The introduction of a comprehensive Occupational Safety and Health Act (OSHA) 1994 was in response to the need to cover a wider employee base and newer hazards introduced in the workplace. The OSHA 1994 is enforced by the Department of Occupational Safety and Health (DOSH) (previously known as Factory and Machinery Department. The name was changed to reflect changes in coverage) under the Ministry of Human Resources.
Every organization should be able to effectively implement the awareness on occupational safety and health strategy by having a formal EH & S systems that follow standards such as ISO 14001 and OSHA 18000, among others. This standard provides a framework for organizations to identify and control the OSH incidents and implement a systematic approach to setting goals and targets of OSH to achieve the goals and highlights the success achieved. Thus, this scenario leads to an investigation of the implementation of OSH management by one of the most established air-conditioning manufacturing company, Carrier International Sdn Bhd in Bangi. A brief overview about a comprehensive and outstanding OSH management system as well as supported by complete documentation gives us a better understanding about the correct organization safety management.
Willis Carrier invented the first system for "manufactured weather" in 1902, he sparked an industry that revolutionized the way in which we live and "firsts" that have shaped and defined the heating, air conditioning and refrigeration industry. Carrier established its first foothold in Malaysia in 1959 when Carrier International (Malaysia) Ltd was formed as a distributor for Carrier air-conditioning equipment and components. The company was subsequently renamed Carrier International Sdn Bhd (CISB). Today, CISB is one of the largest suppliers of air-conditioners in South-East Asia.
Carrier (Malaysia) Sdn Bhd was incorporated in 1960 to take care of the marketing and servicing of all types of Carrier air-conditioners for the Malaysia market. It is staffed by professionally trained personnel and features a collective team of qualified technicians. Carrier Corporation, USA owns 51% of Carrier (Malaysia) Sdn Bhd's share, while Permodalan Nasional Berhad (PNB) holds the remaining 49% share.
Carrier air-conditioners have been sold and installed in Malaysia for more than 40 years now. Carrier has the proud distinction of cooling the nation's latest architectural wonders like the Kuala Lumpur International Airport, or "KLIA", Menara Kuala Lumpur or "KL Tower", Petronas Philharmonic Hall, and the Prime Minister's Office in Putrajaya.
STATEMENT OF SAFETY AND HEALTH POLICY
Environmental, health and safety becomes an increasingly important business concern. The roles of the organization are indisputable offering supportive environment for the implementation EH&S program. As new regulations evolve internal and external stakeholders increasingly paying attention to their ongoing business, and need to stay in compliance with these regulations in the minds of these companies. The consequences of not in accordance with OSH regulations are drastic which can lead to penalties, fines, damage to the image , erosion of shareholder value, plant shutdowns, and in some cases even fatalities. (Matthew, 2010). Thus, it leads to the commitment of CISB as the most established manufacturer of air-conditioning to be a responsible corporate citizen through making environmental, health & safety considerations priorities throughout its operations as officially stated below in their statement of safety and health policy.
The purpose of The Safety and Health Policy are to demonstrate the company's concern and commitment to ensure safety and health of the employees. It acts as a basis for developing and implementing programs for securing safety and health at the workplace as stipulated under the guidelines by The Occupational Safety and Health Act 1994, (Act 514). Finally, it should affect all work activities and decision making process of the organization.
There are three main parts of the written policy, namely:
General Policy Statement
The first part can be a simple and brief statement of the overall intent of the employer to look after the safety and health of the workforce. Among others it should:
Indicate that the management accept responsibility for safety and health of the employees and others who may be affected by the work activities.
Outline the goals of the policy.
Establish the importance of safety and health to overall business performance.
Bear a reference to other parts of the policy document which go into more details.
Be dated and signed by the Chairman or Managing Director, or whoever speaks for the organization at the highest level.
The second part of the policy document should explain the organization for safety and health responsibilities. This will be mainly about "who is to do what". Essentially it should spell out:
the list of safety and health responsibilities of all levels of management i.e. from top management down to supervisors, and safety and health personnel (if any)
The role of workers in the implementation of the policy. Each employee has a duty not to endanger himself or others by his actions or omissions, and to co-operate in all measures provided for his safety and health
The structure and functions of safety and health committees and other in-house safety and health organization (if any).
The third part of the written policy documents deals with practical systems and procedures. It concerns mainly with potential hazards and methods of dealing with them. Among others, essentially it should specify detailed arrangements for ensuring that the General Policy is being implement including:
the arrangements for training and instruction
information about whatever hazards there may be in certain processes, the control measures and the ways in which employees should co-operate for their own safety and health
specify the company's safe system of work including safe work procedures and rules
scheme for the issuance, use and maintenance of personal protective equipment (P.P.E.)
the procedure for reporting and investigation of accidents
Emergency measures such as fire and first-aid arrangements.
CARRIER INTERNATIONAL SDN BHD (CISB) STATEMENT OF SAFETY AND HEALTH POLICY
The company's goals are to protect and to provide a better life for employees, society and the earth's natural resources by:
Ensuring compliance with Malaysian laws and regulations.
Ensuring compliance with UTC standard practices.
Eliminating all employee injuries by making the workplace free from hazards and unsafe conditions.
Establishing EH&S standards and managing to achieve the objectives and goals planned.
Continuous improvement of the EH&S management system & the operational performances with total employee involvement & responsibility, and working with suppliers and contractors.
Prevent or minimize any potential adverse environmental impacts arising from operations, products and services by:
Ensuring proper management and optimum consumption of our natural resources including water, electricity, r22 and raw materials;
Ensuring proper management of domestic and schedule wastes such as contaminated rags, empty containers and general rubbish;
Reduce, reuse and recycle scraps such as aluminum, copper and steel.
Communicating the EH&S policy to all employees and making it available to all interested parties.
Based on our observation, Carrier International Sdn Bhd has issued a written EHS Policy Statement that is in alignment with the UTC and Carrier EHS Policy statements. It has been signed and dated by the Senior Site Manager. The policy will be reviewed annually, reissued as necessary, and communicated to all employees. The policy will articulate senior management's EHS philosophy, commitment and expectations, providing a visible guide for the organization. The policy statement will be available to the public upon request (refer to Appendix 1). The policy will be reviewed annually and minute in the OSC minutes of meeting.
As such, CISB has been comply with the basic seven regulations under OSHA 1994 that enforced by DOSH under Employers' Safety and Health General Policy Statements (Exception) Regulations, 1995. They have a complete set of EH&S manual for the accurate guideline of the company safety management program. It is also proving that CISB has complied with legal requirement under Section 16 of Act 514 states:
"Expect in such cases as may be prescribed, it shall be the duty of every employer and every self-employed person to prepare and as often as may be appropriate revise a written statement of his general policy with respect of his employees and the organization and arrangements for the time being in force for carrying out the policy, and to bring the statement and any revising of it to the notice of all of his employees".
It is important that contents of the policy be made known to employees during induction and job training. The general policy statement should be displayed at strategic locations in the workplace. It its understood that CISB has act in accordance with OSHA 1994 as they had give top priority to formulate a written safety and health policy of their workplace to ensure the success of their safety and health program. It is also equally important that CISB ensure that what is written down is being implemented at their workplace. In short, a safety and health policy is not a mere scrap of paper but a living document.
SAFETY AND HEALTH COMMITTEE
An employer employing 40 or more persons must establish a safety and health committee at the workplace. The committee's main function is to keep under review the measures taken to ensure the safety and health of persons at the workplace and investigate any related matters arising. An employer must notify the nearest occupational safety and health office of any accident, dangerous occurrence, occupational poisoning or disease which has occurred or is likely to occur at the workplace.
CISB SAFETY AND HEALTH COMMITTEE
Figure 1: CISB Safety & Health Committee Chart
In addition to the OSH, Carrier International Sdn Bhd has an EHS Committee which serves to provide the participation, involvement and communication channel from the employees to the management and vice versa in overall implementation of EHS program trough out the organization level. The committee role and responsibilities are defined in the Occupational Safety and Health (Safety Committee) Regulations, 1999.
The EHS Committee is chaired by Human Resource Manager and consists of appropriate key members of the local management team and equally number of employees from various department representatives. The Safety Officer/Coordinator will be the Secretary for the committee (refer to Appendix 2).
The Operation EHS Committee will at minimum meet every quarter and the minutes of the meetings are documented. The appropriate level of communication regarding the committee actions will be provided to the affected plant population. (Refer to Appendix 12)
Base on our interview with En. Basiruddin, EH&S Manager of CISB, the Safety and Health Committee has meet the terms of safety and health committee function as listed below:
Review and approve operation-wide policies, the EHS Annual Plan, program evaluation results and other initiatives
Approve the necessary human, financial, technical resources required to implement EH&S program.
Approve the annual EH&S plan and make a continuous follow up of the progress towards goal and objective.
Review status of ongoing programs and progress to goals/targets
Review regulatory compliance status
Provide direction to line and functional staff
Sustain interest and communication in EHS throughout the operation
Establish issue-specific subcommittees as necessary
Ensure appropriate procedures, programs and activities are in place
Ensure employee understanding of EHS policies, procedures, programs and other initiatives
Ensure that adequate technical skills are available
Ensure employee participation in the development and implementation of EHS programs and activities (e.g., participation on EHS committees, self inspections, communications, hazard identification and control, etc.)
Accident is unexpected and unplanned event in a sequence of events, which occurs through a combination of causes which result in physical harm (injury or ill health) to the individual, damage of property, near miss, loss or any combination of these effects" (Ismail, 2002). Due to its hazardous nature, manufacturing is globally perceived as an accident-prone industry. It has always been reported that manufacture work has a very high rate of injuries and deaths. Therefore, there is a negative stereotype concerning safety in the construction industry. To improve manufacturing site safety, technical issues are no longer emphasized amongst governmental agencies and private sectors. The direction for accident prevention has been shifted to the development of safety management frameworks promoting the implementation of safety programs. Given that the personal safety and health of each employee is of primary concern, the prevention of occupational accidents and injuries is of such consequence that it should be given precedence over operational productivity. Hence, CISB has documented manual on procedure to prevent accident in their workplace as reported to our establishment.
There are 3 major steps taken to avoid such accident occur during the company's operation which has been briefly discussed below:
PREVENTION AND CONTROL
Those risks that have the greatest potential for adverse effects will receive the highest ranking, and be addressed first. Lower priority risks will be evaluated for applicability to the operation and addressed as such. Control measures, such as engineering controls, policies, programs, procedures, standard work, etc., will be used when technological options are not available or cost prohibitive. The program to eliminate, prevent or control the risk will be developed, responsible person to complete the activities assigned in the document and distributed to all concerned by the EH&S Manager. Activities that have the potential to create a significant risk to human health or the environment, additional requirements such as Cardinal Rules and standard work covering requirements for monitoring equipment and process have been developed. Emerging issues of major significance will be evaluated and addressed based on their assigned priority
PERSONAL PROTECTIVE EQUIPMENT (PPE)
Personal protective equipment (PPE) and clothing is used when other controls measures are not feasible and where additional protection is needed. Workers must be trained to use and maintain equipment properly. In CISB the workers must understand the limitations of the personal protective equipment. The employer is expected to require workers to use their equipment whenever it is needed. Care must be taken to ensure that equipment is working properly. Otherwise, PPE may endanger a workers' health by providing an illusion of protection and below are the sample of PPE provided in CISB line operation.
Figure 2: Sample of PPE list At Raw Material Assembly by CISB
All EHS incidents will be reported, reviewed and investigated to a level commensurate with the actual and potential consequence of the occurrence and in accordance with UTC Policy 33 and UTC Policy 52.
Carrier International Sdn Bhd will investigate incidents in accordance with Carrier and UTC incident / accident investigation process.
All occupational employee and/or contractor fatalities
All serious EHS incidents and serious near misses
All incidents requiring notification to a regulatory agency
All incidents that led to receipt of a government EHS enforcement action
All incidents that require the implementation of the operation's emergency response plan
All recordable injuries/illnesses
Other incidents that have the potential to seriously affect the health and safety of employees or the environment.
All first aid cases
Proper management of hazards sporadically identified in the workplace can be done through effective process. A safety hazard is any force strong enough to cause injury, or damage to property. An injury caused by a safety hazard is usually obvious. For example, a worker may be badly cut. Safety hazards cause harm when workplace controls are not adequate and this leads to the EH&S Committee to recorded job hazard analysis in ensuring safety management control. (Refer to Appendix 3)
HAZARD ASSESSMENT RISK
The assessment process will identify EHS risks and regulatory and company requirements (including standard practices); list the affected areas in the facility; assign a ranking; identify strategies to eliminate, prevent or control the risk; identify the responsible parties for addressing the risk; and identify an estimated completion date. In Carrier International Sdn. Bhd., the assessment is accomplished through:
Machine Guarding Inspection
Confine Space Inspection
Working at Height Inspection
Incident Investigations performed.
Management Audits and Inspections
Trend analysis performed quarterly by the EH&S Manager
Risk assessment of new Service contracts priority to acceptance.
Employee concerns identified during training sessions and during Oversight Committee meetings.
Ergonomic assessments performed annually
Review existing and proposed Legal Requirements and UTC Standards by EH&S Manager.
Emergency evacuation drills performed annually
Review of EH&S risks prior to purchase, lease or divestitures
Review of process, chemicals or equipment prior to purchase or implementation
When EH&S incidences from other UTC locations are communicated.
Job Hazard Analysis (JHA)
The Risk Assessment is an ongoing process, which will be evaluated by the EHS Manager and other appropriate personnel prior to the Annual Planning process and annual Program Evaluation. All Hazards identified from the above activities will be registered into the "Risk Assessment Inventory Form" for prevention and control process. (Refer to appendix 4)
After the risk has been identified, it will be combined with the Probability of occurrence of the event with the Consequence and then assigning a degree of risk by using Table below:
Ultimately, the individual or team who identified the hazard must ensure proper communication of the hazard to the appropriate workplace authority (manager, department head, or designated person). Each HIRARC must be fully documented. In CISB, proper job hazard analysis has been taken seriously to ensure accident prevention and control within the whole organization operations. (refer to Appendix 5)
Emergency can be concluding as 3 important criteria:
Accident - unexpected event which cause damage or harm.
Emergency - an unforeseen combination of circumstances or the resulting state that calls for immediate action.
Disaster - a sudden calamitous event bringing great damage, loss and destruction.
During an emergency, individuals may panic or overreact. As a consequence early actions have to be taken to address the crisis. These initial tasks can be undertaken by Emergency Response Teams (ERT) structured by CISB while waiting for assistance from the relevant authorities to deal with the crisis at hand.
Figure 3: Emergency Response Team Chart
Mr Basiruddin, EH&S Manager of CISB mentioned that many accidents are just caused by ignorance, and absence of safety equipment, and procedures, and are avoidable if dealt with in the correct manner. The first step did by CISB in reducing accidents is to have proper safety procedures for all processes was to. For example, if the employees are dealing with heavy machinery, you must set out the safety processes, and steps that they have to take for dealing with that machinery or chemical as documented in job hazard analysis. (Refer to Appendix 3) CISB workers have been educating about how to handle the machinery or the chemical properly. Although training is necessary, the workers have been provided with safety equipment and uniforms that keep them safe from harm. It should be a strict rule that employees wear gloves, helmets, uniforms, or any other relevant piece of clothing at all times when handling machinery, or chemicals, so that the chances of accidents occurring are minimized.
In terms of chemical hazards safety management, CISB has comply with the regulations by registering 149 chemical used within the company operations. (Refer to Appendix6) It is a compulsory for any company to report the chemical involvement within their operation event as to be prepared for any chemical hazards or disaster. For disaster which is classified as non-disastrous, the relevant agencies can handle using minimum resources and facilities at local level. In case of disaster caused by fire or hazardous materials (hazmat), Fire and Rescue Department Malaysia will act as a main agency to handle it. CISB ERT has a role to contribute and play in both disastrous and non disastrous disaster in assisting the government machinery.
Nonetheless, any accident occurs in CISB has been managing effectively based on several steps undertaken by the ERT and EH&S committee as listed below:
First step to take is reporting the accident to the immediate senior or supervisor and calling an ambulance.
If there are representatives or workers responsible for first aid, informing them of the accident will help the victim get medical aid at the earliest.
Any work related accident how minor it may be, should be recorded in accident investigation report. Details such as the date, time and place of occurrence and any other possible detail should be included in the record. (refer to appendix 7)
Medical attention should be given to the injured person. All injuries, minor and major should be reported so that the medical report has clear details of all injuries sustained. This report will be produced in court during the compensation claim litigation.
The supervisor must take responsibility of investigating the possible cause of the accident. This way further such incidents can be avoided. It will also reduce unnecessary damages to the company.
The victim must request for absence of leave and the employer must inform the same to the Health and Safety Executive if the leave is availed for more than 3 days.
Carrier International Sdn Bhd has a written emergency plan to protect people, the environment and property appropriate to the nature and scale of its activities. The plan includes effective response measures to protect people, the environment and property from potential emergency situations and incidents such as:
Fires and Explosion
Major chemical spills and releases
Natural disasters (e.g., earthquakes, tornadoes, hurricanes, etc.)
Any other significant risk to people or the environment)
Influenza Pandemic etc.
Emergency plans will be tested and reviewed annually and after any incident that meets the criteria of UTC Policy 33 or UTC Policy 52 or as changes in local conditions warrant. Revisions, if necessary, will be made to the plan(s) after each review and communicated to the affected parties. Our emergency plan is in SP17 Emergency Response Plan.
In addition, The EH&S Manager must complete the form that required by Regulation 10 of the Occupational Safety and Health (Notification of Accident, Dangerous Occurrence Occupational Poisoning and Disease) Regulation 2004 and must be kept in the place of work for 5 years. Failure to maintain and post is a contravention of the above Regulation. (Refer to Appendix 8 and Appendix 9)
Based on the incident reported below, our observation found that CISB has manage effectively prevent and control workplace accident as only 6 cases recorded by year 2010.
It is impressive noted that CISB has successfully reducing and assessing their risk possibility and manage hazard analysis effectively to prevent higher rate of workplace accident among their workers. Nevertheless, from our observation, the written safety manuals must be enforced to be read by all employees, so that they know how to act in certain situations. Apart from this, the company should make sure that routine inspections are held of all the equipment, and machinery, so that if there are any discrepancies, they are caught earlier.
SAFETY TRAINING ARRANGEMENT, FACILITIES AND DOCUMENTATION
The training activities as identified by the risk assessment will form the "Training Plan" meanwhile EH&S issues to be communicated based on risk assessment document will form part of the "Communication Plan". The key action items of the risk assessment document will be included in the "Annual Plan".
As the risk assessment document will be monitored for corrective action progress, the "Training Plan", "Communication Plan" and "Annual Plan" will automatically to be monitored.
In CISB, EHS Training will be provided that enables employees to acquire the appropriate EHS skills and knowledge to perform their job functions. The training program consists of:
Identification of job functions that require EHS training and/or certification shall be done by the EHS manager and Human Resource manager.
Education and training will be delivered by the EHS manager or third party accredited training organization based on the assessment and the nature of task employees are involved with.
The effectiveness of the training at providing awareness, knowledge, skill or behavior change will be evaluated by management through inspections and audits, quiz programs during the training sessions, and by the EH&S Manager at the time of the Program Evaluation. Effectiveness will also be determined by:
Reduction in EH&S performance trends.
Qualitative assessment of the Internal Audit findings.
Employee evaluations completed following selected training sessions.
Through review during the annual Program Evaluation
A training plan that outlines who will be trained, the topic and dates that training will be conducted
Training documentation including certifications, competency assessments (where required), proof of attendance, a written description of training, dates of training which will be maintained by EHS department by documentation and will be filed based on required storage period.
In CISB, a written "Training Plan" for each year and will consist of the following types of training (refer to Appendix 10):
Mandatory Training for all new employees
New Employee EHS orientation
Policies and goals
EH&S Cardinal rules and procedures
Job Specific Training prior to starting work on a new job
Relevant rules, procedures and regulatory requirements
Hazards and preventive and control practices and equipment
Training needs identified through the risk assessment process
Training material will be obtained or developed by the EH&S staff with input and assistance by supervision and employees. Training will be delivered by the EH&S staff and / or supervisors or the training manager as defined in the Training Plan.
Training Effectiveness Evaluation
Effectiveness will be determined by:
Reduction in EH&S performance trends during the Annual Program Evaluation
Qualitative assessment of the management audit findings
Employee evaluations completed following selected training sessions
Pre and Post Tests
Human Resource Department will retain copies of training materials and signup sheets as indicated below: (Refer to Appendix 11)
Items that are not completed according to the dates listed on the Calendar will be added to the risk assessment for review, monitoring and tracking to completion by the EHS Oversight Committee.
An annual EH&S Training Plan will be developed by the EHS Department and reviewed by the EHS Oversight Committee Items that are not completed according to the dates listed on the Calendar will be added to the risk assessment for review, monitoring and tracking to completion by the EHS Oversight Committee.
SAFETY AND HEALTH PROMOTION AND PUBLICITY
Communications are for conveying EHS issues, information and awareness. Mandatory communications include:
Communication of Carrier's Cardinal Rules
Posting or providing information as required by Cardinal Rules
Reporting of EHS information and incidents to Carrier/UTC as required
Communicating relevant Carrier Alerts, Bulletins, and similar awareness advisories
Results of incident investigations, audits, inspections, new or revised rules or procedures, the annual EHS plan, EHS performance, new or revised training, etc.
Annually, a written Communications Plan will be developed which, at a minimum addresses:
EHS performance, including progress toward goals
EHS incidents, such as injuries, spills, regulatory violations, etc.
Rules, procedures and general EHS information
Intended audience, including employees and other stakeholders as appropriate
Methodology for two-way communication between management and stakeholders
Specific communication methods and frequency of communication
EHS manager filed a copy of the communication plan. Requests for information from external organizations are channeled through the business communications department or group.
The effectiveness of communication will be determined by improvement in EHS performance trends and qualitative assessment through management audits and program evaluation.
DRILLS AND EXERCISES
To test the efficiency of CISB ERT, its emergency plans and procedures, its training effectiveness, and equipment is by conducting drills and exercises. There are different types of exercises which can be implemented at the workplace. The drills and exercise are such as Functional Exercise or Full-Scale Exercise etcetera to evaluate a plan. Drills and exercises must be conducted regularly in practical situations or as depicting real situations so as to develop the response organization (ERT) into an effective coordinated team, which can functions efficiently during an actual emergency.
CISB Company has done the OSH to their employees and become the company who are very committed to the safety and health among their workers. This can lead to the successful on doing their jobs and satisfaction among their workers. In order to keep their reputation at the organization, they have to keep their performance and their worker's quality and productivity towards their company. So, the companies have to take action as a whole view of the company so that they can identify the weakness and strength about their company including their safety and health towards the workers. Other than that, the company very details on every step that they take so that they can overcome the problems without causing the bigger loss to the company. The OSHA 1994 has being the guideline to the CISB Company towards the successful company about the productivity and the job performance to the workers.
CISB has become more secured company to the workers that do daily tasks in the company and they can retain their performance and their quality to achieve what they want to get on their goals. Furthermore, CISB has stated that they are good company condition workplace to secure their worker's safety and health in order to fulfill they goals towards the successful of the company.