HEALTH

HEALTH AND
AND SAFETY
SAFETY AT
AT WORK
WORK FOR
FOR
PEOPLE WITH DISABILITIES
PEOPLE WITH DISABILITIES
Occupational
Occupational Health
Health and
and Safety
Safety Management
Management System
System Manual
Manual

OCCUPATIONAL HEALTH AND SAFETY

MANAGEMENT SYSTEM MANUAL

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RECORD OF CHANGES TO THE OHSMS MANUAL

Revision Pages Revised

Date Approved by Signed
No. modified by

Drawn up by: Date

Approved by: Signed Date

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INDEX

INDEX_______________________________________________________________________3
1. GENERAL REMARKS_____________________________________________________5
1.1. INTRODUCTION________________________________________________________________5
1.2. COMPANY PRESENTATION_____________________________________________________5
2. OCCUPATIONAL HEALTH AND SAFETY POLICY, OBJECTIVES AND
GOALS_______________________________________________________________________5
3. THE OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT SYSTEM__9
3.1. GENERAL REMARKS___________________________________________________________9
3.2. THE OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT SYSTEM MANUAL___9
3.2.1. Objective and scope of application_________________________________________________________9
3.2.2. Management of the Manual______________________________________________________________9
3.2.3. Format of the Manual__________________________________________________________________10
3.2.4. Distribution of and modifications to the Manual_____________________________________________10
3.3. OCCUPATIONAL HEALTH AND SAFETY SYSTEM DOCUMENTATION
(PROCEDURES AND INSTRUCTIONS)_______________________________________________11
3.4. OTHER DOCUMENTS__________________________________________________________11
4. MANAGEMENT RESPONSIBILITIES_____________________________________12
4.1. RESPONSIBILITIES____________________________________________________________12
4.2. ORGANISATION_______________________________________________________________13
4.3. DEFINITION OF RESPONSIBILITIES AND FUNCTIONS___________________________13
4.4. MEASURES FOR MAKING CHECKS AND ENSURING EMPLOYEE PARTICIPATION
__________________________________________________________________________________16
4.5. THE MANAGEMENT REPRESENTATIVE________________________________________16
4.6. INFORMATION AND TRAINING OF PERSONNEL________________________________16
5. OCCUPATIONAL RISKS_________________________________________________17
5.1. IDENTIFYING AND KEEPING A RECORD OF STATUTORY REQUIREMENTS_______17
5.2. IDENTIFICATION, ASSESSMENT AND RECORDING OF RISKS____________________17
5.3. PROGRAMMED INSPECTIONS__________________________________________________18
5.4. PROCESSING SUGGESTIONS___________________________________________________18
6. PLANNING HEALTH AND SAFETY OBJECTIVES________________________18
7. CONTROL OF ACTIVITIES_______________________________________________19
7.1. ACTIVE CONTROL____________________________________________________________19
7.1.1. Control of purchases___________________________________________________________________19
7.1.2. Contracts, subcontracts and temporary employment agencies___________________________________19
7.1.3. Maintenance of installations_____________________________________________________________19
7.1.4. Care and surveillance of employees’ health_________________________________________________20
7.1.5. Control of hygiene hazards______________________________________________________________20

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7.1.6. Selection and control of PPE____________________________________________________________20

7.2. REACTIVE CONTROL__________________________________________________________21
7.2.1. Investigation of incidents (occupational accidents, incidents and illnesses)________________________21
7.3. CASES OF DEVIATION, NONCONFORMITY AND CORRECTIVE ACTIONS_________21
7.3.1. Adoption, control and monitoring of corrective and preventive measures__________________________21
7.4. CHECKING, MEASURING AND TESTING________________________________________22
8. OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT DOCUMENTS
AND RECORDS_____________________________________________________________22
9. ASSESSMENT OF THE OCCUPATIONAL HEALTH AND SAFETY
MANAGEMENT SYSTEM___________________________________________________22
9.1. INTERNAL AUDITS____________________________________________________________22
9.2. REVISION OF THE SYSTEM BY THE MANAGEMENT OF THE COMPANY__________23
10. COMMUNICATION, CONSULTATION AND PARTICIPATION IN
HEALTH AND SAFETY______________________________________________________23
10.1. INTERNAL COMMUNICATION________________________________________________24
10.2. EXTERNAL COMMUNICATION________________________________________________24
10.3. THE CONSULTATION AND PARTICIPATION PROCESS__________________________24
11. EMERGENCY PLAN____________________________________________________24
12. APPENDICES___________________________________________________________25
APPENDIX I. ORGANISATIONAL CHART FOR THE COMPANY………….._____________26
APPENDIX II. EMERGENCY PLAN____________________________________________________26

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1. GENERAL REMARKS
1.1. INTRODUCTION

The company....., in its concern for the health and safety of its employees, has
developed an Occupational Health and Safety Management System. In developing
this System, special attention has been paid to disabled employees and to the
measures that are to be applied to both them and the workplaces where they
perform their job duties.

This System is based on compliance with Health and Safety at Work (Northern
Ireland) Order 1978, Health and Safety Regulations and approved Codes of Practice
supplementing Regulations, which all impose duties in respect of specific hazards or
work processes or groups of workers and OHSAS 18001 Specification on
“Occupational Health and Safety Management Systems”.

This Occupational Health and Safety Manual is the property of the company, and
may not be reproduced in full or in part. Any company, organisation or person
wishing to have a copy of this Manual must make a request in writing to the
company’s Management.

The company’s Management fully accepts the content of this Manual as well as the
content of the procedures to which it refers, and supports and promotes all actions
designed to ensure that it is fully applied.

The head of each department must be familiar with the content of the Manual and
have in-depth knowledge of those aspects that could affect his or her area of
influence. He or she must manage, coordinate and promote its application.

1.2. COMPANY PRESENTATION

Information about the activities carried out by the company (mention what appears
in the memorandum of association and/or articles of association, whichever is
applicable). The places of work where the activity is mainly carried out are......

2. OCCUPATIONAL HEALTH AND SAFETY POLICY,

OBJECTIVES AND GOALS
The company, aware that responsibility for the management of Occupational Health
and Safety falls to all those who work in the organisation in accordance with their
different levels of responsibility, adopts a management system based on Health and
Safety at Work (Northern Ireland) Order 1978 and applicable Regulations and Codes
of Practice and on OHSAS 18001 as an essential element for guaranteeing that this
principle also works in practice.

The company’s Occupational Health and Safety Policy has therefore been
developed through the company’s own Management System, with its basic elements

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being the periodical outlining of preventive and protective health objectives, in

compliance with legislation that is applicable to the company and the Management’s
commitment to a Continuing Improvement of its activities in health and safety
matters, integrating this policy at all levels of the entire organisation.

In order to be able to develop this policy, the company’s Management places all
the necessary and viable resources and means for undertaking this task at the
disposal of its personnel. It also provides periodic information regarding the
established objectives and achievements made, facilitating and stimulating
employee participation in the policy’s development and improvement.

The company’s Management will also establish appropriate information and

instruction programmes so that Occupational Health and Safety becomes another
element in the undertaking of the company’s activities.

The company’s Management is committed to studying and analysing the results

obtained, alongside its employee representatives. Therefore, the process will be
cyclical and will form the basis for assessing and updating the Management System.

Below, by way of a guide, possible examples for declarations of principles and

commitments, as well as objectives, are given.

Signed: The Management of the Company

Example 1:

With the aim of achieving the highest levels of Health and Safety we declare the
following basic principles of our policy:

 We are at the service of our clients, committed to society, the environment

and the health of our employees, and respect the legal framework and
regulations established for each case.

 We accept the need to constantly work to improve the quality of our

products, services, processes and working conditions. We achieve this by
doing our work properly the first time around and by assuring that no task is
carried out without the due safety measures set firmly in place.

 Occupational accidents or any injury that takes place at work are essentially
failures in management and are therefore avoidable through proper
management whereby measures are adopted to identify, assess and control
possible risks.

 People are the most important asset for guaranteeing our future. Therefore,
they must be qualified to meet the objectives of our organisation and their
opinions must be considered.

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 We undertake all our activities without compromising health and safety

aspects in favour of economic or productivity considerations.

To carry out these principles the following commitments are made:

 All personnel in positions of responsibility will guarantee the proper

conditions for the employees in their charge. As part of their role they will
show interest and lead by example.

 The company promotes and establishes the necessary means so that the
communication of deficiencies and/or suggestions for improvements are
analysed and, where possible, implemented. A spirit of innovation and
constant improvement is vital for the future of our company.

 We establish channels for the exchange of information among our

personnel as well as with our clients and suppliers in order to constantly
improve the way we select our supplies, carry out our work, manufacture
our products and provide our services...

 We inform and train our workers about risks arising from their work, and
about the means and measures to be taken to prevent them. To do so, we
have the necessary procedures in place to develop the various preventive
measures.

 We analyse all accidents, which could cause harm and take steps to rectify
the situation immediately.

Our company accepts the principles set out above as a guarantee for its survival and
growth.

Example 2:

Strategic objectives:

 The company’s employees understand that doing their work well at all
times is fundamental for our future and that their work will only be
considered well done when it is carried out under due safety conditions.

 Carefully ensure that the organisations that provide us with services have an
effective OHSMS and, if applicable, contribute to its improvement.

Specific objectives:

 Draw up an Occupational Health and Safety Manual.

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 Update the Risk Assessment for all work areas and posts, take appropriate
measures and plan the necessary actions for the control of the identified
risks.

 Draw up a training plan based on the results of the Risk Assessment.

 Design and put in place procedures for: the investigation of

accidents/incidents and the periodical revision of workplaces.

 Develop an awareness campaign to reduce work accidents resulting from

falls or blows. To this end a revisions system will be established by means of
a questionnaire/checklist on the tidiness and cleanliness of work areas.

 Draw up directions for the completion of the following tasks, considered

critical as a result of their possible consequences:

 Maintenance and cleaning of machinery and equipment

 Loading and unloading of lorries
 Revise and update the Emergency and Evacuation Plan. Carry out practice
drills in the use of extinguishers.

 Leading by example, insist on compliance with all the annually established

procedures and objectives.

 Signpost hazards in the workplace.

 Define the Personal Protection Equipment (PPE) that is to be used for each
task.

Note: For each of these objectives we will designate a person responsible for the
objective and a period of execution.

3. THE OCCUPATIONAL HEALTH AND SAFETY

MANAGEMENT SYSTEM
3.1. GENERAL REMARKS

The Management System developed by the company encompasses all actions

relating to the company’s processes and services that affect the Health and Safety
of its employees.

The Management System is an effective tool devised to help accomplish the

programme that is drawn up annually, based on the policy established by the
company’s Management.

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The System is included in documentary form in this Manual and in the Procedures
through which the System is applied.

3.2. THE OCCUPATIONAL HEALTH AND SAFETY

MANAGEMENT SYSTEM MANUAL
3.2.1. Objective and scope of application

The objective of this Manual is to facilitate an appropriate description of the

Management System that will serve as a permanent guide during the setting up and
operating of the System. It is the basic reference document and includes a description
of the System’s general structure and operating procedures.

It is applicable to the Workplaces of the company with registered address

at.....in.....

3.2.2. Management of the Manual

The company’s System Coordinator, by delegation of Company Management, is

responsible for:

 The planning, analysis, and drawing up of the different chapters of the

Manual.
 The controlled release and distribution of copies.
 The maintenance of this Manual.

The company’s Management is responsible for approving the content of this Manual
and any subsequent modifications that are made to it.

3.2.3. Format of the Manual

All the Manual’s pages will indicate the following:

a. the page number

b. the manual’s code
c. the copy number
d. the manual’s revision number
e. the page revision number
f. the edition date

The format used for Appendices that correspond to forms or record cards will be the
following:

 Name: Mod.MAEP.XX.YY

 Mod: Model

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 M: Manual
 A: Appendix to the Manual
 EP: Emergency Plan
 XX: The first two digits correspond to the Manual’s code
 YY: The second two digits correspond to the code for the type of form
or record card

Any partial revisions made to this Manual will be recorded on the inside flap of its
cover along with their corresponding justification.

A partial revision is one that modifies part of the Manual. When, after successive
partial revisions, the company’s Management believes that the modifications that
have been introduced require a new edition of the Manual, this will be done, with the
System Coordinator responsible for its drawing up and the company’s Management
responsible for its approval.

3.2.4. Distribution of and modifications to the Manual

The company’s System Coordinator is responsible for analysing and proposing

modifications to the Manual. He or she is also responsible for ensuring that all those
who possess a controlled copy of the Manual receive the modified edition.

When those in possession of a controlled copy receive the modified pages, they are
then responsible for making the corresponding substitutions and eliminating the
obsolete pages.

3.3. OCCUPATIONAL HEALTH AND SAFETY SYSTEM

DOCUMENTATION (PROCEDURES AND INSTRUCTIONS)

The Procedures form part of the documentary support of the Occupational Health and
Safety Management System. They are written documents in which the undertaking of
an activity is described with the aim of showing how to carry it out properly and
consistently, regardless of how many times it has to be carried out.

They have been developed partly in accordance with Health and Safety at Work
(Northern Ireland) Order 1978 and applicable Regulations and Codes of Practice and
OHSAS 18001 on “Occupational Health and Safety Management Systems”, and partly
by taking into account technical criteria that are widely accepted with regard to
employee health protection.

The processing of all the supporting documentation for the Occupational Health and
Safety Management System is described in the procedure on “The Creation, Revision,
Control and Management of Documentation” as described in Chapter 8.1.

3.4. OTHER DOCUMENTS

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The other documents and records necessary for the correct development of the
Occupational Health and Safety Management System include:

 Initial Risk Assessment

 Occupational Health and Safety Management Plan
 Annual Report on Health and Safety Activities
 Applicable legislation and regulations concerning aspects of occupational
health and safety
 Work posts, with the identification of the risks to which employees are
exposed
 Up-to-date inventory of existing work equipment and its corresponding
certification
 Information Bulletin on Legislation
 Catalogue of Officially Approved Personal Protection Equipment
 Emergency Plan (Point 12 in this Manual)
 Training Plan (end result of the training planning mechanism)
 Occupational medical histories
 Health surveillance plan
 Standardised tools and methods for the identification, assessment,
analysis and recording of risks and harm

These documents and registers, as with the rest of the documentary part of the
System, have three objectives:

 To make it possible to demonstrate the System’s conformity with the

requirements of Health and Safety at Work (Northern Ireland) Order 1978
and applicable Regulations and Codes of Practice and OHSAS 18001.
 To enable evaluation of compliance with objectives and goals.
 To facilitate evaluation of the effectiveness of the working of the System
itself and its suitability for complying with the Occupational Health and Safety
Policy established by the company’s Management.

4. MANAGEMENT RESPONSIBILITIES
4.1. RESPONSIBILITIES

The company’s Management is ultimately responsible for setting up, maintaining

and controlling the Occupational Health and Safety Management System.
Furthermore, health and safety management must be adopted at each level of the
organisation in accordance with its degree of responsibility.

This responsibility obliges the company’s Management to:

 Obtain the material and human resources necessary to set up the System.

 Promote actions, which ensure compliance with the defined Occupational

Health and Safety Policy.

 Establish the System’s objectives and design the corresponding strategies.

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 Coordinate the preventive action Plans and Programs.

 Determine priorities in the adoption of the appropriate preventive measures

and the supervision of their effectiveness.

 Ensure that an Emergency Plan is drawn up and, furthermore, ensure that it is

established, developed, updated and improved.

 Establish the internal measures necessary to guarantee that the System

established in the organisation meets its objectives at all times.

 Designate the member of the management team who, having sufficient

authority, will ensure that the requirements of the reference regulations are
fulfilled and kept up-to-date. Initially this designation will devolve upon the
company’s Management.

4.2. ORGANISATION

Appendix I include the general organisational chart for the company and the
organisational structure to which the principal persons responsible for the System
belong.

4.3. DEFINITION OF RESPONSIBILITIES AND FUNCTIONS

Although the responsibilities, authority and relations between all the personnel who
direct, carry out and check any activities related to health and safety management
are clearly established in each procedure, this section aims to describe the set of
responsibilities for each post as regards Occupational Health and Safety
management.

The Company’s Management (Managing Director, Chief Executive…):

 Is legally and ultimately responsible for the effective working of the Health and
Safety Management System.

 Approves the definitive programme for the Occupational Health and Safety
Management System.

 Presents the company’s top management body with the annual Health and
Safety Management Plans, including the Company’s general Management
Plans, for approval.

 Establishes the Policy for the Health and Safety Management System.

 Chairs, either directly or by delegation, the Health and Safety Committee

meetings.

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 Presents before the company’s top management body the annual statement
on the activities carried out and the report on the working of the system.

Health and Safety Committee:

This is an employee participation body that specialises in the area of Occupational

Health and Safety Prevention, created in compliance with Health and Safety
legislation.

It is normally formed by election of Safety Representatives representing the

employees and by an appropriate number of Management representatives. The
Coordinator of the Health and Safety Management System will attend in his or her
capacity of technical assessor of the System. Depending on the area under discussion
and with the consensus of its members, the Health and Safety Committee may invite
those persons who can provide knowledge and experience on the subject in question
to their meetings. The persons invited will have their say but will not be able to vote.
The Committee meets at least once every............ (statutory minimum: every three
months) and whenever special circumstances so require.

Its functions within the Health and Safety Management System are as follows:

 Employee consideration, review and input into the drawing up and

development of the Occupational Health and Safety Management Plan.
 A means of consultation between management, staff and employees on
health and safety matters.
 Promotion of cooperation between management and employees in
investigating, developing and carrying out the measures to ensure the
health and safety of employees.
 Examination of Safety Audit reports reports and the Activity Plan on a
regular basis.
 Presentation of its opinion regarding the Risk Assessment method
employed.


Health and Safety Delegates:

 Collaborate with the company’s Management in the improvement of

preventive action.
 Promote and encourage employee cooperation in the execution of the
regulations.
 Issue, within a general deadline of two weeks, any reports that they are
asked to produce on being consulted, prior to any execution of matters
within their competence.
 Supervise and control compliance with regulations relating to Occupational
Health and Safety.
 In the event of there not being a Health and Safety Committee, the Health
and Safety Delegates will undertake the functions that would correspond to
the Committee.

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System Coordinator:

 Draws up the reports on health and safety matters, at the request of the
company’s Management.

 Records all Occupational Health and Safety legislation and regulations

applicable to the company..... in a file. “Procedure for Identifying and
Keeping a Record of Statutory Requirements” OHSP.01.

 Records all the identified risks using the different procedures drawn up for
this purpose and draw up situation outbreaks.

 Records all the proposed corrective actions and has them monitored.

 On a weekly and annual basis draws up the accident rate statistics that the
company has defined.

 Proposes objectives and goals to be met in the Occupational Health and

Safety Management System.

 Draws up the Annual Plan of Inspections and the Audit Plan and proposes
them for approval through the Company’s management representative to
the company’s top management body.

 Is responsible for managing the drawing up of the Emergency Plan and the
training that derives from it.

 Manages, with the assessment of the Health and Safety Service, the
necessary Personal Protection Equipment. Keeps a catalogue of the
equipment in use and draws up an annual report on this matter.

 Keeps a control of the records generated by the system. As well as the

records, he or she also participates in the control of all the System
documentation in accordance with the procedure established for this.

 Participates in the drawing up and development of the Training Plan from

the point of view of Occupational Health and Safety.

Health and Safety Organisation:

In accordance with Health and Safety at Work (Northern Ireland) Order 1978, the
company has (Designated Employees, its own, a joint or external Health and Safety
Service)......

Its functions are (in the event of having an External Health and Safety Service, state
the service provision specifications that are established in the contract):

 To give advice and support in accordance with the types of risk.

 The supervision and monitoring of all actions affecting its area of
competence.

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All Personnel:

Must comply with the responsibilities with which they are assigned within the
Occupational Health and Safety Management System: comply with the instructions
that they are given, collaborate in the proposal of corrective actions, inspections, the
use of PPE, etc.

4.4. MEASURES FOR MAKING CHECKS AND ENSURING

EMPLOYEE PARTICIPATION

In order to find out whether the Occupational Health and Safety Management System
has been defined and developed correctly and is operating effectively, the Company
will check the conformity of its actions with the system and with the policy, objectives
and goals that have been established. By the term “check” it is meant an action
aimed at confirming that the established operations, activities and practices comply
with the requirements of the System.

Also considered as included here are the activities designed to guarantee compliance
with Regulations, such as internal audits and revisions by the company’s
Management.

The Audit Plan, drawn up in accordance with the “Procedure for Internal Audits”
OHSP.12, identifies the audits which have to be carried out on the System during the
year. The company’s Management, when approving said plan; will also assign the
resources necessary for its execution.

The necessary evaluations made in the periodic controls of unavoidable risks will be
carried out by the Health and Safety Service in accordance with the evolution of these
risks, at the request of the System Coordinator.

In addition to these checks, there is a constant monitoring of the programmed

activities and of the evolution of objectives through the institutionalised channels of
internal communication: Committee Meetings, informative chats, written supports,
etc.

4.5. THE MANAGEMENT REPRESENTATIVE

The company’s Management delegates the task of supervising and promoting the
development and establishment of the System and the operative function within it to
the System Coordinator.

This Coordinator is assigned the necessary responsibilities for different activities, in

accordance with Section 4.3 on the “Definition of Responsibilities”.

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4.6. INFORMATION AND TRAINING OF PERSONNEL

In order to guarantee that the personnel correctly perform the functions with which
they have been assigned in the Procedure for Occupational Health and Safety, the
company includes this aspect of management in its procedure for “Occupational
Health and Safety Information and Training” OHSP.13.

The “Emergency Plan” also includes the basic techniques for ensuring that the
company’s personnel is organised and trained, thus guaranteeing speed and efficiency
when action has to be taken in emergency situations. Moreover, the “Emergency
Plan” indicates its own revision system, in order that the structure designed is kept
up-to-date.

5. OCCUPATIONAL RISKS
5.1. IDENTIFYING AND KEEPING A RECORD OF STATUTORY
REQUIREMENTS

In order to comply at all times with statutory requirements it is essential to establish a

system for keeping an up-to-date and organised record of laws, regulations and rules
of any type that refer to aspects of Occupational Health and Safety and which must be
complied with. This system must also establish how the specific enforceable
requirements that must be taken into account are to be identified and how they are to
be disseminated to the department(s) responsible for their application.

In order to do this, the company has developed the procedure “Identifying and
Keeping a Record of Statutory Requirements” OHSP.01.

5.2. IDENTIFICATION, ASSESSMENT AND RECORDING OF

RISKS

The general activity of identifying, analysing, assessing and keeping a record of

occupational risks is the starting point for the Management System and indicates one
of the areas where the company’s efforts should be focused.

Occupational Health and Safety should be focused on the continuing improvement of

working conditions, and therefore measures should be adopted and activities carried
out in all the phases of the company’s undertakings in order to prevent and/or
reduce occupational risks.

The identification of risks is essential, so that they can be avoided through awareness
of their existence or, if this is not possible, analysed, assessed and recorded, as a prior
step to their elimination/reduction/control and as a necessary activity for the control of
the System itself.

This identification will come about as a result of various activities within the
Occupational Health and Safety Management System.

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The Assessment must cover all work posts within the company.

It must also be carried out when substantial modifications are made to employees’
posts.

It must be carried out using the method established by the Health and Safety
Executive for NI or, if this were not sufficient, then in the form that is considered most
appropriate with regard to Health and Safety.

Whatever the case, the “Procedure for the Identification, Assessment and Recording of
Risks” OHSP.02 establishes the way in which this activity is to be carried out in the
System.

5.3. PROGRAMMED INSPECTIONS

The object of the “Procedure for Programmed Inspections” OHSP.03 is to define a

methodology for the programmed performance of Inspections of the different areas
of the company, with the aim of systematically and methodically detecting the
dangers and risks deriving from them to ensure the Health and Safety of employees.

5.4. PROCESSING SUGGESTIONS

The object of the “Procedure for Processing Suggestions” OHSP.04 is to define a

work method that facilitates processing suggestions in an ordered and controlled
way, in order for them to be used as a source of awareness of risks and a channel for
everyone to participate in the improvement of working conditions.

6. PLANNING HEALTH AND SAFETY OBJECTIVES

Health and Safety objectives are defined clearly and specifically in the company. The
information necessary for establishing said objectives comes from different sources,
such as:

 Registered statutory requirements.

 Nonconformities and possible improvements detected during internal and
external audits.
 Results of the Management System revision.
 Risk Identification Activities.
 Reactive Control Activities.
 The established Occupational Health and Safety Policy.

The company’s Management is committed to drawing up an annual programme to

promote Occupational Health and Safety Management in the company. Said
programme will cover the objectives to be met, including goals, person’s responsible,
material resources and execution dates.

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7. CONTROL OF ACTIVITIES
7.1. ACTIVE CONTROL

These are provisions adopted by the company to ensure that activities that are liable
to cause or increase risks to employees’ health, and which directly or indirectly affect
the achievement of the established objectives, are carried out under controlled
conditions:

7.1.1. Control of purchases

This activity must allow awareness, before acquisition, of the risks that new purchases
could present, so that the elimination, minimisation and control of these potential risks
can be managed before materialising in the form of an injury.

The method to be used for making purchases is established in the “Procedure for the
Control of Purchases” OHSP.05.

7.1.2. Contracts, subcontracts and temporary employment agencies

Contracts, subcontracts and temporary employment agencies: the company’s

management is responsible for insisting that any companies contracted to carry out
work within the company inform their employees of all the risks to which they are
going to be exposed, as well as providing them with the appropriate protection
elements. Said requirement will be carried out in accordance with the “Procedure for
Contracts, Subcontracts and Temporary Employment Agencies” OHSP.15.

Moreover, the company must provide the contracted company with the relevant
information regarding the risks to which its employees will be exposed during the
execution of their work or during their time at the company.
With regard to Temporary Employment Agencies, the company may not contract
their services if current legislation prohibits the use of agency workers for the situation
in question.

7.1.3. Maintenance of installations

Once a year, the company’s Management will check that all installations that are
subject to specific controls have the corresponding documentation issued by the
relevant Government Authorised Organisation.

With regard to installations that are not subject to specific controls but which if not
working properly or having broken down could represent a serious risk to employee
Health and Safety (critical installations), the company’s Management will check that
the established maintenance plan has been carried out.

7.1.4. Care and surveillance of employees’ health

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The objective of the “Procedure for the Care and Surveillance of Employees’ Health”
OHSP.06 is to establish an action mechanism to guarantee the care and surveillance
of the health of employees during their working day.

This aims to reveal any conflicts between health conditions and the characteristics of
work posts, in order to avoid continued exposure to a risk and to protect those who
are considered particularly vulnerable (women, minors, disabled people, etc.). It also
makes it possible to identify, through effects on health, risks that had not previously
been recorded and which, as a result, will require the risk assessment carried out for
the affected workplace to be revised.

7.1.5. Control of hygiene hazards

The company has a system aimed at controlling hygiene risks caused by physical,
biological and chemical agents.

Said control system is covered in the “Procedure for the Control of Hygiene Risks”
OHSP.07.

7.1.6. Selection and control of PPE

The company makes sure that all its employees have and make use of whatever
Personal Protection Equipment (PPE) is necessary due to the conditions that prevail at
their job, in order to protect them from the unavoidable health risks to which they may
be exposed. This activity is carried out in accordance with the definitions in the
“Procedure for the Selection and Control of PPE” OHSP.08.

The company is committed to taking the necessary steps to minimise risks at their
source and thus reduce the need for its employees’ use of PPE. To do this it will follow
the criteria of using the best available technology at an affordable price.

If the use of PPE is unavoidable, the company will consult its employees and their
representatives with regard to the acquisition of the most appropriate models. This is
to be done with the aim of reducing any possible inconveniences or discomfort during
use.

7.2. REACTIVE CONTROL

7.2.1. Investigation of incidents (occupational accidents, incidents and
illnesses)

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If, despite carrying out the activities of the Health and Safety Management System, an
incident does take place (accident, incident or work-related illness), it is necessary to
carry out an analysis of the incident in order to ascertain its fundamental causes,
rather than merely its immediate cause, and come up with the necessary corrective
actions to prevent a recurrence of the incident.

At the same time, this analysis must allow the identification of the source hazard that
had not been recorded previously, so that preventive action can be established for
similar hazards.

The object of the “Procedure for the Investigation of Incidents” OHSP.09 is to define a
method for the investigation and analysis of incidents (accidents, incidents and
occupational illnesses) that occur within the company.

The company commits itself, insofar as it is able, to the analysis and investigation
of all types of incidents, specifically those that have not caused any harm, working
on aspects of training and awareness so that employees collaborate on this task.

7.3. CASES OF DEVIATION, NONCONFORMITY AND

CORRECTIVE ACTIONS
7.3.1. Adoption, control and monitoring of corrective and preventive
measures

The fundamental objective of the Occupational Health and Safety Management

System is risk prevention, i.e. being aware of risks before their potential
materialisation and correcting them at their source, in order that they disappear
and/or are minimised and controlled.

To make this happen, it is essential for all actions, in the event of the detection of risks
or “nonconformities”, to lead to the same place: the “Procedure for the Adoption,
Control and Monitoring of Corrective and Preventive Measures” OHSP.10, which will
make it possible to respond to the objective of dealing with incorrect situations that
are the source of risks.

7.4. CHECKING, MEASURING AND TESTING

The activities of checking, measuring and testing will be carried out by an

independent third party (usually linked to the organisation’s Insurance Company),
which is also responsible for producing the corresponding annual statement regarding
the calibration of the apparatus and equipment that is used for said activities, as well
as the corresponding qualification of its technicians.

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8. OCCUPATIONAL HEALTH AND SAFETY

MANAGEMENT DOCUMENTS AND RECORDS
It must be possible to check the functioning of the System by means of the records
that are generated.

For each procedure an appropriate form is appended where what each procedure
establishes can be registered.

The processing of the records that are used in the System (format, reference number,
updating procedures, file and storage) is clearly established in the “Procedure for the
Creation, Revision, Control and Management of Documentation” OHSP.11.

9. ASSESSMENT OF THE OCCUPATIONAL HEALTH

AND SAFETY MANAGEMENT SYSTEM
9.1. INTERNAL AUDITS

The “Procedure for Internal Audits” OHSP.12 is established with the aim of periodically
and systematically evaluating the Occupational Health and Safety Management
System and any activities concerning health and safety in the company.

Audits allow the System’s degree of implementation to be checked, as well as its

effectiveness. The following aspects must be focused on:

 Adaptation of the System in line with Health and Safety at Work (Northern
Ireland) Order 1978 on “Occupational Health and Safety”.
 Adaptation of the System in line with applicable Health and Safety Regulations
and Codes of Practice and OHSAS 18001 on “Occupational Health and Safety
Management Systems”.
 Degree of compliance with the Management Plan.
 Adaptation of the System to comply with the Health and Safety Policy.

The System Coordinator, in accordance with the “Procedure for Internal Audits”
OHSP.12, will draw up an Audit Plan on an annual basis, where it will be determined
“who” does the audit, “what” they audit, “how” they do the audit and “on what” the
audit is “based”. The plan will also establish the course that the result of these audits
should take in order to ensure that they really do fulfil their function.

9.2. REVISION OF THE SYSTEM BY THE MANAGEMENT OF

THE COMPANY

In order to ensure its suitability and efficiency, the Occupational Health and Safety
Management System will be subject to systematic and periodic revisions and
assessments by the Management.

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Revisions of the System will be carried out at least once a year.

The revision will consist of an assessment by the company’s top management body,
at the proposal of the Management’s representative, of the results of:

 The audits carried out throughout the year, whether internal or external.
 The rate of accidents within the company.
 The degree of compliance with the health and safety objectives established in
the corresponding Management Plan.
 The efficiency index reached in the execution of corrective and preventive
actions deriving from the different procedures within the Management
System.

The conclusions of the aforementioned assessment and corresponding corrective

action will be recorded in a report that will be distributed to the company’s
Management, to the Management representative in the System, to the System
Coordinator, to the Health and Safety Committee or, otherwise, to the Prevention
Delegates or the employee representatives.

10. COMMUNICATION, CONSULTATION AND

PARTICIPATION IN HEALTH AND SAFETY

The objective in this case is to establish guidelines for both internal and external
communication, as well as to establish mechanisms so that any employee may make
consultations and participate in Occupational Health and Safety and in its
management within the company.

The company’s Management is ultimately responsible for the communication,

consultation and participation of the employees, while the System Coordinator is
responsible for its execution, control and monitoring.

10.1. INTERNAL COMMUNICATION

The company’s Management believes that it is very important that internal

communication, integrated within the company’s daily activity, and the flow of
information referring to its evolution, improvements, problems, changes, suggestions,
obligations, etc., reaches all those who have a role within the company, in
accordance with the “Procedure for Communication, Consultation and Participation in
Occupational Health and Safety” OHSP.14.

To do so, it takes advantage of already existing, institutionalised communication

channels within the company.

10.2. EXTERNAL COMMUNICATION

The company’s Management, complying with applicable statutory requirements, will

notify the competent industrial and health authority of the incidents and activities that

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it is required to report, mainly those deriving from accidents and occupational

diseases, epidemics and common illnesses that must always be reported, and also the
management plan and the report on the activities of the Health and Safety Service.

Moreover, it will strictly comply with the need to send the “Accident report resulting in
an employee being unfit for work” to the corresponding Entity, in accordance with the
“Procedure for Communication, Consultation and Participation in Occupational Health
and Safety” OHSP.14.

10.3. THE CONSULTATION AND PARTICIPATION PROCESS

In the consultation and participation process, the company’s Management will act in
accordance with Health and Safety at Work (Northern Ireland) Order 1978 and other
applicable regulations. To do so it will use the employee representation that exists in
the company (Health and Safety Committee, Prevention Delegates, etc.) in
accordance with the “Procedure for Communication, Consultation and Participation in
Occupational Health and Safety” OHSP.14

11. EMERGENCY PLAN

The Emergency Plan in itself is not a procedure but rather a Management System
document. See APPENDIX II.

The procedure is the periodical updating of said Plan in order to guarantee that it has
been properly adapted to the actual situation of the risks, which generate emergency
situations. Said procedure is included in the document entitled “Emergency Plan”.

12. APPENDICES
APPENDIX I. Organisational chart of the company
APPENDIX II. “Emergency Plan”

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APPENDIX I. ORGANISATIONAL CHART FOR THE

COMPANY…………..

APPENDIX II. “EMERGENCY PLAN”

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