Chapter 2: Work Planning and Procedures
Effective Date: July 1, 1997 (Issue No. 2)
Last Updated: December, 2014
SECTION ONE - WORK PLANNING
Many operations at HKUST may involve the use of dangerous equipment, hazardous materials, and/or dangerous work procedures. Some of the activities involve outdoor or occupational and environmental fieldwork may associate with unique hazards. Careful operational planning and appropriate hazard analysis and implementation of control procedures are needed to help prevent accidents. This section describes the process for effective planning, how a safety evaluation is conducted, what must be done while the activity is in progress, and documentation that may be required.
Planning and conducting work activities (e.g. experiment, operation, job, project) so that they can be accomplished successfully - both technically and safely - is every employee’s responsibility. Management is responsible for assuring that proper training and planning have been conducted and that necessary documentation is complete. HSEO is responsible for providing the necessary guidance and technical support from a health and safety perspective.
Hardware, methods, and personnel requirements are all components of the work process and are established during the planning and organizational phases. Management’s safety evaluation should be integrated into planning and start-up, and the information obtained while monitoring the activity can be used to assess the effectiveness of the planning and to modify the hardware, methods, and personnel to improve it as needed.
Planning is an orderly process of thinking about an activity so that it can be completed efficiently and successfully. As the planner begins to visualize the hardware, methods, and personnel required, he/ she should also begin to identify the hazards that may be associated with the activity and, consequently, the controls that should be applied. A safety evaluation is then made to determine if the controls applied to the activity will fulfill the objectives of the safety policy.
D. Risk Assessment
A safety evaluation or risk assessment consists of identifying hazardous situations associated with a particular activity, and then evaluating the risks they present. (Appendix 2A summarizes this process.) A safety evaluation is performed at the time an activity is planned, before it starts, as well as while it is in progress. The amount of time given to planning and evaluation is determined by the complexity of the activity and the types of hazards involved. It may require a short mental review of the activity or a more formal analysis.
- 1. Identifying Hazards
- Visualize the materials and equipment to be used, how personnel will actually perform the operations, and anticipate any changes that are likely to occur. Identify the energy sources that will be involved, using Appendix 2A as a checklist. Then review the applicable prescribed codes, standards, and regulations to determine the controls that must be included when planning the operation. Although the level of safety of an activity will usually be acceptable after the mandatory controls have been implemented, some danger or risk may remain. Because many of our research activities are experimental in nature, there may not be established codes, standards, or regulations that prescribe adequate controls, and therefore careful consideration must be given to devising appropriate controls.
- 2. Evaluating the Risk
- Risk is defined as having two components: (1) the severity of a particular accident, and (2) the expectation that accident may happen. The severity component considers all the consequences that could result from the accident, such as injuries, illness, equipment damage, program losses, employee morale problems, environmental damage, legal problems, and adverse public reaction. It can be expressed numerically (in terms of a dollar amount) or qualitatively (e.g. low, moderate, or high).
The expectation of occurrence - usually based on past experience (accident frequencies) - can also be expressed numerically (in terms of probability) or qualitatively. A hazard for which there is a moderately or highly severe consequence with a moderate or high expectation is an accident-prone situation and must be controlled. This type of approach is shown in the table below:
Additional Controls Needed
Yes or No
- Whether a risk is acceptable or not may be considered a subjective evaluation and in such cases a discussion with HSEO is recommended. The examples shown here are meant simply to give a sense for how these decisions should be made.
- A simple practical example may illustrate this concept of evaluating risk. Using a defective wooden 2 x 4 as a decorative moulding would have an acceptable risk (the severity of a possible accident is low). Using the same piece of wood in a ladder would have an unacceptable risk (the severity of a possible accident is high; the expectation that it would happen is moderate or high).
Once a risk is evaluated as being unacceptable, it must not be tolerated. The hazard producing the unacceptable risk must be either terminated (eliminated from the activity), transferred (sent to a facility where controls are adequate), or treated (controlled by application of additional controls or barriers). Consult HSEO for information and assistance.
- 1. Physical Barriers and Behavioral Controls
- Effectively controlling a hazard depends on placing barriers between the hazard (e.g. an energy source) and the target (e.g. the people or things that are in the energy pathway). The best barriers are usually physical entities (containment, interlocks, fences, shielding, barricades, etc.). However, physical barriers also require the use of behavioral controls (signs, checklists, operating procedures, safety procedures, quantity limits, training, etc.). For maximum reliability, a control system usually includes both physical barriers and behavioral controls (e.g. a fence with a sign explaining the hazard). Behavioral controls are strongly influenced by human factors such as fatigue, stress, distraction, forgetfulness, population variability, literacy, etc. Also, the safety control function must be capable of withstanding the accident conditions it might be subjected to. These factors ultimately determine the actual effectiveness of any particular barrier selected (see Appendix 2A, Item 6). Additional factors to be considered when making this decision are barrier cost and duration of the activity.
- 2. Engineering Control, Administrative Control and Personal Protective Equipment
- Engineering Control eliminates or reduces occupational hazards in the work place through engineering measures. This is the preferred approach because engineering measures actually eliminate the hazard from the work place or reduce the hazard at the source. Examples include:
- Facility Design—Isolation of hazard, removal of hazard by local exhaust, (dilution by ventilation);
- Operational Design—Substitute hazardous materials, change process to reduce exposure;
- Equipment Design—Enclosure of hazard, interlock to prevent accidental exposure.
- Administrative Control reduces worker’s exposure to occupational hazards by administrative means. This approach does not reduce the hazard itself, but the worker’s exposure to it through safety procedures and other administrative means. Examples include:
- Management -- housekeeping, maintenance, work schedule, operational safety procedures;
- Warning -- signs, hazard warning placards;
- Training -- operation/hazard specific training.
- Personal Protective Equipment (PPE) protects workers from hazards by special clothing or safety equipment. This is the last resort because the hazard is not reduced to a level which does not require PPE, and there is a chance of unacceptable exposure if the PPE fails. Examples are respiratory protection, eye protection, body protection, fall-arresting protection.
- A combination of these three approaches is often used to ensure occupational hazards protection.
- 3. Implementing Control Criteria
- The criteria for the controls selected must be incorporated into the hardware design and procurement and into the preparation of training instructions so that the necessary controls are functional before the activity is to begin. In addition, sufficient time must be allowed to verify that the controls and hardware have been installed correctly and that personnel have been properly trained. The responsible individual should then make a safety evaluation just before the activity begins to ensure that all is ready.
A written plan may be necessary to: (a) demonstrate that the safety controls to be implemented for an activity will reduce the risks to an acceptable level, (b) validate design or construction in accordance with applicable safety criteria, and (c) provide a standard against which the activity can be audited. This written plan may be in the form of an Operational Safety Procedure (OSP). An OSP is a management-approved document required for those activities described in Section G.
OSPs used by experimenters are limited in scope and are specific in content. An OSP must be reviewed annually and should be revised and reviewed whenever an operational change causes it to become outdated.
- 1. Activities That Require An Operational Safety Procedure
- If your proposed activity is similar to those described below, contact HSEO for assistance early in the planning stage, since an OSP is probably required:
- Operation of an experimental high-energy system (large electric current, high magnetic field, high-pressure gas or fluid, high voltage, laser systems, etc.).
- Operation of equipment capable of generating significant levels of hazardous ionizing or non-ionizing radiation.
- Any activity that involves the presence of a radioactive material in a facility not intended for the process.
- Any activity that involves the presence of an explosive in a facility not intended for the process.
- Any activity that involves the use of a carcinogen, suspect carcinogen, or etiological agent (pathogen) in a facility not intended for the process.
- Any activity where implementation of the controls specified by a prescribed code or standard is not sufficient to reduce the risk to an acceptable level.
- Any activity that is not in compliance with a mandatory code or standard or an existing safety policy.
- Whenever required by management or by the HSEO.
- 2. Preparing the Operational Safety Procedure
- The person who is responsible for a proposed activity is also responsible for preparing the OSP. The essence of preparing an OSP is to ensure proper planning and execution of an activity free of unacceptable risks. The preparer should be satisfied that all hazards have been identified and adequate controls selected. OSP reviewers/approvers, and management, must also be convinced that the OSP is adequate.
- OSPs are prepared in a format most appropriate to the nature of the operation; however, every OSP must include:
- A description of the anticipated activity and its hazards and risks.
- The name of the individual responsible for ensuring compliance with the OSP.
- Instructions to be followed to implement the controls that will reduce the risks to an acceptable level.
- Information concerning any special conditions that may be present.
- Emergency response procedures.
- A sample OSP form can be used either for the preparation of an OSP or as an outline. Appendix 2B provides additional details and serves as a guide when preparing an OSP.
- 3. Review and Approval
- Each OSP, prepared by the responsible individual, must be reviewed by the Department Head (or his/her designate) and approved by HSEO. Each reviewer indicates approval/agreement with the OSP by signing the signature page of the completed OSP. Each person who approves the OSP must be satisfied with the adequacy of the hazards analysis and controls described in the OSP, and that the residual risk of the activity is acceptable to HKUST after the specified controls are implemented.
- 4. Dissemination
- The best planned, written, and reviewed OSP is of little value if those who are to use it are unaware of its contents. Before an operation begins, the responsible individual must verify that each participant has read and understood the OSP. Safety Procedures are effective controls only if they are understood and used. The controls specified in an OSP are applicable to all personnel in the area described who should also be required to sign-off on the OSP.
As discussed in other sections of this Chapter, management is to make periodic safety evaluations of the work activity. If monitoring is not performed, management cannot ensure that the responsible individual has implemented the controls required by the OSP.
Information obtained by monitoring the work in progress provides the responsible individual with an opportunity to make a continuing safety evaluation (e.g. Are employees following the procedures? Is the equipment being maintained? Are the controls effective/adequate? Are there any indications that an accident is likely to happen?)
The responsible individual must continually watch for changes in the activity that may introduce a new hazard or increase the risk. This information should then be evaluated, and appropriate adjustments made to the hardware, methods, or personnel so as to reduce the risk to an acceptable level.
SECTION TWO - ACCIDENT INVESTIGATION
Reporting and investigation of accidents and near-miss incidents are vital parts of an accident prevention programme. Accident investigation can provide accurate and timely information, which can be used to prevent future accidents.
B. Legal Requirements
The legal requirements on reporting accidents and incidents (dangerous occurrences) to the Labour Department are stipulated in the Occupational Safety and Health Ordinance (OSHO) and Employees' Compensation Ordinance (ECO).
Accident investigation shall be initiated by the Head of Department, his/her designate, or the unit manager at the site of an accident. Depending on the nature of the accident and the circumstances, a task group may be appointed by the University to conduct the investigation. The task group membership should include members of management, members of HSEO and, if appropriate, members from other departments.
The Director of HSEO or his delegates shall provide all necessary assistance to respective departmental or unit management in conducting accident investigations.
- Disintegration of a revolving vessel, wheel, grindstone or grinding wheel
- Collapse or failure of a lifting appliance
- Explosion or fire that causes damage to the structure of any workplace and prevents the continuation of work
- Electrical short circuit or electrical failure that causes a fire or explosion, or causes structure damage
- Explosion of a pressurized vessel or container
- Total or partial collapse of structure
- Overturning of, or a collision with any object by a bulldozer, excavator, lorry etc.
- 1. Accident
- An incident that results in injury, illness, property loss, activity interruption or environmental damage.
- 2. Serious Accident
- An accident that involves the death or serious bodily injury of a person. "Serious bodily injury", as defined under the OSHO, refers to any bodily injury that results in the person's admission at a hospital or clinic for treatment or observation.
- 3. Near-miss
- An incident that could have resulted in an accident.
- 4. Dangerous Occurrence
- A specific type of incident that is required to be reported to the Labour Department under the OSHO. The following are regarded as dangerous occurrences under the OSHO:
E. Reporting of Incidents/Accidents
After an accident, the supervisor of the injured person or the unit manager of the area where the accident occurred should complete an Accident/Incident Report Form (download form) and send it to the respective Head of Department. Once endorsed by the Head of Department, the report should be sent to HSEO for appropriate follow-up actions.
For serious accidents or dangerous occurrences, Security and HSEO must be informed immediately. As required by the OSHO, these cases have to be reported to the Labour Department within 24 hours.
If the accident involves the injury of an employee of the University, the Personnel Office shall be informed of the accident as soon as possible for initiating the employee compensation procedure as required by the Employees' Compensation Ordinance.
The Finance Office shall also be informed if the accident may involve other insurance claims, e.g. for property damage, public liabilities etc.
Depending on the nature of the accident and the circumstances, HSEO may initiate an investigation of an accident. A copy of the investigation report shall be forwarded to the relevant Department Head(s) for reference and appropriate actions.
Accidents which result in, or which have the potential to inflict serious injuries may require a formal investigation. In such cases, the University shall appoint an impartial team to investigate the cause and recommend procedures for prevention of future accidents. Assistance from HSEO should be sought if necessary.
- A formal accident investigation report shall be compiled by the investigator(s). The report shall be forwarded to the Head of Department and HSEO for reference and appropriate actions.
- HSEO shall co-ordinate and follow-up on the recommended actions with the action parties.
Staff and students should be encouraged to report near-miss accidents so that potential hazards can be identified and eliminated before a more serious accident occurs.
F. Guidance on Effective Accident Investigations
Every accident should be investigated irrespective of the seriousness of the consequences. Both minor and major accidents have the same chance of occurrence.
When an accident occurs, the prime concern is for the injured person. The injured person should have immediate access to first aid and medical facilities. Unless the injured person is well enough to be questioned at the scene, he/she should not be further upset with questions. The investigation process should begin promptly once the injured is properly taken care of.
Inspect the scene for any hazards that could cause another accident. Keep everyone away from the immediate area so that the scene remains undisturbed until all the facts and any evidence are collected. Personally interview everyone involved, i.e. the injured person(s), nearby employees, and other personnel who may provide clues to the causes of the accident. Investigators must emphasize that their investigation is a fact-finding, not a fault-finding, mission, otherwise, the workers and supervisors who have the information may conceal the information to protect themselves and their fellow employees.
Where possible, the investigator should be free of the operational control of the supervisor(s) concerned, in order that he may be objective. He/she should maintain a cooperative attitude toward them (e.g. by meeting with the supervisors before and after his investigations and conferring with them) but his/her judgment must not be affected by the fact that he/she might be placing the blame on the boss.
The investigation should be thorough and attempt to identify underlying causes. The tendency to blame an accident on an employee’s “carelessness” should be avoided because the term is too vague and usually hides problems which could be corrected if identified. However, this “avoidance” should not be used as a license to overlook clear-cut cases of carelessness or negligence.
G. The Accident Investigation Report
Once the accident investigation has been completed, the investigator should assemble and record the facts in an Accident Investigation Report. The Report should be written in such a way that it is easy to understand what has occurred during the course of the accident and how it occurred.
The Accident Investigation Report should consist of the following important parts:
- The description of the accident.
- The causes of the accident including contributing factors.
- The recommended actions to prevent recurrence.
The most commonly recommended methods of preventing recurrence can be one or a combination of the following:
- Repairing the unsafe condition.
- Replacing the unsafe condition.
- Designing or engineering a new process to prevent recurrence.
- Re-designing the cause of the unsafe condition.
- Re-training the injured worker and others as indicated.
- Transferring the injured worker to a type of work that is commensurate with his/her ability to perform the work.
- Establishing a new safety procedure.
- Undertaking appropriate disciplinary actions, if deemed necessary for the prevention of similar accidents.
Priorities, due dates (if appropriate) and the action parties responsible for implementing the recommended actions should be indicated. Management must assure that recommended corrective actions are implemented in a timely fashion.
SECTION THREE - CONTRACTOR SAFETY MANAGEMENT
Activities carried out by contractors on campus may create risks for staff, students and other premises users. Whilst the contractors have the responsibility to ensure that their activities are being carried out safely, the University will make every effort to assure that the safety and health of its students, staff members and visitors are not adversely affected.
The contractors have the responsibility to ensure the safety of their workers and to ensure that their works are carried out safely. Departments at HKUST should exercise reasonable control and monitoring over their contractors to ensure that they are applying proper management and safe working practices in their works within the University premises.
Wherever it is reasonably practicable to do so, work areas should be physically separated from areas used by staff and students.
Every effort should be made to select the most suitable contractor for the job. The safety performance of the contractor must be considered as an important criterion in the selection process.
New contractors bidding on the jobs of the University shall be required to provide information on their safety management system. The information provided shall be reviewed by HSEO who shall give appropriate advice to the responsible departments in selecting contractors.
The safety record of contractors working with the University should be kept by the responsible departments and a list of contractors with acceptable safety performance shall be compiled. Only those contractors who are included in the list shall be re-invited to tender the jobs of the University. Feedback from University’s site supervising staff shall be obtained and those contractors who persistently fail to meet safety standards should be deleted from the list.
Before tendering a work project, full consideration should be given to health and safety issues that may affect premises occupants and the workers.
At an early stage in the preparation of tender and contract documents, the following information should be confirmed and agreed with the concerned user department(s) as well as HSEO and the Security Control Centre as appropriate.
- The nature and scope of the work.
- The areas within which the work can be physically contained.
- The time period within which the work will be undertaken.
- Information relevant to the safety of the contractor’s own employees and site workers while undertaking the work at HKUST (e.g. specific hazards in laboratory areas, existence of hazardous materials, etc.)
- Access and exit arrangements for the occupants and contractor's workers.
- Additional security measures.
The above information should be included as part of the contract specifications made known to contractors before they submit their tenders, as individual items may have significant cost implications.
Appropriate safety clauses and requirements, requiring the contractors to comply with applicable statutory regulations and specific safety rules of the University, should be included in the contract documents.
A copy of the Requirements on Safe Working Practices for Construction Contracts Undertaken at the Premises of The Hong Kong University of Science & Technology should also be included as part of the contract documents requiring compliance by the contractor. The document is put under this Section as Appendix 2D.
For jobs of considerable size and complexity, a pre-bid safety briefing meeting with prospective bidders is considered necessary. This pre-bid meeting offers an opportunity for the University to clearly explain the specific safety performance standards expected of the contractors in carrying out the work.
Prospective bidders should be reminded to price those safety items which are considered to have cost implications.
For works of considerable size and complexity (e.g. works that may cause significant disruption to occupants), a pre-start meeting should be held with the contractor to exchange important information and work out appropriate work arrangements and schedules. The meeting should involve appropriate member(s) representing the affected occupants. HSEO may also be involved if necessary.
The following information should be given to the contractor prior to the commencement of the works.
- Confirm and, if necessary, clarify the premises users requirements and other relevant details previously identified in the contract documents.
- Information relevant to the safety of the contractor’s own employees. This may include the presence of underground services, location of fragile roofs, location of chemical stores, etc.
- The operation of the premises fire alarm system, location of alarm buttons, evacuation procedures etc.
- Any other information as needed by the contractor.
The following information should be supplied by the contractor prior to the commencement of the works.
- Contractor’s access/exit arrangements, both in general and with specific reference to vehicles delivering the contractor’s and any subcontractor’s materials, equipment and personnel.
- The contractor’s proposals for use of scaffolding (mobile and fixed), ladders, and other access equipment; necessary barriers and overhead protection, including the time frame for their erection and dismantling.
- The contractor’s proposals for separating the work areas from other occupied areas, details of any fencing, protective fans etc., including the time frame for their construction and dismantling.
- The contractor’s proposals on handling and disposal of construction waste (including hazardous waste).
- Arrangements for storage and using hazardous or noxious materials, including time schedules for using those materials.
The contractor’s liaison officer should be requested to confirm that all relevant safety requirements have been read and understood by himself, his site supervisor and subcontractors. Any questions about the safety requirements should be resolved at the pre-start meeting, or as early as possible.
Health and safety matters should be reviewed and discussed as a standing agenda item at site meetings with the contractor. A separate site safety meeting, with participation of HSEO staff, may be considered necessary for projects of considerable size and complexity.
Periodic inspections should be conducted to ensure that the works are carried out in a safe manner. Inspections shall be conducted by the responsible staff members of the contractor. Responsible members from the contract supervising office and HSEO should also conduct safety inspections at appropriate intervals.
Unsafe situations identified must be reported promptly to the responsible persons for actions. When an extremely hazardous situation is found during an inspection, the contractor’s work should be stopped immediately until the situation has been rectified. Assistance from the Security Control Centre should be sought if required.
It should be a contractual requirement for contractors to provide accident investigation reports for all lost time accidents and dangerous occurrences to the Contract Supervising Office and HSEO, for reference and necessary actions.
Appendix 2A Safety Evaluation and Control Summary
Appendix 2B Operational Safety Procedure Preparation Guide
Appendix 2C HKUST Incident/Accident Report form
Appendix 2D Requirements on Safe Working Practices for Construction Contracts Undertaken on the Premises of HKUST