A Critique of the Proposed National Education Policy Reform
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1. Description of activity: Material (Steel sheets with sharp edges) are stored in the raw material storage area. An overhead crane is used to move the material to a rack near the shearing machine which is about 30 meters away from raw material storage. Individual sheets are lifted manually from the rack and moved to the shearing machine. Shearing (or cutting) takes place, cut pieces are removed manually (stretching is required) and kept on nearby racks. Scrap is removed manually (considerable bending is required) and moved to the scrap area Hazard identification
2. Definition of key terms OH & S Hazard Risk Hazard Identification Risk Assessment Tolerable / Acceptable Risk Safety
18. Hazards: Broad Categories Work Equipment, e.g. entrapment in machinery, equipment without ergonomics consideration. Workplace, e.g. uneven floors, poor lighting, high noise level. Materials and substances, e.g. dusts, welding fumes. Environmental, e.g. temperature extremes, both hot and cold. Working practices and procedures, e.g. poor manual handling techniques, unhygienic conditions
19. Hazards Struck by : person struck by object Struck against : person strikes against object Contact With: Contact with energy source like electrical, hydraulic, thermal, pneumatic Caught between : pinched, crushed between objects Caught on : person or his clothing gets caught on an object Awkward Posture: exertion due to stressful / awkward posture Caught in : person caught in opening Fall to Same level: Fall to same level by slipping or tripping Fall Below: Fall to level below EX: Exposure to gases, dust, mist, UV, IR, Noise etc Excessive force, exposure to stressors from excessive force Excessive repetitions, exposure to stressors by excessive frequency
20. Hierarchy of controls Elimination – Modify a design to eliminate the hazard (Mechanized instead of manual packaging) Substitution – Substitute a less hazardous material or reduce the system energy (Lower the force, pressure, temperature, current) Engineering Controls – Ventilation systems, machine guarding, interlocks, sound enclosures Signages, warnings and / or administrative controls – Alarms, safety procedures, equipment inspections, access controls PPE – Safety glasses, hearing protection, face shields, safety harnesses and lanyards, respirators and gloves Determining need for controls
21. Description of activity: Material (Steel sheets with sharp edges) are stored in the raw material storage area. An overhead crane is used to move the material to a rack near the shearing machine which is about 30 meters away from raw material storage. Individual sheets are lifted manually from the rack and moved to the shearing machine. Shearing (or cutting) takes place, cut pieces are removed manually (stretching is required) and kept on nearby racks. Scrap is removed manually (considerable bending is required) and moved to the scrap area Hazard identification
22. OH & SMS and OHSAS 18001 Planning – Legal and other requirements Identification and access to legal and other OH & S requirements Applicable requirements to be reckoned while establishing, implementing and maintaining OHSMS Up to date Communication Persons Other relevant interested parties
23. Safety related legislation in India Factories Act and MFR Gas Cylinder Rules SMPV Rules The Electricity Act and IER Petroleum Act and Rules IBR MSIHC PLI
24. OH & SMS and OHSAS 18001 Planning – Objectives and Programmes Documented objectives at relevant levels and functions Measurable where practicable Consistent with OH & S policy Consideration to Legal and other requirements OH & S risks Technological options Financial, Operational and business requirements Views of relevant interested parties
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26. OH & SMS and OHSAS 18001 OH & S Objectives and Programmes OH&SMPs for achieving objectives Responsibility and authority Means and time frame Review at regular and planned intervals and adjust to ensure objectives are achieved
38. OH & SMS and OHSAS 18001 Implementation and Operation – Competence, Training, and awareness Competency of personnel Appropriate education, training and /or experience Records Training Needs identification, fulfillment, evaluation of effectiveness, records Awareness related to OH&S consequences and benefits Roles and responsibilities Potential consequences Training procedures – responsibility, ability, language skills, literacy and risk
49. Consultation with relevant external interested parties OH & SMS and OHSAS 18001
50. Implementation and Operation –Documentation OH&S Policy and objectives Description and scope of OHSMS Description of main elements, interaction, reference to related documents Documents , including records required by OHSAS Documents, including records necessary to ensure effective planning, operation and control of process related to OH&S risk management OH & SMS and OHSAS 18001
51. OH & SMS and OHSAS 18001 Implementation and Operation – Control of Documents Controlled Control of records Approve for adequacy before issue Review, update and re-approve Identification of changes and current revision status Availability of relevant versions at use points Legible and readily identifiable Identification of documents of external origin and control distribution Unintended use of obsolete documents and identification
52. Implementation and Operation – Operational Control Identification of operations and activities associated with identified risks where controls are necessary to manage risks (including management of change) For these operations and activities Operational controls, integration of operational controls in OH&SMS Controls related to purchased goods, equipment and services Controls related to contractors and visitors Where absence could lead to deviations for OH&S policy and objectives Documented procedures to cover situations Stipulate operating criteria OH & SMS and OHSAS 18001
53. Implementation and Operation – Emergency Preparedness and Response Identify and respond to potential emergency situations Respond to actual emergency situations and prevent/mitigate adverse OH&S consequences Reckon needs of relevant interested parties like emergency services, neighbours Testing, involving relevant interested parties Review and revision OH & SMS and OHSAS 18001
54. Checking – Performance Measurement and Monitoring M & M OH & S performance Qualitative and quantitative Objectives Effectiveness of controls Proactive measures Reactive measures Record data and results Calibration and maintenance of equipment Calibration records OH & SMS and OHSAS 18001
55. Checking – Evaluation of Compliance Periodic Evaluation of compliance with applicable Legal and Other Requirements Record results OH & SMS and OHSAS 18001
75. Control of Records Identification, storage, protection, retrieval, retention and disposal of records Legible, identifiable, traceable OH & SMS and OHSAS 18001
91. Results of internal audit, evaluation of compliance , participation and consultation, relevant communication from interested parties, OH&S performance of organization, objectives , incident investigation and CAPA, follow up from previous MRMs, changing circumstances and recommendation for improvement
