equipment and
materials at the workplace
Management Of Change procedure in place
to assess risks form changes or proposed
changes in the organization, its activities or
material, design of work areas, processes,
installations, machinery/equipment, operating
procedures and work organization, including
their adaptation to human capabilities.
When determining controls or changing
existing controls, consideration is given to
reducing risk according to the following: 1)
elimination, 2) substitution, 3) engineering
controls, 4) signage/warning/administrative,
5) Personal protective equipment as
expressed in the Risk management Policy
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4.3.2 Legal and TPGs legal requirements Policy establishes a Fully compliance with the
other requirements process to identify, have access, standards
Regulations communicate to all concerned and monitor
the revisions of the relevant Laws &
Regulations. The laws as follows:
 TT OSH Act (local)

 Water Pollution Rules (Local)
 Noise Pollution Rule (Local)
 NFPA 70 and 70E
 OSHA CFR 1910
A register of relevant Occupational, Health

and Safety guidance has been established
and is being maintained according to the
procedure.
4.3.3 Objectives A procedure has been established for Fully compliant with the
and programme/s developing and reviewing the implementation standards
of H&S objectives and targets and
documented. The objectives and targets are
set in the annual Strategic Plan established
consistent with the H&S Policy and are
influenced by the significance of risks,
technological options, financial, operational
and business requirements and the views of
interested parties including Sector
‘Regulatory Authorities’ and other legislative
requirements.
Database for monitoring HSE related Metrics

and identifying trends.
Strategic plan developed based on review
and analysis of data trends.
Audits done both internally and by external
parties annually. Actions followed to closure
via Action Items Register Database.
Clause4.3.3 of OHSAS 18001:2007
The management has set a high-level

objectives related to H&S for continual
improvement of the Organization’s H&s
performance comprising of both leading and
lagging indicators.
The H&S Programme(s) are reviewed at

quarterly and if necessary amended to
address changes to the activities & services
or operating condition of the organization.
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A dedicated HSE budget is allocated.
4.4 The management has drafted an Compliance with

Implementation organizational chart and the annual H&S requirements
and operation states specific objectives, targets and
timelines.
Adequate resource in terms of finance

(dedicated budget), human resource,
equipment, infrastructure and technology for
4.4.1 Resources,
roles, effectively implementing H&S is provided by
responsibility, the management, which includes a team of
accountability and HSE professionals dedicated to implementing
HSE objectives.
authority
The HSE Roles and Responsibilities of
various personnel in the organization is
communicated adequately upon their arrival
through well-developed job descriptions and
an in-depth HSE Induction and relevant HSE
training.
And any personnel who experience a change

in their role are briefed suitably on their HSE
roles in the current role. This is controlled
under the Management Of Change program
4.4.2 Competence, The organization has established a The training needs

Training and procedure for identifying training needs and assessment for specific
Awareness for providing training to all employees at needs does not identify all
risks, e.g. working on
different levels of the organisation whose
heights not clearly
activities has significant impact on the H&S identified as high risk
performance. The training procedure activity.
incorporates the need to make the
employees at levels aware of their roles and
responsibilities in adhering to the OH&S
policy and procedures including:
 H&S awareness and understanding

of the H&S Management System
 The significant H&S hazards,-actual
or potential-of their activities and
their benefits of improved
performance;
 The potential consequences from the
deviations from specified operating
procedures;
 Emergency preparedness and
response requirements.
In addition employees are trained on,

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LOTO(Lock Out & Tag Out), Permit To work,
Electrical safety , Manual Handling, Hot Work
activities, working with chemicals etc
depending on the necessity. Each of these
are governed by the relevant procedure
which was developed based on applicable
regulations. E.g Lock Out Tag Out Procedure
based on OSHA The records of all H&S
training programs are documented and
maintained.
Training matrix developed and communicated
4.4.3 Through TPG’ communication policy it has Compliance with

Communication, procedures for internal and external requirements
participation and communication. The internal communication
consultation. (through Inter office memos, notice boards, e-
mails, alerts and internal meetings) includes
providing information to various levels in the
organization with regard to its H&S aspects
and H&S Management System. External
communication is facilitated through regular
meetings with established community groups
4.4.3.1 and leaders.
Communication
Communication with contractor is established
through meetings with Supervisors, Hard
copy information posted on Notice boards as
well as all site meeting (entire worksite must
participate)
4.4.3.2 TPG has formed the HSE Committee Fully compliant with
participation & comprising of representation from all requirements
Consultation disciplines and representation from all levels
of the Organisation. The CEO mandates this
team to meet at least once monthly. This
meeting addresses matters of H&S concerns
and seeks employee feedback for corrective
actions. The representatives are also tasked
with communicating mandates on relevant
issues. Minutes of these meetings are made
available to all employees via intranet and
posted on notice boards.
All employees participate in Hazard
recognition and correction via the internal
hazard reporting and correction system
(COACH), these observations are
categorised and trends identified, the HSE
committee reviews and addresses trends.
4.4.4 The following documents are identified and Compliance with the
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Documentation discussed as below; requirements
 HS&E Polices
 H&S Strategic Plan
 H&S Management System Manual
 Safe work System Procedures-eg Hot
Work, Confined Space Entry
 General Procedures
 Operational Standard Operating
Procedures
 Legal Register
 Risk Register
 Emergency Preparation and
Response Procedures
 Checklists
 Internal Audits
 Incident Investigation records
 Training Matrix and completion
records
 Plant equipment maintenance and
certification records
 SDS for all chemicals used on site
4.4.5 Control of TPG’s document control procedure Compliance with
documents addresses identification, preparation, requirements
approval, issue, changes/modifications, re-
issues and review of all H&S Management
System document.
Records of all current and valid documents

and also background information related to
changes are maintained whenever an
amendment is made on the entire procedure.
Management Representative (H&S)

maintains a hard copy and soft copy of the
obsolete document for future reference and
all other copies of obsolete documents are
destroyed by the respective copyholders.
4.4.6 Operational The organization has established operational Compliance with

control control procedures for operations and requirements
activities that are associated with the
identified significant H&S risk in line with the
policy, objectives & targets.
Management of Change procedure in place .
The procedures for communicating the

relevant requirements to suppliers and
contractors have also been established and
implemented.
4.4.7 Emergency Emergency Preparedness Plan developed to No periodic testing of

preparedness and ensure appropriate responses to unexpected Emergency evacuation
or accident incidents relating to H&S as well drills for the identified
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response as natural disasters. emergencies such as Fire
Emergencies and site
Clause 4.4.7 of OHSAS 18001:2007 evacuation, Rescue from
heights and Tsunami
A procedure has been established for response.
preventing and mitigating the impacts of such
emergency situations. And the procedure
also covers the requirement of periodical
mock drills for testing/ verification of
implementation of such procedures where
practicable.
TPG reviews and revises its emergency

preparedness plan and response procedures
after the occurrence of incidents or
emergency situations where necessary.
TPG regularly participates in emergency

communication and exercises with it’s
neighbours.
TPG have identified nine type of emergency

situations , which are illustrated in the
following Emergency response procedures:
 Fire and Major accidents on site

 Site evacuation
 Environmental Spillage Clean-up /
containment procedures
 Earthquake response
 Hurricane preparedness and
response
 Rescue from heights
 Rescue From confined space
 Tsunami response
 Emergency response with Estate
4.5 Checking The organization has established a system Compliance with
for monitoring and measuring the actual requirements
performance of key characteristics against
the H&S objectives and targets set about in
4.5.1 Performance it’s Strategic Plan using both proactive and
measurement and reactive measures. This includes evaluation
monitoring of compliance with relevant H&S legislations
and regulations, targets for audits and
training, review of incident data, hazard
observations and targets for close out of
action items.
The results are analyzed to determine the

areas of success and to identify areas
requiring corrective and improvement on the
basis of performance indicators. OH&S
performance on incident matrix is measured
and monitored on a monthly basis.
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4.5.2 Evaluation of TPG has developed a system for monitoring Compliance with
Compliance all the applicable legal requirements and the requirements
compliance level to legal requirements, which
is verified in the entire operation of the
organization at regular planned intervals.
Observations, and actions are recorded and
circulated to Chief Executive Officer and
Compliance Auditor.
The records of repetitive violation are

discussed in the management review
meetings to permanently eliminate the non-
conformance.
4.5.3 Incident TPG has established an Incident Individuals conducting

investigation, management procedure to investigate all incident investigations
nonconformity, incidents including near miss to identify the have not been trained in
corrective action root cause, need for corrective and root-cause analysis
and preventive preventive action, for continual improvement techniques as a result
action and underlying potential deficiencies in the Roots causes are not
management system. clearly identified to prevent
4.5.3.1 Incidence reoccurrence.
investigation The HSE Committee reviews all incidents
and communicates the summary of incidents,
causes and corrective action to all employees
via email. This is mandated in TPG’s incident
management procedure.
Action items recorded in Action Item Register

for follow through till closure.
4.5.3.2 Non- The organization has established a Reviewing the

conformity, procedure for handling and investigating the effectiveness of corrective
corrective action & causes for actual non-conformance and action(s) and preventive
preventive action potential non-conformances and taking action(s) taken needs
corrective and preventive actions respectively improvement as this is not
as appropriate to the magnitude of problems identified in the procedure
to mitigate any impact caused, along with and there is no evidence
defined responsibilities and authority. This this is taking place
process is established in TPG’s Incident
reporting and investigation procedure and
well as the Risk Assessment procedure.
The procedures also covers the record

keeping and communicating of causes
identified, corrective and preventive actions
taken and changes , if any, incorporated in
the respective procedure as part of
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standardization.
Actions are recorded in the Action Item

Register database.
4.5.4 Control of Through TPG’s Planning and Document Compliance with

records Control Department, it has established requirements
procedures for maintaining records, which
are legible, identifiable and easily traceable to
the activity, product or service. A procedure
has been established for identification,
collection, indexing, access, filling, storage,
maintenance and the retention period and
disposition of OH&S management records.
Records are maintained to demonstrate

conformance to the requirements of
Standards OHSAS 18001:2007 for a
minimum period of 2 years.
4.5.5 Internal Audit The organization has established an Auditing Compliance with
procedure which covers the audit planning, requirements
scheduling, audit methodology, recording,
and reporting results. There are H&S Deficiencies identified with
Management system audits to be carried out closure of
at predetermined time intervals in order to recommendations and
determine compliance with relevant action items arising out if
management system requirements. There audits.
are also procedure specific audits (checks
compliance with relevant procedures eg
LOTO and Hot Work against legal
requirements and assess applicability to
TPG’s system and there are Job Specific
audits to assess compliance of on going jobs
to TPG’s requirements.
reporting results and retaining associated

records; and
the determination of audit criteria, scope,

frequency and methods.
Audits are done by different levels of the

organization – Executive, Team Lead,
Engineers and Workers. All persons are
suitably trained for the level of audits being
performed.
4.6 management Management Review meeting held quarterly Compliance with

Page 14 of 32
Review to discuss the overall performance of the requirements however
organization. It is chaired by the Chief follow up of action items
Executive Officer and all members of HSE not done effectively as
committee, Executive Management and there were cases observed
Team Leads participate in the meeting. Items open 6 months after due
discussed includes: date.
 status of incident investigations,

corrective actions and preventive
actions
 results of internal audits and
evaluations of compliance with
applicable legal requirements
 recommendations for improvement
 HSE related complaints (internal and
external)
 implementation of the agreed
strategic plan
Follow up actions and accountable parties
are identified and minutes recorded to be
reviewed and updated at subsequent
meetings.
Page 15 of 32
4.0 Significant Hazards

This section outlines the most significant hazards present at TGU’s facility. The hazards were
identified during site visits, task analyses, employee consultations through interviews and
anonymous surveys, examination of accident and incident reports and ill health data, trends as
outlined previously in the methodology section of the report. A hazard is the potential for harm and
is associated with a condition or activity that, if left uncontrolled, can result in an injury or illness.
The identified hazards have been grouped into two categories; Physical hazards and Health and
Welfare hazards.
Hazard prioritization was done based on the consequence, which is a means to rank the worst
severity of risks associate with a particular task, and how likely an injury would occur and how
many people could be affected or exposed taking into consideration existing control measures. A
simple 3 x 3 risk assessment matrix was then used to assign a numerical value to the
Consequence and likelihood, the resultant score gives determines the overall risk rating.
Consequences with a Low level of potential harm, e.g. may result in the need for first aid, was
given a rating of 1, those which could have resulted in greater injury such as burns, strains, or
temporary disability was assigned Moderate level of harm and given a rating of 2, Potential death,
permanent disability and major injuries are the result of significant harm and therefore assigned the
highest rating of 3. The potential or likelihood of the harm occurring was based on if it was Unlikely
(1), Possible (2), or Likely (3) to occur. The details 3 x 3 Matrix used can be found in Appendix 1.
Following the risk evaluation and prioritization of hazards, the most significant risk from both the
physical and health and welfare hazards were selected and a detailed risk assessment carried out
on each. ALARP chart is given below to identify the risk magnitude.
3 x 3 Risk Assessment Matrix

LIKELIHOOD OF Likely Possible Unlikely
OCCURRENCE Probably will occur in time if not Possible to occur in time Unlikely to occur; may
corrected, or probably will occur if not corrected or assume exposure, will
one or more times. standard improved. not occur.
3 2 1
CONSEQUENCES
High
 Imminent and immediate danger 3 9 6 3
of death or Permanent disability.
 Major Environmental Impact/
Violation of Legal Requirement
Moderate
 Hospitalized minor injury, 2 6 4 2
reversible illness.
 Spillage/ Leak of Non- Hazardous
Chemicals
 Non Compliance with Legal
Requirement
Low
 First aid or minor medical 1 3 2 1
treatment.
 Minor Spillage/ Waste
Page 16 of 32
4.1 Physical Hazards

No Hazards Hazard Effects C L RR
1 Substandard surface conditions Slips, trips and falls 2 3 6
2 Working with powered equipment and Electrical shock, cuts, amputation, 3 2 6

tools
3 Fire hazards (Flammable and Explosive Severe burns from contact with fire, 3 2 6
Atmospheres, fire emergency response) becoming trapped and suffocation
from smoke inhalation.
4 Work on with elevated platforms Electric shock, falls from height 3 3 9
resulting into broken bones, death
5 Crane operations Dropped objects causing crushing or 2 2 4
significant injuries, electrocution
from coming into contact with high
voltage line
6 Working at heights Falls from heights resulting in 3 2 6
broken bones or death, tools falling
from heights coming in contact with
persons on lower level resulting in
major injury, sparks or slag hot
material falling and entering another
area creating adverse reactions
such as explosions or fire
7 Vehicle movement at site Contact with persons or structures, 2 1 2
electricity
1.0 Substandard surface/flooring conditions
During site walkthroughs, it was observed that throughout the facility there were instances of
substandard surfaces noted. The water treatment facility is designed with a built-in spill
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containment area under its flooring; the floors are sloped to aid in drainage of any spills and are
coated with chemical and slip resistant paint. There are many areas of the floor which are chipped
and the slip resistant coating peeled off. Laboratory workers and operations staffs that access this
area daily are exposed to slip and fall hazards resulting from improper drainage. Rotten wooden
floors in the retrofitted 40 feet storage containers used to house temporary contractors and security
staff were found, this is a trip and fall hazards which can lead to personal injuries. These slip, trip
and fall hazards can result in personal injuries. Costs from these injuries include medical
expenses, additional labor and potential civil claims.
It is quite evident that there are possible chances of slip, trip and fall injuries by the chipped floor
and staff housing area, which can lead to minor to major injuries and can be legally claimed by
workers. Barrication should be placed on affected areas, posters should also be displayed on the
walls of adjacent areas for the awareness of these hazards and risks. Immediate repair work of
housing section as well as floor of working area should be started.
Laws & Regulations:
1. As per OSHA 29CFR 1910.22 regulation all places of employment walkways, passages and floors
must be kept clean, orderly and dry condition and free of hazards e.g. protruding objects, loose
boards, corrosion, leaks, spills, wet surfaces etc.
1.0 Working with powered equipment
The workshop area has fixed equipment such as lathes, power presses, pedestal drills and
pedestal grinders and circular saw used for general maintenance purposes. The area is well
designed with equipment sufficiently separated to allow for comfortable operation of multiple pieces
simultaneously. Good signage in the work shop advising persons of required PPE. Designated
pedestrian walkway kept clear and barriers surrounding the equipment prevent hazardous debris
from coming into contact with pedestrians. Fixed Guards and safety equipment were generally in-
place however there was a broken interlock guard on the circular saw, this could lead to
employees touching the blade and receiving severe cuts. The operator is at risk but any one
cleaning or in the near vicinity could touch the machine whilst the blade is still moving. The
company could be sued if an employee is injured; they are also in breach of PUWER. The wood
being used would also become a biological hazard and hazardous waste. Emergency stops are
installed however not easily identifiable, these should be easy to access and visible to ensure a
quick response time in the event of an emergency. Maintenance staff has undergone suitable
training which included the safe use of all equipment as shown in the training records and
competency documents however there is no system in place for controlled use. The work shop
area is normally kept open and is easily accessed by anyone, through interviews with staff it was
realized that it is common practice to allow contractors without documented training to operate the
equipment.
It is quite clear that inspection is done properly, so proper weekly inspection of all machines and
equipment should be carries out and recorded for proper records. Emergency and preparedness
plan should be updated with respect to new design. Emergency stops should be properly labeled
with respect to controls, preferably using LED lights on stops to make them visible to workers and
staff. There should be a system to measure the effectiveness of given trainings on technical
grounds and health, safety and environment. It is recommended that access control to the
workshop are be implemented and a system to control use of the powered tools be put in place,
this could be a in the form of a simple permit with job safety analysis, issued to users by the
Page 18 of 32
workshop supervisor. This system can be audited periodically by the existing Advanced Safety
Audits (ASA) programs which will identify deficiencies and allow for corrective actions to be
implemented and followed to closure.
Laws & Regulations:
1. As per OSHA 29CFR 1910.242,243 regulation, Employers must ensure that employees
use hand and portable power tools and equipment that are in safe condition, including tools
supplied by employees.
2. Local Order No. 61/ 1991, requires earthing of the powered equipment, use of guards
especially for rotating equipment e.g. drills, grinders, saws etc.
3.0 Fire Hazards

3.1 Flammable / Explosive Atmospheres
Natural Gas is used to power the generating turbines and is fed directly from a neighbouring
process facility and delivered via pipelines which run throughout TGUs site. There are several
provisions which allow natural gas to be vented during normal operations. As a consequence
several areas of the plant are designated as zone 1 areas as described in The Dangerous
Substances and Explosive Atmospheres regulations 2002, ‘A place in which an explosive
atmosphere consisting of a mixture with air of dangerous substances in the form of gas, vapour or
mist is likely to occur in normal operations occasionally. Hot work activities taking place in or
around these areas create a significant risk of ignition and explosion should natural gas be venting
at the same time. A Natural Gas explosion on the TGU site could be catastrophic to the site and
the surrounding areas including the public. This can lead to significant loss of plant equipment,
personnel injury, damage to the public, decrease in ability to fulfil customer and shareholders
expectations and will also lead to TGU being shown negatively in the media. To eliminate this risk,
TGU has adequate signage of the hazardous zones and a robust Hot Work operations policy which
only allows hot work after isolation and purging of all flammable gases, continuous atmospheric
monitoring and a dedicated Fire watch. Vehicle movement in the plant areas such as Road tankers
delivering chemicals to the water treatment plant, Forklifts and other vehicles used to transport
material and workers pose a risk for the vehicle to strike equipment or worse still people working in
the area. A recent incident (Oct 2005) in Texas which occurred at a petrochemical plant showed
the impact a vehicle collision with process plant can have in this type of environment. In the
incident a forklift towing a trailer collided with a line containing highly flammable liquid propylene,
causing a release and a vapour cloud explosion. Sixteen workers were injured, the process unit
was heavily damaged, and a nearby school was evacuated. In order to mitigate against this type of
risk there are barriers around the area to prevent contact with any plant or pipe work, a banks man
is used to guide the drivers, and the equipment itself has flashing lights and audible alarms which
sound when reversing. Audits of the hot work permitting system and traffic control should be
continued with improvements areas recorded in TGU Action Item Register where it can be
monitored for completion.
3.2Fire hazards- Emergency Response

For a fire to occur it needs a source of ignition, (heat or flame) and a potential source of fuel and
oxygen. If the ignition sources and fuel can be kept apart, removed, eliminated or reduced, then
the risks to people and plant is minimised. There are many fire hazards across TGU’s facility; some
sources of ignition include:
 Open flames such as those used in cutting, welding, grinding. (controlled by TPG Hot Work
procedure)
Page 19 of 32
 Persons smoking on the facility as observed in several incident reports.
Sources of fuel include:
 Combustible material such as oily rags overflowing it’s storage bin and waste oil, left close
to generating turbines
 Stationary supplies consisting paper, plastic folders, and other office stock stored in spare
room with installed shelving almost at ceiling height where material are in close contact with
light bulbs.
Unsafe conditions include:
 Emergency exits in the office building blocked by storage of old printer, this could lead to
persons being unable to escape or causing a further trip and fall hazard on the stairway.
 Fire extinguishers blocked by furniture or removed from location on the process area.
It is recommended that a no smoking policy be implemented immediately and continue the use of
the Hot Work procedure to reduce the potential for ignition source. TPG has a hazard identification
program call the “Hazard Hunt Walkdowns” in which templates are developed which outline the
safe conditions desirable across the facility. Groups of employee use these templates to conduct
audits and correct issues, their participation is rewarded via the end of year bonus. Storage rooms
should be included in this program as well as checking the oily rag bins.
4.0 Working with Mobile elevated platforms
Hazards associated with operating Man Lift and similar type aerial work equipment’s common
dangers of operating a man lift involve more than just fall from heights. Scissor lifts hazards
including body party or limb getting caught and crushed in the scissor arms. This could occur when
the scissor lift lowers and the arms compress over each other. Danger of electrocution when
come into contact of power line, checking for power lines or electrical hazards in the work area
before operating a man lift is essential. Loading too much weight into the basket of the man lift
could result in the man lift collapsing or being overturned. Overturning could also result when the
base of the man lift is set on uneven ground or slopes. Potential workers falling off the man lift drop
an object from up high on the man lift and could cause bodily harm to individuals below. This is
why most workers with a man lift are required to put up safety signs or caution around the
perimeter of their workspace. Uses of full-body harness where workers need to be train on it use
e.g. never hook the lanyard snap hook outside the basket, there is lanyard securing point designed
in the basket itself.
It is recommended to use permit to work system whenever working on elevated performs. Also
availability of harnesses for workers working at a height of more than 2 meters as per OSHA
regulations. Proper inspections should be carried out before starting any job. A banks man should
be used when moving equipment.
5.0 Hazards of Crane operations:
For Maintenance activities TGU uses many cranes for lifting equipment for removal to service or
removing parts of structures in order to gain access to equipment. Main hazards associated with
overhead and mobile cranes are collapsing or toppling which cause by sitting the crane on uneven
Page 20 of 32
ground and excessive load. The jib of the crane can strike against other structure which can lead to
serious accident and property damage, the load can fall from height, striking against object and
can contact with live overhead which could result in serious consequence. Damage attachments
used in conjunction with lifting equipment could result in failure and serious accident, Main hazards
associated with overhead and mobile cranes are following:
 Overloading
According to OSHA, 80 percent of all crane upsets and structural failures can be attributed to
exceeding the crane’s operational capacity. When a crane is overloaded, it is subject to structural
stresses that may cause irreversible damage. Swinging or sudden dropping of the load, using
defective components, hoisting a load beyond capacity, dragging a load and side-loading a boom
can all cause overloading. Nearly 80 percent of these upsets can be attributed to predictable
human error when the operator inadvertently exceeds the crane’s lifting capacity. Overloading
most often occurs when poorly trained personnel are allowed to operate cranes. Using
technologies such as load-measuring systems for training and planning can greatly reduce the
hazard of overloading and operator incompetency. TPG has a robust lifting and rigging policy and
procedure in practice which includes hiring competent contractors and using certified equipment,
and approved lifting plans. TPS’s mechanical engineer oversees all lifting operators and in also
certified on rigging and lifting.
Laws & Regulations:
1. British Standard BS 7121 (3.7) states, safe working load (SWL) must not be exceeded
other than for the express purpose of testing the crane under the supervision of a
competent person.
2. OSHA 1926.753(e)3, to avoid accidents due to overloading the total load shall not be
exceeded in any case.
3. Lifting Operations and Lifting Equipment Regulations 1998 (LOLER),

Regulation- 4(b) every part of a load and anything attached to it and used in lifting it is of
adequate strength All lifting operations involving lifting equipment must be properly planned
by a competent person, appropriately supervised and carried out in a safe manner.
 Electrical Hazards
According to OSHA, nearly 50 percent of overhead and mobile cranes accidents are the result of
machinery coming into contact with a power source during operation. Power line contact is literally
defined as the inadvertent contact of any metal part of a crane with a high-voltage power line.
Power line contact most often occurs when the crane is moving materials nearby or under
energized power lines and the hoist line or boom touches one of them. Usually, the person who is
electrocuted is touching the crane when it comes in contact with the power line. But, the danger is
not just limited to the operator. It extends to all personnel in the vicinity. As a part of TPGs Vehicle
Movement plan, a Route plan is need for the use of all heavy equipment which details it’s path
from entry to exit and all working locations, it must also be accompanied by a banksman.
Laws & Regulations:
1. British Standard BS 7121 code of practices for safe use of crane states, during work near
overhead power lines there must be 10 feet distance between the crane boom and the
power lines.
Page 21 of 32
6.0 Working at heights-
6.1 Materials Falling:
Falling from a height on all workplace is a major concern. Most of the height activities are
performed with cranes. Mechanical failure, slipping and incompetency’s of riggers, crane operators
is a major reason for fatalities at the workplace. During the operation of crane lifting keep an eye
on load it may slip or damage the property. Previous data show that approximately 25 persons died
in the workplace as a result of accidents because of persons caught in load. The risk can be
reduced if the hoist is inspected. All lifting types of equipment should be inspected and maintain
properly to prevent these accidents. Other reasons include the fall of tools and persons from a
height. Tools are not tied while working at height and fall on persons at the ground.
Laws & Regulations:
1. British Standard BS 7121 code of practices for safe use of crane states, during work near
overhead power lines there must be 10 ft distant between the crane boom and the power
lines.
2. OSHA 1926.1408(d)(2)(iii),For equipment with articulating or extensible booms: The

uppermost part of the equipment, with the boom in the fully extended position, at true
vertical, would be more than 20 feet below the plane of the power line
6.2 Scaffolding)
Personel falling and object falling are a common hazard in work at height in TGU’S falling object
could injure someone; steps are taken to make sure that this is prevented. The effectiveness of
any measures will depend on the material and tools that are being used and the effect that
weather, wind or other factors may have in creating a more common hazard. It is recommended
that risk of falling materials causing injury should be minimized by keeping workplaces at height
clear of loose materials and stacking or storing materials well back from edges. Sheets of plywood,
insulation, and decking are secured to prevent them from being blown over edges. Ways of
preventing objects rolling or being kicked off the edge might include toe-boards or solid barriers or
attach them to people or fixed structures. Any guards used (including brick guards) must be robust
and usually require a mid-rail. Tools or personal items, such as mobile phones, can cause injury if
they hit someone. High visibility netting may be one way of dealing with this risk; another might be
to ensure personal items or other equipment not necessary for the task are left in a safe place
before working at height.
Scaffold or staging is a temporary platform used to support a work crew and materials to aid in the
construction, Scaffolding is used for multi-purpose such maintenance of plant and construction
Page 22 of 32
sites. There is a range of scaffolding erection and dismantling activities are carried out at TPG. An
estimated over 2 million workers, or 60 percent of the industry especially the construction industry,
work on scaffolds. Protecting these workers from scaffold-related accidents may prevent some of
the 4,000 injuries and over 50 deaths every year (Bureau of Labour Statistics (BLS), 2001 and
2005 data for the private sector), at savings for American employers of $80 million in workdays not
lost. In a recent Bureau of Labour Statistics study, 70 percent of workers injured during the work on
the scaffold. Working at heights was identified as a significant hazard therefore a comprehensive
risk assessment is detailed in section 5.1 of this report.
7.0 Vehicle movement at site.
It was observed that there are several vehicles in regular use across the Facility, these include,
backhoes for drain cleaning, cranes, man lifts, scissors lifts for aid in Maintenance operations,
trucks and forklifts for material transportation and pick-up trucks and bicycles used by personnel.
Hazards associated with this include, contact with pedestrians, contact with structures and
overhead electrical cables, contact with other vehicles, toppling of equipment with can result
injuries and damage to property, costs of repair and insurance, civil claims. Control measure in
place include Vehicle Management policy which require a Route plan for all heavy equipment,
certified equipment operators, inspection program for vehicles, site speed limit and posted signs.
To further reduce these risks it is recommended that pedestrian walkways be designated across
the facility especially in loading and delivery areas where there is constant use of the forklift trucks.
4.2 Health and Welfare Hazards

No. Hazards Hazard Effects C L RR
1 Biological Hazards 2 2 4
2 Noise Hazard Noise induced hearing loss, distractions, 3 2 6
tinnitus
3 Long hours at workstations Musculoskeletal Disorders 2 2 4
(MSDS)
4 Working with Display screen Fatigue, vision issues, posture problems 2 2 4
equipment (DSE)
5 Stress Hazard Anxiety and depression, Heart Disease, 3 3 6
Psychological disorder etc
6 Fumes and Dust Adverse health effects 3 2 6
1.0 Biological Hazards
There are not many Biological hazards however health illness potential arises from, maintenance
work done on the sewage treatment plant, poorly maintained portable toilets mobilized for contract
workers at various locations at TGU’s site and poor personal hygiene. Sewage and wastewater
can contain hazards such as bacteria which can cause shigellosis, parasites such as Roundworm
(ascariasis), and viruses like Hepatitis A, these can cause intestinal, liver, and other infections.
These are usually spread when a person ingests faecal matter even in microscopic amounts from
contact with objects, food, or drinks contaminated by the faeces, or stool, of an infected person. If
equipment, work practices, and personal protective equipment (PPE) don't protect you from
swallowing these agents, you can get sick. Necessary routine or corrective maintenance done on
contaminated parts of the sewage treatment plant can directly expose workers to all of these
Page 23 of 32
hazards. Portable toilets are not easy to be maintained at high levels of cleanliness at all times.
This due to the nature they are spread out in large area & limitation on water storage. Mitigation
measures are by providing pre-determined schedule to clean it more frequently & systems in place
to arrange for sewage removal and when required or as per scheduled. Other main mitigation is by
practicing good hygiene e.g. washing hand after visiting toilets, before handling food or before
taking lunch breaks & end of shift.
2.0 Noise
Noise hazards in operating plant are of a continuous magnitude rather that intermittent or
impulsive, the source is from equipment such turbine compressor, generator and auxiliary
equipment such as motors to power cooling fans. Noise is considered significant hazard since
recent occupational noise study showed the noise levels across the facility to range from 73 (dB) to
98 (dB) decibels. Unprotected exposure to noise levels above 85 decibels can cause noise-
induced hearing loss, it can affect workers by damaging damage the hair cells and nerve endings
in the cochlea. Workers mostly affected would be Operations and Maintenance staff, who are
around the equipment for between 6 to 9 hours daily. One of the most common types of hearing
loss is called tinnitus. Damage to the cochlea or any part of the inner ear often leads permanent
hearing loss is more significant. Noise also can cause other effects such as speech interference,
lack of concentration, and annoyance, which can cause distractions and result into accidents. The
existing noise level is a residue after engineering control measure already incorporated in the
equipment design hence nothing much can be done to mitigate other than administration & PPE
controls. TGU’s hearing conservation plan includes existing controls such as permanent signage
posted on level of noise & mandatory PPE requirements. A variety of hearing protection is
available and easily accessible prior to entering areas where hearing protection is required. Some
area requires ear plugs while other areas require ear muffs and in the area where dB is more than
95, double hearing protection is required. Workers are trained annually in the use of hearing
protection, and managing exposure time. Training also includes information on noise hazards,
effects of hearing loss and potentials on continuous or prolong exposure without adequate hearing
protections. As part of the pre-employment medical assessment an Audiometric test is conducted
to ensure there no existing conditions and to obtain baseline hearing results, annual tests are
conducted and managed by the Occupational Physician to ensure no adverse effects are
occurring.
3.0 Musculoskeletal Disorders (MSDs):
Work is carried out at a workstation in every industry especially in TGU’s where there is a
significant administration and support staff such as the finance, human resource, communications,
health & safety, technology support and planning departments. This makes musculoskeletal
disorders a considerable risk because of poor workstation, poor job and layout as well as design.
The employer must assess workstation before employee start using it must ensure that employees
are trained in how to use it. There are a variety of conditions such as physical conditions which
affect muscles, joints, and limbs the name given to this condition is musculoskeletal disorders, also
referred to as work-related upper limb disorders, repetitive strain injury, and upper limb disorders.
Health issue associated with these are tendonitis and tennis elbow, carpal tunnel syndrome, cramp
which include symptoms such as pins and needles, loss of grip strength stiffness, numbness,
aching or pain and weakness of muscle. There are a number of reasons that cause
Musculoskeletal disorders especially when sitting at a workstation such as repetitive movement,
pressure or blow to the body, forceful movements such as gripping and twisting, vibrations. Use of
a pointing device, trackball, or mouse may cause health issues if the activity is based on one arm,
hand and a finger. Exposure time should be reduced, repetitiveness and speed with the use of the
mouse. The mouse can be used close to the body so that the employee's arm is not stretched too
far and also rest your arm or wrist on the desk. Upon reviewing heath and insurance claims it was
noted that there were some related to musculoskeletal disorders. Through visits to the office areas,
review of the Ergonomics policy and questioning employees if was realized that TGU has
comprehensive guidance on best ergonomic practices and properly designed and adjustable
Page 24 of 32
workstations however these weren’t fully understood by employees. If these conditions are ignored
they can develop into serious injuries which can result in significant insurance claims, increased
use of extended sick leave which may require the hiring of additional persons to take up the
workload thereby increasing administrative costs. In order to reduce these risks it is essential that
affected staff understand the prevention strategies. This is achieved by training of the use of
existing engineering controls such as adjustable workstations and proper work positions, education
on best practices in ergonomics and its benefits well has how to identify signs of early MSDs..Early
detection of most Muscular- skeletal disorders (MSD) type conditions can be simply prevented by
changing work patterns and behaviour. A system for monitoring MSDs through worker claims,
feedback and complaints should be set up together with ongoing monitoring of existing cases.
4.0 Display Screen Equipment (DSE):
It was noted that the operations group as well as the administrations staff used DSE for 8 out of 12
hours daily. Display screen equipment or visual display units have some acute or chronic health
effects such as diseases or permanent damage to the eyes. It was observed that employees of
TGU’s work for 12 hours shift requiring them to used visual display units to control, monitor and
investigate issues occurring on the generation plant. Discomfort and tired eyes caused by screen
glare or reading the laptop or computer screen from long periods without sufficient breaks or
combination of these can lead to such health issues. These signs and symptoms can include
(photophobia) means blurred or double vision and sensitivity to light as well as soreness of the
eyes, headaches, blurred vision. If eyes are continuously concentrating on a task for a long period
of time it might make you aware of an eyesight problem which you had not noticed before. Through
interviews with the operations staff it was noted that they were no complaints of posture, visual or
fatigue issues, this is due to the systems TGU has put in place to reduce negative effects of
working with DSE. Users were aware of proper hand positions, correct adjustment for seating and
screens, additional supports such as document holders, footrests and blinds for blocking glare.
Work planned to include regular breaks or change of activity, lighting and temperature and noise
are also suitably controlled. DSE training and assessments of workstation carried out by all
employee early on in induction. Eye tests provided for those who need them, TGU to pay for basic
spectacles specific for VDU use (or portion of cost in other cases). These practices should be
continued and assessed regularly. Failure to do continuous monitoring and evaluations can lead to
issues arising and not being addressed resulting in increased medical claims, demotivate staff and
increased days away from work.
5.0 Workplace Stress:

The Health and Safety Executive in the UK defines Work- related stress as the adverse reaction
that people have to excessive pressure or other demands placed on them at work. Though not a
disease, chronic stress can cause ill health and may act as a trigger for mental health problems
such as anxiety and depression. According to the European Agency for Safety and Health at Work,
stress is the second most reported work-related ill-health complaint, affecting almost a quarter of
worker in the 27 EU member states. Stress causes a range of physical and behavioural symptoms
in the short-term which can become serious ill-health conditions such as anxiety and depression,
high blood pressure and heart disease.
The causes of work related stress can be characterised as:
 Organisational factors, such as unreasonable pace of work, inadequate managerial support
or demanding work schedules.
 Personal relationships issues which include bullying/harassment and feelings of isolation
 Physical factors in the workplace such as lighting, noise, and temperature.
Physical effects of stress can present as raised heart rates, blurred vision, skin rashes etc. Stress
can also cause psychological and behavioural changes such as, increased alcohol consumption
and smoking, difficulty sleeping, inability to cope with everyday tasks and situations. These may all
be short term effects of an isolated or finite period of excessive stress and may resolve with
minimal treatment. If excessive pressure remains chronic symptoms and disease such as
Page 25 of 32
hypertension, heart disease, susceptibility to ulcers and loss of libido can occur. This was identified
as a significant hazard therefore a comprehensive risk assessment is detailed in section 5.2 of this
report.
6.0 Fumes and Dust-:
Welding is a hazardous activity that poses a unique combination of both safety and health risks to
more than 500,000 workers in a wide variety of industries. According to the Occupational Safety
and Health Administration (OSHA), the risk from fatal injuries alone is more than four deaths per
thousand workers over a working life time. Protecting the workers when performing welding
operations depends on understanding of the hazards involved and the proper way to control
them. Control of welding hazards includes avoiding eye injury, respiratory protection, and
ventilation of the work area, protective clothing, and having safe equipment to use. Hot
environmental conditions include air temperature, radiant heat, humidity and air movement.
Welding operation is known to produce heat, the exposure to which in combination with the
internal body heat due to physical activity and clothing requirements may lead to some health
disorders or even heat-related illnesses. Following are the health hazard associated with welding
work;
Increased heart rate
Increased body temperature
Urinating less frequently than normal
Small volume of dark-coloured urine
Irritability
Welding are treated as high risk work and it requires Permit to Work for authorization, a Hot Work
permit to make sure the area is safe and a Job Safety analysis(JSA) to identify and control health
hazards associated with the activities. Procedures for accessing welding position, location and
duration of exposure are in place. Welding in a large workshop, or outdoors, prevents build-up of
fume and gases. However, in a small workshop, fume will not be readily dispersed and the welder
may be subjected to a higher than average exposure. Working in confined spaces, in particular,
requires an efficient, monitored, ventilation system so exposure is controlled and there is no
depletion of oxygen in the working atmosphere, these are all addressed through the JSA and
Confined Space Entry Permitting system.
No Recommendations Priority
1 Access control to the workshop are be implemented and a system to
control use of the powered tools be put in place e.g. permit with job
safety analysis.
2 JSA should be audited periodically by the existing Advanced Safety
Audits (ASA) programs which will identify deficiencies and allow for
corrective actions to be implemented and followed to closure.
3 Proper inspections by competent person should be carried out in

workshop and adjacent working areas to check the condition of machines
and note the damage control and measures to be taken.
Page 26 of 32
4 It is recommended that risk of falling materials causing injury should be
minimized by keeping workplaces at height clear of loose materials and
stacking or storing materials well back from edges.
5 High visibility netting should be placed while working at height so as to

minimize the risk of falling objects and injuring anyone or damage to
property
6 Emergency and Preparedness response plan should be updated as per

the changes in the design of workplace or machinery. Dedicated
personnel should be named for response lead in case of fire, explosion
or any other accident related to workplace.
7 It is recommended that all toilet areas should be cleaned periodically and

recorded to maintain proper schedule. Systems should be placed to
arrange for sewage removal and when required or as per scheduled.
8 Awareness of practicing good hygiene to workers e.g. washing hand

after visiting toilets, before handling food or before taking lunch breaks &
end of shift.
9 JSA and Confined Space Entry Permitting system should be placed in

welding area, and confined spaces where there is more chance of fumes
accumulation. Also ventilation system is installed in the workshop area
so exposure is controlled and there is no depletion of oxygen in the
working atmosphere,
5.0 Risk Assessment
5.1 Physical Hazard – Working at Heights
5.2 Health & Welfare Hazard – Workplace Stress
Stress is a major cause of sickness absence in the workplace and costs over £5 billion a year in
Great Britain. It affects individuals, their families and colleagues by impacting on their health but it
also impacts on employers with costs relating to sickness absence, replacement staff, lost
production and increased accidents (HSE-Tacking work-related stress using the management
standards approach).
The UK Health and Safety Executive have developed an approach to stress based on
management standards to be achieved by organizations under the headings of: demands, control,
support, relationships, role and change.
A Stress Risk Assessment involves the same basic principles and processes as for other
occupational risks. The stepwise approach which was used to assess stress levels at TGU
Page 27 of 32
includes five steps: 1) Identify the hazards, 2) decide who might be harmed and how – focusing on
the six stress management standards, 3)Determine existing controls, 4) Determine Further control
required, assign responsibility, 5)Monitor and review
Hazards were identified by reviewing the following;
 trends in records of sick leave (e.g. headaches, recurrent colds or flu and musculoskeletal
disorders)
 cases of annual or long service leave (or non-usage) as a result of psychological risk
factors or work-related stress (e.g. using annual leave as sick leave is depleted or not using
annual leave due to work pressure)
 cases of worker’s compensation or psychological injuries (e.g. work-related stress, post-
traumatic stress disorder, anxiety and depression),
 trends or common themes in complaints or workplace grievances,
 trends in the Employee Assistance Program (EAP) usage and types of issues managed,
 related and unresolved issues in minutes of meetings (e.g. workload or change in work
roles),
 work schedules records that reflect on work, overtime usage or other relevant information
 lack of knowledge and compliance of the organisations policies and procedures related to
psychological risk factors (e.g. harassment, bullying or discrimination),
 observing if there were any work areas that were understaffed,
 any areas experiencing a high number of sick days compared to others,
 work areas where employees handle conflict destructively (e.g. using blame language or
personal criticism- gleaned from interview and employee surveys.
 Employee stress assessment survey
Analysis of data to determine who might be harmed and how is given in the Risk Assessment table
below. An assessment of TGUs current control measures for addressing workplace stress has
been analysed for adequacy and recommendation for improvements given where applicable, this
can also be seen in the risk assessment table below (TPG Workplace Stress Risk Assessment)
Page 28 of 32
TPG Workplace Stress Risk Assessment
What are the hazards Who might be harmed and how Controls already in Further action to be Responsible Prio
place taken person rity
Job demands 80% of Maintenance workers, 1) Fatigue Risk 1) Training on Fatigue 1) HSE Team P1
This risk factor relates to the inclusive of Mechanical, Electrical Management Policy Risk Management Policy Lead
various demands placed on and civil technicians and trainees to assist with fatigue for operations
employees in their roles. Data 60% of Operators and operators management. 2) Expand FRMS policy to
analyzed highlighted : in training, and 50% of 2. Four shifts on include Maintenance staff 2) HSE Team P1
an inability to combine work Administrative staff identified with rotation for needs Lead
based on demands from issues relating to job demand. Operations staff 3) Review structure and
different groups; unachievable These issues can lead to these determine human
deadlines and difficulties in employees taking short cuts and resource needs to cater 3) Chief P3
managing work based on load; bypassing the safe work permit for realistic workload Operating
issues with having to neglect system, being fatigued while Officer
tasks because of work load; doing safety critical tasks,
having to work extra-long hours external stress from not long
in order to complete tasks; hours and not being able to fulfil
inability to take sufficient breaks family commitments can lead to
demotivation.
Control- This risk factor is Generally the Maintenance and 1) Performance 1) Retraining for 1) Human P3
related to control over and Administration departments Charters per supervisors on resources
involvement in decisions that indicated that their deliverables individual performance charter Manager
could be reasonably expected are instructed without development and need to
in a job or role. consideration for other ongoing consult individuals.
Data analysed indicated that tasks, scheduled leave, ability
employees did not have and preferences.
significant input into type of
tasks, deadlines, time, breaks.
Support- this includes the The entire maintenance 1. Incentive 1) Enhancement of review 1) Human P3
encouragement, sponsorship department and 40% of the programs process to ensure more resources
and resources provided by your Administration department 2. Recognition transparency and Manager
manager and your identified a lack of support and programs implementation of more 2) Maintenance P1
colleagues. trust regarding their immediate 3. Spot awards frequent reviews. and
Page 29 of 32
Data analysed indicated that supervisor. This tense 4. Quarterly and Administration
The ability to address work relationship creates and Annual reviews 2) Supervisory training to team leaders
concerns or to obtain support environment where employees 5. Adequate budget, improve work
from line management was a will not consult supervisors on tools and equipment relationships.
deficiency within the work related problems,
maintenance and administration employees may not feel
departments comfortable to highlight safety
concerns or deficiencies and
might proceed to perform unsafe
work due to fear which can lead
to major incident, injuries and
even loss of life.
Relationships – promoting 65% of the Operations staff 1. Grievance Policy 1. Retraining on conflict 1)Plant Manager P3
positive working to avoid conflict inclusive of trainees and 90% of 2. Suggestion Box resolution in conjunction
and dealing with unacceptable Maintenance staff confirmed 3. Incident Reporting 2. Peer group social with Human
behavior. being harassed or bullied at least Policy events resources
Data analysed indicated: once, with 50% of combined 3. Harassment/ Bullying 2) Corporate P3
A high level of Harassment and Maintenance and Operations staff Policy to be developed Communication
bullying and strained being bullied more than once. officer in P1
relationships within work 100% of Maintenance, conjunction with
environment. Operations, and Administrative supervisors
departments indicated having 3) Human
strained relationships. Poor work resources
relationships can lead to anxiety manager
and depression which then leads
to demotivation as well as health
issues resulting in increased
absenteeism and presentism.
This can also result into physical
and social isolation and physical
confrontations and poor decision
making.
Page 30 of 32
Role – ensuring that your role is 90% of total employee survey 1. Job Descriptions 1) Interdepartmental 1) Plant P3
clear and that you do not have indicated that they were not 2. Performance training and information Manager
conflicting roles. aware of the significance of at Charters sessions or
Data analysis showed that while least one other department. This 3. Clearly defined communications
persons knew their individual can lead to disrespect, bullying, policies and
tasks and how they fit into the confrontations, harassing and procedures
organization, they were not feelings of isolation and
aware of how other contribute depression
or their value in the organisation
Change – how organisational 75% of employees indicated that 1. Management of 1)Implement fixed monthly 1)Executive to P1
change is managed and there was inadequate Change procedure meetings at each level initiate and
communicated. communication within the 2. Suggestion Boxes (Executives to Team enforce within
organisation to discuss changes 3. Grievance Policy Leads; Team Leads to respective
at work and associated impacts 4. Departmental and Engineers & Lead departments.
regarding new roles and Plant Meetings Operators; Engineers and CEO (Chief
responsibilities, organizational Lead Operators to Executive
changes and how it would directly Technicians) to ensure Officer)
affect them. This can lead to information is adequately CFO (Chief
employees being distracted by transferred to all levels of Financial
issues not being addressed such the organization. Officer)
as salary increases etc which PM (Plant
results in a decreased focus on Manager)
job related and safety critical CSM (Corporate
tasks. Services
Manager)
* Priorities Justification
P1 - High priority . The action requires to be taken within 1 month

P2 – Medium priority. The action needs to be taken within 3 months
P3 – Low priority. The action needs to be taken within 6 months to 1 year
Monitor and review

All further actions should be included in TGU’s Action Item Register to follow through to closure. Another risk assessment should also be scheduled
within assess if improvements have been made based on implemented solutions. A system should also be put in place
Page 31 of 32
6.0 Conclusions
TPG’s Health and Safety Management System was critically assessed against OHSAS 18001
Standards and a detailed gap analysis showed that while there is robust system in place, which
closely follows the 18001 standard there were areas for improvement in order to be fully compliant.
Through site assessments, interviews and surveys a risk profile of the hazards which employees
are exposed to was developed. The most significant Physical hazard and Health and Welfare
hazards were identified and a detailed risk assessment developed with recommendations for
mitigating risks suggested. Below is a brief summary of these activities.
The organization has developed an adequate H&S Policy, various procedures such as System
Procedures, General Procedures & Occupational Control Procedures, and competence and
training needs are assessed, all of this done in consultation with employee representatives. There
is a process for developing Method Statements & Risk assessments for all the tasks being
executed. TPG also measures its’ H&S performance by both proactive and reactive measures
using several methods. Internal / External Audits and management review are being carried out at
periodic intervals. Though the assessment was found to be satisfactory there improvements which
can be made using in-house resources or for little cost and time. The following is a brief summary
of the gaps identified;
1) While a risk assessment process exists there is no means for identification of

Workplace Stress Risks.
2) TPG has training needs assessment program however critical special needs training
have been overlooked for working at heights as a result employees were found involved
in this high risk activity without suitable and sufficient training.
3) It has been found that some activities are being carried out, which are not properly
assessed and identified in the risk assessments . This requires immediate attention for
correction.
4) The reporting culture on Near-Miss, Incidents, dangerous occurrence, property
damages does not extend to contractors and subcontractors who are a significant part
of TPG’s labour force.
5) Incident investigation team not adequately trained in rootcause analysis techniques
therefore some investigations do not identify underlying and root causes and
recommendations put in place are not sufficient and does not prevent reoccurrence.
6) Some of the identified emergency response procedures are not tested periodically
7) Close out of action items arising out of incident investigations and audits are not
sufficiently tracked to closure in a timely manner.
Through site surveys, documentation reviews, discussions and interviews with staff a wide range of
significant hazards were identified, both physical and those associated with health and welfare. It
was found that trough TPG’s hazard identification and risk assessment programs most of these
hazards were know and some level of controls already put in place. The hazards observed
include… The most significant
Page 32 of 32

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Unit ID Assignment NEBOSH Student Number: 00061559

2.3 Description of Organisation

It is a medium sized organization employing approximately 100 persons consisting of permanent

2.4 Legal Environment

3.0 Review of the Health and Safety Management System

 Plan: establish the objectives and processes necessary to deliver results in

4.4 Implementation and Operation (Do)

4.4.3 Communication, Participation and consultation

4.5.3 Incident investigation, nonconformity, corrective action and preventive action

4.6 Management Review; (Act)

3.2 Safety and Health Management System - Gap Analysis

The policy is appropriate to the nature and

Framework for setting and reviewing QH&S

E-copy posted on intranet and hard copies

The Policy is communicated to all levels

Policy have been reviewed and updated

4.3. Planning An annual faclilty risk assessment is Risk to works conducted at

TPG Job Safety Analysis Procedure identifies

 TT OSH Act (local)

A register of relevant Occupational, Health

Database for monitoring HSE related Metrics

Clause4.3.3 of OHSAS 18001:2007

The management has set a high-level

The H&S Programme(s) are reviewed at

4.4 The management has drafted an Compliance with

Adequate resource in terms of finance

And any personnel who experience a change

4.4.2 Competence, The organization has established a The training needs

 H&S awareness and understanding

In addition employees are trained on,

Training matrix developed and communicated

4.4.3 Through TPG’ communication policy it has Compliance with

Records of all current and valid documents

Management Representative (H&S)

4.4.6 Operational The organization has established operational Compliance with

Management of Change procedure in place .

The procedures for communicating the

4.4.7 Emergency Emergency Preparedness Plan developed to No periodic testing of

TPG reviews and revises its emergency

TPG regularly participates in emergency

TPG have identified nine type of emergency

 Fire and Major accidents on site

The results are analyzed to determine the

The records of repetitive violation are

4.5.3 Incident TPG has established an Incident Individuals conducting

Action items recorded in Action Item Register

4.5.3.2 Non- The organization has established a Reviewing the

The procedures also covers the record

Actions are recorded in the Action Item

4.5.4 Control of Through TPG’s Planning and Document Compliance with

Records are maintained to demonstrate

reporting results and retaining associated

the determination of audit criteria, scope,

Audits are done by different levels of the

4.6 management Management Review meeting held quarterly Compliance with

 status of incident investigations,

4.0 Significant Hazards

3 x 3 Risk Assessment Matrix

4.1 Physical Hazards

2 Working with powered equipment and Electrical shock, cuts, amputation, 3 2 6

1.0 Substandard surface/flooring conditions

Laws & Regulations:

1.0 Working with powered equipment