Safety Audit Guidelines
1 The Pollution Control Department (PCD) of the National Environment Agency licenses the import, sale, storage, transportation and use of hazardous chemicals. These chemicals are listed and controlled under the Environmental Protection and Management Act and its Regulations.
2 Besides having stringent regulatory controls, it is equally imperative that companies have adequate and effective systems in place to ensure safe management of hazardous chemicals.
3 The Safety Audit Scheme is, therefore, to spur companies to systematically identify and rectify weaknesses in their management systems and practices of handling hazardous chemicals once every two years.
4 Companies under the Scheme can either conduct their own safety audit studies in-house or engage accredited consultants to do so on their behalf. Companies that are going to be conducting safety audits for the first time are advised to engage an NEA accredited consultant.
5 Companies shall seek prior approval from PCD should they decide to use an in-house audit team. When appointing the in-house audit team, the companies shall ensure that :
- the team leader should not feel inhibited from disclosing strengths and weaknesses and in the management of hazardous substances and in recommending necessary actions,
- the team and team leader's skills and experience are appropriate,
- top management submits a letter to PCD stating that it has confidence in the skills and experience of the team and team leader and that it will act on their recommendations (where practicable).
6 To ensure compliance with the recommendations, a follow-up action plan with the date of compliance shall be included in the Safety Audit Report. Our officer will arrange with the company for an inspection upon the compliance.
7 The elements to be audited under the Scheme are in Annex 1.
8 The list of accredited consultants is in Annex 2.
9 The guideline for the safety audit report is in Annex 3.
10 A list of reference reading material is in Annex 4.[ Note for Industries under Ministry of Manpower's Safety Management System Audit Scheme and ENV's Safety Audit Scheme. ]
ELEMENT TO BE AUDITED UNDER THE SAFETY AUDIT SCHEME
The audit shall ascertain whether the installation has a written safety policy endorsed by top management in which safe management of hazardous chemicals are adequately covered.
The audit shall ascertain whether the management of the company has set up and maintained a comprehensive set of written safety information to enable all its staff to handle and store chemicals safely. The information shall cover those items normally reflected in the material safety data sheets of the chemicals, which include identification and understanding the potential hazards of chemicals, safe working procedures and emergency actions to take in case of emergency.
SAFE WORK PRACTICES
The audit shall ascertain whether safe work procedures have been established to ensure the safe handling, including transportation, loading and unloading, storage and use of hazardous chemicals by plant employees as well as contract workers. Identification of all hazardous chemicals and their hazards used in the plant, a work authorisation system and compliance of standards and regulatory requirements should be part of the safe work procedures.
MANAGEMENT OF CHANGE
The audit shall ascertain whether the installation has developed and instituted a system including use of proper written procedures to manage changes to handling of hazardous chemicals. It shall also ascertain whether the plant staff have been informed of and adequately trained to safely manage such changes.
MAINTENANCE OF FACILITIES
The audit shall ascertain whether a maintenance system to ensure that all facilities used for the handling and storage of hazardous chemicals, including storage containers, are maintained in sound and good working order at all times.
The audit shall ascertain whether training provided to staff responsible for the handling and storage of hazardous chemicals is effective and that such training adequately covers the safety information and safe work practices. The training shall ensure staff are kept up to date on changes to the types and work procedures in the handling of the hazardous chemicals.
The audit shall ascertain whether the installation has established a system to investigate every incident in the workplace involving the handling and storage of hazardous chemicals, and to promptly address the investigation's findings and to implement the recommendations.
GENERAL PLANT INSPECTION/REVIEWS
The audit shall ascertain whether regular inspections and reviews on handling and storage of hazardous substances have been conducted, and procedures for reporting potential hazardous conditions and monitoring the remedial actions established.
The audit shall check on whether the company has an established programme to carry out hazard analysis on the handling of hazardous chemicals so as to identify, assess and evaluate potential hazards, especially when new hazardous chemicals or a significant increase in the quantities of hazardous chemicals are handled. The audit shall also ascertained whether the company has an established procedure to record these hazards and develop and implement means to eliminate the hazards or reduce the hazards to an acceptable level of risk.
EMERGENCY PLANNING AND RESPONSE
The audit shall ascertain whether the on-site emergency action plan established by the installation can deal with all accidental releases and/or fires of hazardous chemicals and whether there are adequate emergency equipment stored on standby and maintained in good working order.
The audit shall also ascertain whether regular rehearsals of all or part of the emergency action plan were carried out and documented. It shall also ascertain whether the lessons learnt from these rehearsals were recorded and used during updates of the plan.
The audit shall ascertain whether contractors engaged to handle hazardous chemicals, including transportation, have been carefully selected, informed of their safety responsibilities and adequately trained to handle hazardous chemicals safely and to respond to emergency.
The audit shall ascertain if the site conforms generally to guidelines pertaining to the safe management of hazardous chemicals stated in the Semiconductor Equipment and Materials International (SEMI) international standards/specifications or Factory Mutual (FM) loss prevention engineering guidelines or equivalent (only for wafer fabrication plants)
The audit shall ascertain if the maintenance of fire alarm and protection systems and other fire safety works conform to the requirements stated in the National Fire Protection Association (NFPA) code or Uniform Fire Code (UFC) or Uniform Building Code (UBC) or any code of practice established by PSB and FSB. (for sites storing or handling flammable or combustible substances)
ACCREDITED CONSULTANCY FIRMS FOR SAFETY AUDITS
GUIDELINES ON THE SAFETY AUDIT REPORT
1.1 The report shall be structured as follows:
Chapt 1: Executive summary
Chapt 2: Introduction
Chapt 3: Overview
Chapt 4: Assessment
Chapt 5: Findings / Recommendations
Chapt 6: Certification
1.2 The report shall be bound in A4-size. 1 copy shall be submitted to PCD and 1 copy to each of the following agencies for information:
National Environment Agency
Pollution Control Department
Chemical Control Section
40 Scotts Road, #12-00
Attn: Mr Raymond Loh Wai Yuen
- Assistant Director (Plans & Audit Branch)
Singapore Civil Defence Force
Central Enforcement Department
91 Ubi Ave 4,
Ministry of Manpower
Occupational Safety and Health Division
OSH Specialist Department
1500 Bendemeer Road #03-02
Attn: Mr Chui Jian Wei
2 EXECUTIVE SUMMARY
2.1 The audit's scope, schedule, methodology and rationale for the choice of methodology used in the audit shall be outlined.
2.2 The findings of the audit and recommendations for improving the safe management of hazardous substances in the facilities shall be outlined.
3.1 General description of the company and its activities.
3.2 The audit's scope, schedule, methodology and rationale for the choice of methodology used in the audit shall be elaborated.
3.3 The audit team leader and members are to be introduced. Their qualifications and experience should be listed.
4 OVERVIEW OF USE/HANDLING OF HAZARDOUS SUBSTANCES
4.1 This section should present a description of the storage sites, processes and operations in which hazardous substances are involved and an overview of the likely hazards present.
4.2 Maps, sketches and a list of the types/quantities of hazardous chemicals stored should be included. The list should also state each substance's UN Hazard Class, PSA DG Group and NFPA Hazard Rating, if available.
5.1 This section shall present the assessment of the management of hazardous substances in the facility with respect to the prescribed eleven (11) audit elements.
6.1 The key findings of the audit and recommendations to improve the safe management of hazardous substances in the facility shall be presented in detail along with their underlying rationale and an action plan for their implementation.
6.2 Factors that could result in a hazardous / catastrophic event, the likelihood and consequences of such an event and the control measures at the facility should be discussed.
7.1 Certification by audit team leader (or consultant) and senior management that:
- the handling and storage of hazardous chemicals at the site comply with the provisions / sections of the EPMA,
- all reasonable professional skill, care and diligence had been taken in preparing the audit report and that the contents are a true representation of the facts,
- the site conforms generally to guidelines pertaining to the safe management of hazardous chemicals stated in the (SEMI international standards/specifications or FM loss prevention engineering guidelines or equivalent (only for wafer fabrication plants)
- the maintenance of fire alarm and protection systems and other fire safety works conform to the requirements stated in the NFPA, UFC or UBC codes or any code of practice established by PSB and FSB. (for sites storing and handling flammable and combustible substances)
- after the implementation of recommendations, the occurrence of a hazardous substance spill/release at the site, with off-site impacts, in unlikely.
Name of Safety Audit Firm
Name of Safety Audit Firm
Designation of management in charge of FM or EHS
Name of Company Audited
Designation of senior management (e.g CEO, MD, GM or Plant Manager)
Name of Company Audited
REFERENCE READING MATERIAL
*Environmental Audit Handbook
Ministry of the Environment and National Council on the Environment
ICC Guide to Effective Environmental Auditing
International Chamber of Commerce (ICC)
United Nations Environment Programme
An Introduction and Practical Guide
ISO 14000 Standards
14001 - Environmental Management Systems (EMS) Specification
14004 - EMS - General
14010 - Environmental (Env) Auditing - General
14011 - Env Auditing Procedures
14012 - Env Auditors
Safety Audit for the Safe Handling of Hazardous Chemicals
ISO 14000 Guide
Complete Guide to ISO 14000
- * - These references are available at the Woodland Regional Library.
- If your company is going to conduct safety audits for the first time, it is advisable that you engage a consultant accredited by NEA.
INDUSTRIES UNDER MINISTRY OF MANPOWER'S SAFETY & HEALTH MANAGEMENT SYSTEM AND NEA'S SAFETY AUDIT SCHEME
As of 1st Mar 2001, the Ministry of Manpower (MOM) has extended its Safety & Health Management System (SHMS) scheme to cover oil and petrochemical industries and wafer fabrication plants. As NEA's Safety Audit elements are covered under MOM's SHMS scheme, there shall not be a need for industries covered under both schemes to carry out a separate safety audit for NEA subject to the following procedures:
- Industries engage 3rd party auditors registered with both MOM and NEA or 2nd party auditors from their companies' corporate HQs with the approval of both MOM and NEA to carry out MOM-SHMS once every 2 years; and
- The SHMS reports shall be submitted to MOM with a copy to NEA. NEA will accept MOM-SHMS as NEA-SA.