SAFETY HEALTHMANAGEMENT SYSTEM

Our Health Safety Management System has been developed in order to implement theHealth & Safety Policy Statement of Moore Cleaning Services and is based on the requirements of The Occupational Health and Safety Advisory Services BS OHSAS 18001:2007 and ISO 14001.

Our management system is intended to provide the Company with the elements and structure required for effective management of its Health & Safety obligations to its staff, clients and other persons who could be exposed to hazards associated with the Company’s activities. Furthermore, the management system is designed to cover operations both on-site and offsite when controlled by the Company’s employees.

2. POLICY

3. PLANNING

4. IMPLEMENTATION AND OPERATION

5. CHECKING

6. MANAGEMENT REVIEW

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POLICY

OCCUPATIONAL HEALTH & SAFETY POLICY STATEMENT

The Company’s current policy statement can be found within the company Safety Statement

The management system as outlined within this document constitutes the organisation and arrangements the Company has in place for managing its Health & Safety obligations.

2.1CompanyHealth & Safety policy

The Company has developed a Health & SafetyPolicy statement which is authorised by the Board of Directors and is supported in its delivery by the CompanyHealth & Safety Management System.

This policy statement shall be reviewed annually.

2.2COMPANY POLICIES, procedures and guidance

It is the responsibility of senior management to draft policies procedures and guidance in relation to how the Company manages it Health & Safety obligations.

Each department is required to comply with Company policies, procedures and guidance

3PLANNING

Introduction:

It is critical to the health and wellbeing of staff, other persons that hazards associated with the Company’s operations are identified, risk assessed and that appropriate control measures are put in-place in order to reduce the risk of harm. The identification of control measures for each hazard will involve consideration according to the hierarchy of controls as laid out in Company guidance:

The Company has developed systems of monitoring and performance review (sections 5 and 6) which assess the Company against identified indicators and drives continual improvement through the setting of objectives.

3.1Hazard IdentificatioN

It is the responsibility of the Company to ensure that all significant hazards arising out of the Company’s operations are identified and subsequently, risk assessed and controlled as far as reasonably practicable.

In practice day to day responsibility for this lies with Managers and Supervisors who must identify all significant hazards associated with their operations. Methods to do this include:

a)systematic analysis of the task by the manager / supervisor and / or competent person (see Risk Assessment Guidance Notes in the Safety Statement)

b)information provided on suppliers data sheets

c)systematic inspection of the workplace

3.2Risk Management

3.2.1Risk Assessment

It is the responsibility of management to ensure that all significant hazards arising out of the company’s operations undergo a suitable and sufficient risk assessment and measures are identified to control and minimise the risk as far as reasonably practicable to staffand other persons.

In practice day to day responsibility for this lies with Managers and Supervisors who must ensure that risk assessments of operations under their control are undertaken by a competent person or overseen by a competent person. Methods to do this include:

a)Moore Cleaning Services guidance on completing a risk assessment (See Safety Statement)

b)Health and Safety Authority Guidance on completing risk assessment (see HSA Risk Assessment Guidance).

N.B For non-routine activities it is the responsibility of the manager / supervisor of the activity to gain a full understanding of the nature of the hazards associated with the activity and ensure that a suitable and sufficient risk assessment is undertaken prior to the activity commencing. Examples of non-routine activity include temporary alterations to working environments / procedures, utility disruptions, extreme weather conditions

3.2.2Communication of the findings of the risk assessment:

It is the responsibility of Managers and Supervisors to communicate the findings of the risk assessment to all staff who may be affected by the operation in order that they may have the information to work safely or be aware of the hazards and actions of others.

Methods for doing this include:

a)providing and discussing the full assessment with the operator and/or

b)extraction of the salient points from the assessment into Standard Operating Procedures for relevant staff to follow

c)providing staff with relevant training and awareness

N.B. at all times a current risk assessment should be available on request to demonstrate that a suitable and sufficient assessment of the risk has been undertaken.

3.2.3Monitoring of the effectiveness of controls:

To ensure the effectiveness of the control measures the Company has established proactive and reactive methods.

Proactive:

It is the responsibility of managers and supervisors to ensure that:

a)workplace inspections are carried out in accordance with Company policy and procedures;

b)where appropriate preventative maintenance regimes are implemented, documented and monitored;

c)periodic review of the risk assessment to ensure that it remains relevant

Reactive:

a)review of causal factors in relation to incidents;

b)in response to complaints from interested parties and/or findings from audits and assessments

3.2.4Review of risk assessments:

To ensure that the risk assessments remain relevant, Managers and Supervisors must ensure that the risk assessment is reviewed:

a)in light of an incident;

b)as a result of change in the operation (procedure or personnel);

c)in light of new information relating to the operation;

d)at least every 3 years unless the nature of the hazard or activity is such that it requires more frequent assessment

3.3Risk Management – FIRE

The Company has established various mechanisms to support the management of risk from fire:

a)The Company has a competent person with responsibility for advising the Company on fire related matters.

b)Company buildings have undergone fire risk assessments. These assessments are subject to regular review.

c)All staff receive fire awareness briefings.

d)Maintained fire fighting equipment is strategically positioned throughout the Company buildings

e)The office has nominated fire wardens whose role is to monitor the workplace for potential situation that may cause / exasperate fire and to assist in the emergency evacuation of buildings.

f)The Company has installed and maintains fire detection systems throughout its buildings (typically to L2 Standard).

g)The Safety Manager is responsible for ensuring that workplace inspections are undertaken

h)The Officer Manager is responsible for ensuring that there are procedures in place to routinely check portable electrical appliances owned by the Company for electrical safety

3.4Risk Management- Contractors

Risk assessment

It is the responsibility of Managers and Supervisors to ensure that contractors under their control are competent to undertake the tasks assigned to them and ensure that the operations of the contractor do not adversely affect the Company and that the hazards owned by the Company are communicated to the contractor. In order to do this, Managers and Supervisors must:

a)ensure that contractors under their control have undertaken a suitable and sufficient risk assessment of the operation which takes into account the operations of the Company;

b)ensure the contractors have the correct level of competency to carry out the assigned task;

c)ensure that contractors have relevant procedures in place to undertake the work appropriately and minimise risk;

d)ensure that contractors are aware of and have access to information required for them to complete a suitable and sufficient risk assessment;

e)routinely monitor the performance of the contractor through inspection of the workplace

3.5LEGAL AND OTHER REQUIREMENTS

3.5.1The Company is committed to (at least) comply with its statutory and other requirements affecting it. To that end the Company has developed and maintains a register of legal and other requirements to which the Company must conform. It is the responsibility of senior managers to identify and address those requirements which affect areas under their control.

3.5.2It is the responsibility of Health & Safety Manager to lead in identifying changes to legal and other requirements and to disseminate relevant information to the company through appropriate communication routes

3.5.3It is the responsibility of each manager to ensure that any changes in legal requirements are identified and addressed.

3.6Objectives and ProgrammES

In order to achieve continual improvement in the management of Health & Safety throughout the Company, systems have been developed to identify, establish and agree objectives and targets [and subsequent programmes to monitor and achieve the objectives] at Company level.

The objectives will take into account legal and other compliance. Furthermore, in order to be monitored effectively the objectives will be Specific, Measurable, Attainable, Relevant and Time-bound (SMART).

In practice objectives are consulted on and agreed at the CompanyHealth & Safety Committee through advice and guidance from the Health & SafetyAdvisory Group.

4IMPLEMENTATION AND OPERATION

Introduction:

To ensure the effective management of Health & Safety within the Company; the Company has put in place structures to make certain that roles and responsibilities are defined and understood, there are mechanisms to identify training and awareness needs so that staff have the knowledge they need to work safely, and that required resources are identified and available.

In addition the Company has mechanisms for the control of documents relating to the management system to ensure that they are relevant and readily available and has established various communication systems including paper based, electronic and verbal to ensure that relevant information can be exchanged and consultation with staff and representative bodies (e.g. Trades Unions) is achievable.

Furthermore, the Company has put in place strategies and systems for actions in the event of emergencies.

4.1Roles and responsibilities – GenerAL

The Board of Directors bears ultimate responsibility for the health and safety of the Company’s staff, and other persons.

In practice the Company has delegated the authority for ensuring compliance with its obligations to the Managing Director.

The Managing Director has further delegated authority to the department heads and to the managers and this is consistent with the delegation of other responsibilities within the Company

Roles and responsibilities are highlighted in the following figures:

Figure 3: Company Health & Safety management Committees

Figure 4: Roles and responsibilities of the Managing Director

Figure 5: Roles and responsibilities of Senior Managers

Figure 6: Roles and responsibilities of Managers and Supervisors

Figure 7: Roles and responsibilities of staff

The Company requires all new members of staff (or staff that have moved departments) to attend the corporate induction which highlights the Company’s Health & Safety management system and highlights the Health & Safety responsibilities of the Company and of individuals. It is the responsibility of the Health & Safety Manager to deliver the Health & Safety aspects of the corporate induction.

4.1.1Department Induction:

Each Department is responsible for the local Health & Safety induction for new members of staff and should include local rules and site specific information.

4.1.2Job / task specific training

It is the responsibility of the manager / supervisor of the task to ensure that the person(s) undertaking the operation have sufficient knowledge to minimise the Health & Safety risk whilst carrying out the task. Methods to do this include:

a)ensure understanding of the associated risk assessment

b)ensure understanding of the associated procedures

c)ensure any specific training needs that have been identified with the task have been completed prior to the task being carried out

4.1.3Departmental Managers Meetings

The Health & Safety Manager shall meet with all Departmental Managersannually to brief on updates and forthcoming relevant issues, to discuss the performance of areas under their control and to agree objectives in-line with broader Company objectives

4.1.4Departmental Safety Officer Briefings

the Health & Safety Manager shall meet with Company Departmental Safety Officers twice annually in order to brief on updates and forthcoming relevant issues and initiatives and consult on these topics.

4.1.5Contractor Competency:

It is the responsibility of managers and supervisors of tasks under their control to ensure that contractors undertaking tasks on behalf of Moore Cleaning Services are competent to do so.

4.2COMMUNICATION, PARTICIPATION AND CONSULTATION

in the Safety Statement

5CHECKING

Introduction

The Company has established procedures for measuring and monitoring its Health & Safety performance on a routine basis. The performance monitoring and measuring consists of proactive measures (which include workplace inspections, internal audits, occupational hygiene and health surveillance monitoring) and reactive measures (which include incident investigations and monitoring in response to identified issues).

5.1Proactive monitoring and measuremeNT

5.1.1Workplace Inspections

It is the responsibility of the Departmental Managers to ensure that the workplace under their control is inspected regularly and in accordance with the Company’s Monitoring Policy.

In practice it is the responsibility of managers and supervisors to ensure the workplace under their control is inspected and that issues raised as a result of the inspections are addressed within a timescale proportionate to the risk. Records of the workplace inspections should be retained within each Department

5.1.2Occupational Hygiene Monitoring

The Companyprovides access to an occupational hygienist to provide competent advice and workplace monitoring for potential exposure to:

a)certain chemical agents

b)dusts

c)noise

d)temperature extremes

e)light levels

5.1.3Internal Audits

The Company has developed a programme of internal audits to evaluate Health & Safety performance of Departments. The programmes are:

5.1.3.1Annual Returns

It is the responsibility of the Health & Safety Manager to compile an annual return questionnaire designed to gauge the Company’s Health & Safety management performance. It is the responsibility of each Head of Department to ensure that the Company’s Annual Return performance report is completed and submitted within the specified timescale. It is the responsibility of the Health & Safety Manager to collate the data derived from the Returns and report to senior management

5.1.4Health & Safety Manager Internal Audit

It is the responsibility of the Health & Safety Manager to undertake annual internal audits to evaluate compliance and Health & Safety performance and report the findings to senior management

5.1.5Health Surveillance

It is the responsibility of each Department to identify through risk assessment the requirement for health surveillance and to keep appropriate records.

It is the responsibility of the Company to carry out baseline health checks for new staff and to undertake health surveillance on those staff identified as requiring it, to communicate to the Departments any issues arising from the surveillance results and to keep records accordingly

5.1.6Second Party Duty of Care Audits

The Company undertakes periodic second party audits of hazardous waste contractors.

The duty to undertake the audits lies with: the Health & Safety Manager

5.1.7External Audit

The Company is periodically audited by external bodies to assess its management systems. The external bodies include:

a)Dublin Fire Service – fire management

b)Zurich Insurance – general health and safety and business continuity (fire safety)

c)Health and Safety Authority – random checks

5.1.8Monitoring of Utilities

The Office Manager monitors through metering the energy usage throughout the Company. Information is provided to senior management on building energy usage on a regular basis

5.1.9Monitoring of Waste

The Company, through its domestic waste and recycling contractor, will plan to provide information on weights of domestic waste and recycling

The Company will also monitor, through the contractor, the disposal of hazardous chemical and clinical waste in line with its objective to continue to improve recycling and encourage waste minimisation wherever reasonably practicable

5.2reactive monitoring and measurement

5.2.1Accidents, Incidents and Near Misses

It is the responsibility of managers and supervisors to ensure that all accidents, incidents and near misses in areas under their control are reported using the Company reporting mechanism and are investigated to identify root causes and appropriate remedial action is undertaken to prevent recurrence. The findings from the collated data are reported to senior managers.

5.2.2Investigation of ‘Major’ Accidents, Incidents and Near Misses

The Health & Safety Manager will investigate any accident, incident or near miss which has been assessed as being of major significance. The findings from the investigations are reported to senior managers

5.2.3Investigation by Trades Union Representatives

The Company recognises that Safety Representatives have the right to investigate incidents whether highlighted by a Trades Union member or not.

To that end access to the incident data-base is available to Company recognised Trades Union Representatives on request

5.2.4Reporting of Injuries Diseases and Dangerous Occurrences

It is the responsibility of the Health & Safety Manager to assess and, when appropriate, report to the Health and Safety Authority any incident that falls under the requirements of the Safety Health and Welfare at Work (General Application) Regulations, 1993

5.2.5Occupational Hygiene Monitoring

The Health & Safety Manager carries out occupational hygiene monitoring in response to an incident and on request by managers and supervisors of the issues as highlighted in section 5.1.2

6MANAGEMENT REVIEW

Introduction

The Company has developed systems to undertake (at least) annual management reviews of Health & Safety performance.

The annual performance report is submitted to the Company top management through the management structure as shown in Figure 3

6.1MANAGEMENT REVIEW – COMPANY

A management review of Health & Safety performance will be carried out through the CompanyHealth & Safety Committee, which in-turn will report to Company Board

6.1.1Inputs to the review:

  • results of the internal audits and evaluation of compliance
  • results of consultation with Trades Union, and employee representatives
  • relevant communications from external parties, including complaints
  • Health & Safety performance of the Company
  • status of corrective and preventive actions (to include follow up actions from previous management reviews)
  • changing circumstances and developments, including legal and other requirements
  • Extent to which the Company objectives have been met
  • Opportunities for continual improvement

6.1.2Outputs of the review