HSE Gap Analysis and Risk Assessment for Construction Site Safety

Introduction and Aims

Occupational health and safety management has numerous benefits for business. It is not only an employer's duty of care — a legal and moral obligation — but also a critical part of business functions equal in importance to finance, marketing, and production. When health and safety is embedded as part of business culture, the results include a good company image and reputation, better employee motivation and morale, improved efficiency, and ultimately increased profitability.

The implementation of a sound health, safety, and environment (HSE) management system provides an effective framework to minimize or prevent accidents and ill health. The aim of this report is to assist decision-making, planning, and implementation of construction projects by minimizing risks to employees and associated workers engaged in construction activities. This improves cost-effectiveness, reduces indirect costs due to business interruptions, and improves employee and public engagement. The review was conducted in line with the Health and Safety at Work Regulations 1974 and applicable regulations and Approved Codes of Practice (ACoPs).

APM Terminals Construction's (APMTC's) HSE management system is modelled on the recognized BS OHSAS 18001:2007 health and safety management system standard. A gap analysis was conducted to identify gaps and non-conformances, which are prioritized according to the criticality of each gap.

The study identifies non-conformances and gaps in the health and safety management system that can cause hazards to personnel and assets. The report also demonstrates evidence of a lack of visible leadership in the implementation of the HSE programmes. Most importantly, the study reviews the most significant hazards to assess whether risks have been reduced to a tolerable level, and finds that the reduction of hazard levels is inadequate. The study evaluates and measures the risks associated with working at height and noise in order to reduce them to a level described as ALARP (As Low as Reasonably Practicable).

HSE assurance is provided by identifying and managing risks according to the principles of risk tolerance, risk reduction, and continuous performance improvement. The ALARP control principle is achieved when additional measures that could be taken to reduce the residual risk are no longer deemed practical or cost-effective — that is, ensuring that risks which cannot be eliminated are reduced to ALARP. This report applies the ALARP principle to ensure that risks to life, assets, reputation, and the environment are reduced and controlled to acceptable levels.

All relevant hazards arising from the organization's activities have been identified. The two most significant hazards have been selected, and detailed risk assessments were carried out to identify residual risks and recommend mitigation measures to conform to ALARP. The paper recommends best industry practice and economic, technical, and health and safety considerations. The study holds that a platform is essential for presenting or coordinating key issues that require consensus and need to be conveyed to all departments as quickly as possible to discuss safety-related matters.

The best strategy to identify all hazards and risks is to break down all critical jobs and critically assess the risks involved. This strategy assists in carrying out risk assessments for all critical jobs. Non-compliance with the recommendations can lead to litigation, loss of customers, and consequently a loss of revenue.

Aims and Objectives

It is important to develop safer ways of working to ensure that work is completed in a timely manner, with fewer resources and fewer delays due to accidents and absenteeism caused by illness. The aim of this report is therefore to demonstrate to senior management that a thorough review of the HSE management system has been undertaken, risks have been identified, and gaps have been addressed to ensure that additional control measures are in place to make associated risks as low as reasonably practicable.

The key objectives are:

1. To review APMTC's HSE management system and evaluate it against the BS OHSAS 18001:2007 standard in order to establish areas of non-conformance and identify opportunities for improvement.

2. To identify and evaluate the significant hazards to which APMTC employees are exposed during the course of their work, as well as existing control measures.

3. To carry out risk assessments on the two most significant hazards identified (one physical and one health and welfare hazard). The risk assessments are used to evaluate the adequacy of existing controls and to propose SMART (Specific, Measurable, Attainable, and Time-bound) recommendations to further increase the level of control associated with these hazards.

4. Each recommendation is aligned with the resources available to APMTC and is justified by means of a cost-benefit analysis that clearly shows the legal, moral, and financial implications. Each recommendation is tabulated in the form of a step-by-step action plan to aid implementation by the organization. The recommendations are time-bound with target dates, specific actions are described, and budgets and responsible persons are allocated to ensure implementation.

Methodology

A multi-faceted approach was taken in conducting this review. An audit was carried out over a two-day period from 21 to 23 August 2016 and involved both office-based and site-based evaluations of the management system and workplace hazards. The first part of the audit involved assessing compliance of the management system with the BS OHSAS 18001:2007 standard. A desktop study of the APMTC HSE management system was carried out to assess whether its content met the requirements of the standard.

Relevant applicable legislation — including the Control of Noise at Work Regulations 2005 and the Work at Height Regulations 2005 — was considered, as were relevant ACoPs such as the Management of Health and Safety at Work ACoP and Guidance for the Management of Health and Safety at Work Regulations 1999 (HSE Books, 2000).

Interviews were undertaken with a cross-section of the workforce, including supervisors, crane drivers, scaffolders, truck drivers, security guards, and the water purification plant supervisor. A health and safety survey developed for this report was used to identify issues surrounding the implementation of the management system. The information gathered was then captured using a gap analysis tool for the requirements of the BS OHSAS 18001:2007 standard.

Site tours were carried out to identify hazards associated with work activities, including working at height (scaffolds), construction activities, crane driving, transport and movement of vehicles, maintenance of equipment in the workshop, work on electrical systems, and the operation and maintenance of water networks and pumping stations. Interviews were conducted with workers in each area to assess their understanding of the hazards associated with their jobs and the controls in place.

Significant hazards were identified; considerations were made regarding who could be harmed and how, what existing controls are in place, and what additional controls are needed. Hazards were evaluated and ranked using the HSE's 5×5 risk matrix based on likelihood and severity. The two most significant hazards were then selected and detailed risk assessments specific to each hazard type were carried out. Based on the findings from the gap analysis and risk assessments, recommendations are provided that are justified by means of a cost-benefit analysis (HSE's Five Steps to Risk Assessment, INDG163, Revision 3).

Description of APM Terminals Construction (APMTC)

APMTC is a medium-sized civil construction company specializing in the construction of marine port expansion projects, known internally as Brownfield Projects. The main construction projects currently undertaken in the UAE include: construction of a workshop; construction of three commercial buildings; water pipeline works in the vicinity and associated activities; and operation and maintenance of water networks and a pumping station.

The organization has been certified to the ISO 9001:2000 standard and has an HSE management system developed based on BS OHSAS 18001:2007 guidelines. It is headed by a board of directors, and local operations are led by a Managing Director (MD) for Middle East Operations. The MD is functionally responsible for all aspects of the organization's operations in the UAE and reports to the Chief Operations Officer (COO) based in The Hague. The organization has project, procurement, surveying, and human resources departments.

Each project is managed by a Project Manager with a team of project engineers, designers, site engineers, foremen, and team leaders. One HSE Engineer has been appointed to manage and monitor the implementation of the health and safety management system during operations. The majority of the labour force is from Bangladesh and India, and is mostly unskilled. The organization holds major equipment including excavators, bulldozers, graders, backhoes, piling rigs, mobile cranes of various capacities, generators, and compressors.

A typical project is executed in the following phases: site mobilization and establishment; surveying, testing, and soil investigations; substructure, excavations, and reinforcements; piling and foundations; structural steel erection; concrete frame construction; pre-cast floors and panels; external claddings and roofing; finishes (plastering, screeding, and floor finishing); carpentry and joinery; and services (plumbing and mechanical).

The projects are administered from site offices located at the construction site. The site has administrative staff including cleaners and security guards, and provides office space for the client and consultant representatives. The site offices are marked and fenced with proper access controls and security gates. A workshop within the site premises carries out carpentry, welding, steel fixing, and cutting. A vehicle maintenance area is designated for cleaning and general servicing. A canteen managed by a sub-contractor provides food for workers and staff. Adequate ablution facilities, drinking water, and welfare breakout areas are established to accommodate adverse weather, heat, or wind. First aiders and first aid boxes are available; the nearest clinic is 3 kilometres from the site.

The normal working hours are 07:00 to 19:00, with workers rotated not to exceed 8 hours a day, 6 days a week. Night work, if required, does not extend beyond 22:00. The workforce is predominantly male (approximately 90%), with workers aged between 25 and 55 making up over 75% of the total workforce.

Legal Environment and Regulatory Framework

There are two key regulations issued as federal decree in the United Arab Emirates: Ministerial Order 32 (1982) and the UAE Ministry of Labour and Social Affairs (Federal Law No. 8/1980), which broadly cover the main responsibilities of employers and employees on health and safety matters. Abu Dhabi Municipality is the public authority that regulates health and safety on all development activities in the UAE. Its health and safety guidelines are based on EU standards and cover all activities on a construction site. UAE Ministry of Health Regulations govern all health-related affairs in the country.

By virtue of the organization operating as a branch of a Netherlands (EU) entity, EU regulations are also applicable to all its operations. The legal system in the UAE is similar to EU law and is divided into criminal and civil branches. A single safety violation could lead to both civil and criminal law action. The organization is also vicariously liable for damages caused by employees acting in the course of their employment. The enforcement authority in health and safety matters is the Health and Safety section of the UAE Labour Department, or the local authority (Abu Dhabi Municipality) acting on its behalf.

The most important piece of legislation covering occupational health and safety in the workplace is the Health and Safety at Work Act 1974 (HSW 1974), which specifies the general duties placed on employers and employees. The Construction (Design and Management) Regulations 2007 (CDM 2007) is the key regulation for the construction sector, made under the HSW 1974. The associated Approved Code of Practice (ACoP) helps duty holders comply with the minimum accepted standards.

Other main sources of legal rules relating to health and safety in the construction industry currently in force include:

1. The Construction (Head Protection) Regulations 1989 — designed to provide protection, so far as is reasonably practicable, against foreseeable risks of injury to the head in a construction environment.

2. The Construction (Health, Safety and Welfare) Regulations 1996 — imposing requirements with respect to the health, safety, and welfare of persons carrying out construction work.

3. The Lifting Operations and Lifting Equipment Regulations 1998 (in association with the Provision and Use of Work Equipment Regulations 1998) and associated ACoPs — applicable to all lifting equipment and operations, as well as access equipment and other machinery used during construction.

4. The Work at Height Regulations 2005 and associated ACoP INDG 401 — applying to all activities where a person could be injured by falling, even at or below ground level.

5. The Control of Substances Hazardous to Health Regulations 2002 — applicable for activities involving handling hazardous substances such as paints, solvents, and cement.

6. The Health and Safety (Consultation with Employees) Regulations 1996 — requiring the organization to consult employees in good time on matters relating to their health and safety at work.

7. The Employers' Liability Compulsory Insurance Act 1969 — requiring the organization to insure against liability for injury or disease to employees arising out of their employment.

8. The Social Security Act (Claims and Payments) Regulations 1979.

9. The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) — covering reporting of fatalities, serious injuries, and dangerous occurrences.

In addition, a number of regulations were passed to comply with EC directives, including: the Construction Plant and Equipment (Harmonization of Noise Emission Standards) Regulations 1988; the Falling Object Protective Structure for Construction Plant (EC Requirements) Regulations 1988; the Roll-over Protective Structures for Construction Plant (EC Requirements) Regulations 1988; the Construction Sites Directive (92/57/EEC); and the Working Time Directive (93/104/EEC).

By virtue of this legal framework, management has undertaken the necessary protocols to conform with these requirements. While safety procedures have assisted in effecting positive changes, conforming to health and safety law remains an ongoing obligation, and full compliance has not yet been achieved.

Health and Safety Management System Review and Gap Analysis

Description of the Health and Safety Management System

The organization operates an HSE management system that embraces the principles of BS OHSAS 18001:2007 "Occupational Health and Safety Management Systems." The system is structured in three parts.

Part 1 is the Policy Document (statement of intent), which states how top management implements the health and safety policy. It is displayed on some of the organization's notice boards and provides an overview of the management system.

Part 2 contains organizational procedures, guidance notes, and key standard forms — the "how to" of the system. It broadly covers: organizing; planning and implementation; performance measurement; and audit and management review.

Part 3 comprises supporting documentation and guidance, including generic documentation, toolbox talks, hazard checklists, and safety standards for common operations and tasks.

Part 2 of the management system contains the following sections: Section 1 (Manual Structure and Information); Section 2 (Health and Safety Responsibilities); Section 3 (CDM, Contract Start, Commissioning, and Handover); Section 4 (Risk Assessment); Section 5 (Procedures for Inspection and Audit); Section 6 (Incident Reporting and Investigation); Section 7 (Performance Indicators); Section 8 (Welfare and Site Establishment); Section 9 (Fire and Emergency Plans); Section 10 (Occupational Health); and Section 11 (Plant and Tools).

Occupational Health and Safety Policy

APMTC's occupational health and safety policy is a simple and clear document outlining the company's vision and commitment to health and safety. All requirements of the standard — such as commitment to meet all relevant legislative requirements and to provide sufficient resources — are outlined in the policy document. The policy is signed by the Managing Director as a demonstration of management commitment. It is communicated to all employees by email, with copies posted on health and safety notice boards and available on the intranet.

However, the policy document has not been dated, making it unclear when it was last updated. Through consultation with some workers, it was found that they were unaware of the content of the health and safety policy. The HSE model is based on continuous improvement, in which management reviews, plans, monitors, and implements appropriate safety measures. The management also implements the health and safety management model to conform with the OHSAS 18001 model, which includes identifying work activities, checking which activities can cause harm to workers, reducing risks that could lead to hazards, improving the work environment, and verifying whether protective measures have been properly implemented.

Gap Analysis of the Health and Safety Management System

The gap analysis was conducted using the Barbour Checklist: BS OHSAS 18001 Audit Checklist (2016). The following table summarizes the findings, compliance status, gaps, and priority ratings. Priorities are defined as: P1 (Major) — high priority, non-compliance could lead to immediate loss or enforcement action, action required within 1–3 weeks; P2 (Medium) — no immediate impact, but health and safety cannot be managed efficiently if unaddressed, action within 1 month; P3 (Minor) — no immediate impact, action within 3 months to ensure overall effective management and avoid non-compliances.

General Requirements / HSE Management System

Has an HSE management system been established, documented, implemented, maintained, and continually improved in accordance with the requirements of the OHSAS Standard? Yes. Has the organization determined how it will fulfil these requirements? Yes — a yearly safety plan with objectives is established. Is the scope of the HSE management system defined and documented? Yes — contained within the document.

General Requirements / HSE Policy

Written policy statement of intent, signed, dated, and communicated to all employees: Partly Yes — the statement of intent is not dated and has not been communicated to all staff. (P2.) Health and safety of employees is considered an important business objective by top management: Yes. Top management is committed to continuous improvement: Yes. A named senior manager is appointed with overall responsibility for implementing the health and safety policy: No — no person is appointed by name to take overall responsibility for health and safety affairs. (P1.) Policy encourages involvement of employees and safety representatives: Yes. Includes a commitment to ensuring that all employees are competent to carry out their jobs safely: Yes. Responsibilities clearly defined to all personnel including managers, supervisors, and team leaders: Partly Yes — responsibilities of top management are not defined. (P2.) All personnel accept their responsibilities and have adequate time, resources, and competence: No — no defined budget has been allocated for health and safety programmes. (P3.)

Planning / Hazard Identification, Risk Assessment, and Determining Controls

All items in this section are compliant: procedures are established and maintained for ongoing hazard identification, risk assessment, and determination of necessary controls; methodology is proactive; risks associated with organizational changes are identified prior to introduction; a hierarchy of controls is considered; and HSE risks and determined controls are taken into account when establishing the management system.

Planning / Legal and Other Requirements

All items compliant: a procedure is established for identifying applicable legal and other requirements; information is kept up to date; and relevant information is communicated to those who need it.

Objectives and Programmes

Documented HSE objectives with programmes for their achievement are established at relevant functions and levels: Yes. Objectives are measurable and consistent with the HSE policy: Yes. Responsibilities, authorities, resources, and time-frames are designated for achieving objectives: Yes.

Implementation and Operation / Resources, Roles, Responsibility, Accountability, and Authority

A member of top management is assigned specific responsibility for HSE: No — no person is appointed by name, meaning top management may not have the time to tend to HSE affairs and may not be aware of the status of objectives. (P1.) Identification of people responsible for particular health and safety jobs: No — adequate health and safety persons have not been identified or recruited. (P1.) Assessment of experience, knowledge, and skills needed to carry out all tasks safely: No — employee training requirements are not communicated to employees or appropriate supervisors. (P1.) System for ensuring adequate instruction and training for all employees including managers, supervisors, and temporary staff: No — no clear training budget or facility has been allocated. (P2.) Identification of specific training, skills, and experience assessment for people doing hazardous work: No — no competency-based training has been identified and no training matrix has been developed. (P1.)

Implementation and Operation / Competence, Training, and Awareness

System for ensuring competence needs are met when recruiting, promoting, or transferring people, or assigning health and safety responsibilities: No — health and safety competency assessments are not administered as part of the recruitment or promotion process. (P3.)

Communication, Participation, and Consultation

Consultation with employees and employee safety representatives on all issues affecting health and safety: No — a health and safety committee has not been formed and meetings are not held as planned. (P2.) Active health and safety committee chaired by a director or senior manager with representation from all divisions: No — meetings are held seldom and senior managers do not attend. (P1.) Involvement of workforce in preparing improvement plans, reviewing performance, undertaking risk assessments, and investigating incidents: Partly Yes — employee involvement is limited to incident investigations, and no system exists for addressing employee suggestions. (P1.) Cooperation and coordination with contractors on health and safety: Yes — sub-contractors receive a copy of the organization's health and safety plan and are required to align their plans accordingly. Health and safety as a standing agenda item of regular management meetings: No — health and safety is discussed only in safety meetings. (P1.)

Documentation and Document Control

All documentation and document control items are compliant. Documentation is maintained to ensure the HSE management system can be adequately understood and effectively operated. A procedure is established to control documents required by the system and the OHSAS standard.

Operational Control

Operational controls have been implemented and maintained: Partly Yes — operational controls are integrated into the overall HSE management system; however, controls related to purchased goods and equipment pertaining to low-noise equipment are not in place. (P1.) System for hazard identification, risk assessment, and controls and safe systems of work: Partly Yes — only generic hazard assessments have been carried out; individual jobs have not been evaluated using a risk assessment; no hazard register is present. (P1.) Arrangements for measurable, realistic, and time-bound health and safety targets: No — objectives and targets are not reviewed and updated annually, and no action plan is maintained. (P2.)

Emergency Preparedness and Response

Emergency response procedures: Partly Yes — a procedure is in place but no testing and evaluation of the emergency plan is conducted at the required intervals (at least annually). (P1.)

Checking / Performance Measurement and Monitoring

Welfare arrangements including medical facilities: Yes. Key Performance Indicators (KPIs) to measure health and safety performance: Yes. Documenting and communicating inspection, monitoring, and incident investigation reports: Yes.

Evaluation of Compliance

Procedures established for periodically evaluating compliance with legal and other requirements, with records kept: Yes. Methods used include audits, regulatory inspection results, analysis of legal requirements, reviews of incident records and risk assessments, interviews, facility tours, and direct observations.

Incident Investigation / Nonconformity / Corrective and Preventive Action

Procedures established to record, investigate, and analyse incidents: Yes. Investigations performed in a timely manner: Yes. Results documented and maintained: Yes. Monitoring performance and measuring targets and objectives: Partly Yes — targets are not reviewed, which could lead to delays and missed objectives. (P3.) Proactive monitoring involving testing, inspecting, and consultation: Yes. Reactive monitoring such as investigating accidents, incidents, near misses, and hazardous situations: Yes.

Control of Records

All records items are compliant: records are established and maintained, and procedures are in place for identification, storage, protection, retrieval, retention, and disposal. Records are maintained in a legible, identifiable, and traceable state via a SharePoint file on the intranet with restricted access.

Internal Audit

Internal audits of the HSE management system are conducted at planned intervals: Yes. Audit results are provided to management: Yes — through formal close-out meetings and audit reports. Audit programmes are planned and maintained based on risk assessment results: Yes. System for regular audits by competent independent auditors: Partly Yes — the number of trained and competent auditors is inadequate. (P2.)

Management Review

Use of audit and inspection reports to review the safety management system: Yes. Review of objectives to check if they are met in agreed timescales: No — objectives are not reviewed in a timely manner, which could lead to non-conformance. (P2.) Analysis of audit reports to identify future improvement targets: No — objectives are not reviewed and new targets are not set. (P2.) Benchmarking performance against similar business groups: Yes — APMTC is part of the Global Ports Group, which has a subcommittee on HSE.

Suggestions to Improve Performance

The method to improve performance and conform with the OHSAS 18001 model is to assess the significant identified risks and implement appropriate controls to reduce them to a tolerable level. For example, management should develop policies to reduce risks and hazards that could lead to death. The company should also create OHSAS policy objectives to reduce adverse performance outcomes. Analysis of the implementation of OHSAS 18001 reveals that the organization has not implemented adequate training programmes for personnel to gain knowledge and technical understanding of hazard and risk control. The company should therefore implement training programmes to enable employees to become competent to manage risks. Training should focus on maintaining competency certification and ensuring employees understand their health and safety roles and responsibilities. The organization should carry out training for supervisors and other key personnel to implement appropriate health and safety programmes in order to comply with legislation.