A Safety Management System (SMS) should be built on the foundation of up-to-date risk assessments, as these identify the hazards and risks associated with your operations. Without accurate and current risk assessments, your SMS may lack the relevance and effectiveness needed to control potential safety issues. Here’s how a proper SMS should be created as a response to your risk assessments:
1. Risk Assessment: The Starting Point
A risk assessment identifies hazards, evaluates the risk (likelihood and severity of harm), and suggests control measures to mitigate the risks. These assessments need to be specific, up-to-date, and regularly reviewed to reflect any changes in:
- Equipment, materials, or processes.
- Legal or regulatory requirements.
- Incident or near-miss data.
2. Control Measures: The Core of Your SMS
The control measures derived from risk assessments should shape your policies, procedures, and protocols within the SMS. These measures can follow the hierarchy of control, which includes:
- Elimination or substitution of hazards (e.g., replacing hazardous chemicals with safer alternatives).
- Engineering controls (e.g., installing guards on machines).
- Administrative controls (e.g., safety training, safe work procedures).
- Personal protective equipment (PPE) as the last resort.
Every control measure identified should have a corresponding aspect within the SMS that ensures these controls are effectively implemented, monitored, and maintained.
3. Structure of Your Safety Management System
Based on the identified risks and control measures, your SMS should be designed with key elements such as:
- Safety Policy: A statement of your company’s commitment to health and safety, which should reflect the findings of your risk assessments.
- Risk Management Procedures: Formal procedures to identify, assess, and control risks. These procedures should align with the risk assessment outcomes.
- Operational Controls: These are the detailed processes and instructions that are put in place to manage the risks. For example, if a risk assessment identifies a high risk of machine-related injury, your SMS should include specific procedures for machine operation, lockout/tagout processes, and maintenance protocols.
- Training and Competency: Based on risk assessment findings, your SMS should ensure that employees are trained to deal with identified hazards. This includes training in specific control measures, emergency response, and the correct use of PPE.
- Emergency Response Plan: Your SMS should include plans to respond to potential emergencies identified in risk assessments, such as fires, chemical spills, or accidents.
- Monitoring and Review: The system should include mechanisms to track the effectiveness of the control measures. Regular audits, inspections, and incident investigations ensure that the control measures remain relevant and effective. These reviews must be informed by updated risk assessments.
4. Continuous Improvement Through Regular Reviews
Risk assessments must be living documents. Your SMS should incorporate regular reviews of these assessments, especially after:
- Accidents or near misses.
- Changes in work procedures, equipment, or processes.
- Introduction of new legislation or standards.
ISO 45001, the international standard for Occupational Health and Safety Management Systems, emphasizes the “Plan-Do-Check-Act” cycle, where risk assessments continuously inform improvements in the SMS.
5. Legal and Compliance Requirements
In South Africa, the Occupational Health and Safety Act (OHS Act), 85 of 1993 requires employers to identify and mitigate risks to health and safety. According to Section 8(1), employers are mandated to ensure, as far as is reasonably practicable, that the working environment is safe. This includes conducting risk assessments and taking steps to reduce identified risks.
Additionally, regulations such as the Construction Regulations of 2014 (if applicable) emphasize the need for ongoing risk assessments and the implementation of relevant control measures. Compliance with these laws is critical, and your SMS must reflect these requirements by integrating risk assessments into every layer of your safety processes.
