Relevance of Safe Method Statement with Safety Plan As it’s basic constituent in building and construction projects

RK Poddar, Senior Advisor (HSE), Simplex Infrastructures Limited

Introductory Remarks

At the very basic level, it is pertinent to look at different synonyms of ‘work’, which generally, may be expressed as ‘task’, ‘activity’, ‘job’ and such other identities. To carry out an activity or to perform a task, an Act (human effort in isolation or in combination of other resources), a Substance (chemical - hazardous/ non-hazardous, isotopes, radio-active, reactive, toxic, poisonous, flammable, inert, biological and any such other physical/chemical property-laden material, or any other machinery/ mechanical aids), a Situation (a place of work either at minus or plus or zero level or in a confined/pressurized/ vacuum space within the ambient associated locations but having potential to cause physical harm or a negative impact on the place of work and the worker), and Energy (electrical, mechanical, chemical, thermal, stored, potential, kinetic, nuclear etc. in combination or in isolation), are required for completing the task and realizing the identified outcome.

Now, any activity without having a strong proactive element of safety planning as its integral constituent is undoubtedly fraught with unknown, if not adverse, consequence. This consequence primarily arises, if in the absence of a thought-through plan designed to work in co-ordination with one or any other combination of the work-inputs, the activity or related sub-activities may, in all probability, work at cross purpose to the detriment of the proposed task itself. Therefore, adequate planning preceding the commencement of an activity - other synonyms included - is indisputably a must.

How & why an Unplanned Event generally referred to as Accident/ Incident/Dangerous Occurrence etc.?

During my long association with the industry - manufacturing, process, infrastructure, construction, etc. - as a member of the safety (now a days identified as EHS/HSE) team of an organization, I have come across hundreds of accident reports from various work-locations. I also had the opportunity to investigate, enquire, analyze and the root-cause analysis (RCA) of many such unplanned events.

By mentioning ‘Unplanned Event’ in place of the usually common expression like Accident/ Incident, I am consciously trying to draw a distinction between ‘Accident’ and ‘Unplanned Event’. I will, on some other occasion, try to explain the distinction in details. However, it would be suffice to say that all unplanned events are unexpected incidents but accidents per say are not legally equivalent of an unplanned event.

While recalling my past experience, rarely, did I come across an investigation report forwarded by the project team which clearly identified the underlying causes stemming from aberrations/ deviations/ compromises made in the management system and fixed accountability at individual level, especially in the Indian scenario. Notwithstanding some exceptions in the multinational PMC-controlled entities, half-hearted attempts to do RCA could be there. In general though, retracing of failure-chain, in the context of the concerned in-field activity, usually stops at the act of omission or commission of the victim or, in some cases, points to certain deficiency in compliance with the laid down procedure immediately preceding the occurrence. It would be worthwhile to assert that an Accident/ Incident/ Dangerous occurrence is a culmination of a chain of failures that starts with the non-compliance with the defined management system, ineffective plan to implement the system and deficient working of the plan objectively till the end of the process. Also, checks and the consequent effective intervention which could help identify the deviations from the standard operating procedures and facilitate course correction before the damage is done, is seldom introduced. This kind of investigation is basically subjective and serves no purpose.

Responsibility, Authority & Accountability Matrix - a Prerequisite of Safety Planning

PDCA Cycle
If an accident investigation/analysis does not lead to an objective completion of Responsibility, Authority & Accountability Matrix, we end up at best, making correction in the existing physical condition - for example, a missing earthing or a guard etc. Reconnecting the earthing lead or replacing the missing guard does not amount to tackling the issues which otherwise an objective accident investigation/analysis (RCA) would have thrown up. While taking corrective action is a far cry, leave alone preventive measures – we mostly end up doing corrections. There is no disputing this fortunate fact.

It is painful to realize that the so-called EHS professionals are no less to blame in this sordid drama of accident investigation which is supposed to get at the root of the problem for initiating appropriate actions. By replacing one missing earth lead or a guard and not going into ‘why the guard was missing till an accident has occurred’, is nothing short of treating the symptom and not the disease. Why the safety people hesitate in going up the ladder to analyze and identify management failure at individual and collective level in the EHS Management System (SMS), is a separate issue which may be dealt with on some other occasion. However, why this situation is prevalent can be well understood only if the significance of overall task and safety-specific planning to safely execute the task is realized.

Relevance of Planning in the Management of Safety

Ideally and legally, especially in the construction industry - green or white - including the construction phase of a manufacturing entity, the element of Safety Planning should commence at Design which should run through Engineering & Execution and end up at Pre-commissioning and Commissioning; finally handing over the reins to operation and maintenance team to carry on the process like a baton race. In all the phases of the process, an assiduous and integrated compliance with the 7W Process of Work appears relevant. Though, as a common practice, one would invariably come across the fact that safety personnel are summoned only when the in-field and critical activity included, has proceeded and reached a stage where some make-shift safety arrangement becomes unavoidable or is necessitated on the insistence of the client or their PMC. Thus, in most of the cases, safety follows the progress rather than preceding the commencement of activity including design, engineering, and execution phases.

Therefore, it is incumbent to recall some relevant legal provisions requiring Planning to be an integral element of all the phases of work – it ought to be clarified that the 7W Process recommended for reference mostly relates to the execution phase. In the illustration below, I have elaborately dealt with the ‘7W Process of Work’ detailing the entire cycle of Plan, Do, Check, Act (PDCA) in a simplified form so as to comprehend the significance of overall work planning and safety-specific planning related thereto.

Section 6 of the ‘Building and Other Construction Workers (regulation of employment and conditions of service) Act, 1996’ requires Architect, Designer & Project Engineer to give due consideration to safety aspect right from design to maintenance as well as upkeep phases. Also, Rule 39(iv) regarding Health & Safety Policy would make it absolutely clear that hazard identification, risk assessment, and control measures, are to be taken as integral part of a method statement. Consequently, Hazard Identification & Risk Assessment (HIRA), Safety Task Assignment (STA), Job Safety Analysis (JSA), Job Hazard Analysis (JHA), Permit-To-Work (PTW) and such other techniques cannot meaningfully work in the absence of a strong element of Planning. Without Planning, I don’t see any scope for fulfilling ‘Due Diligence’ requirement which alone can legally absolve the employer under Section 53 of the Building and Other Construction Workers (regulation of employment and conditions of service) Act of any perceived offence.

What is the relevance of Due Diligence in Safety Planning?

Diligence is synonymous with a careful and persistent effort. Due, in case of health and safety, implies proactive integration of all required safety and health measures to be planned and executed in respect of all acts, situations, substances or sources of energy with careful and persistent effort.

Therefore, Due Diligence, in the context of a workplace, owned and controlled by an employer or his representative (Section 6 identifies him as the Architect, Designer, and Project Engineer) duty-binds the Architect, Designer and Project Engineer, on behalf of the Employer or the Employer himself, to make a careful and persistent effort to ensure safety and health of the building and construction workers in his establishment. Further, Rule 39 (iv) as part of Safety & Health Policy requires ‘techniques and methods for assessment of risk to safety, health and environmental and remedial measures, therefore, to be identified and assessed for taking appropriate control measures for ensuring workers’ health and safety as well as protection of environment.

In order to reemphasize the relevance of Planning, it would be appropriate to reiterate that Due Diligence is mandated before an unplanned event occurs and not after.

Contrary to the general prevalent practice vis-à-vis the legal position so clearly mandated, I cannot visualize a situation where a comprehensive Safety Planning can follow commencement of an activity. Look into any HSE Planning/ Manual, so confidently worked out and circulated, you will find that the Manual remains as an expression of intent but fails to translate into a document which would be a forerunner of activity planning and its execution.

7Ws Process

How does the Employer or his representative meet the requirements of Due Diligence?

An illustrative list of actions that an employer or his representative (Project Engineer) can take, is summed up as under:
  • Develop specific policies, practices, and procedures for hazardous activities in the workplace.
  • Provide adequate orientation and training to the concerned workforce including management representatives.
  • Ensure that competent supervisory staff monitors hazardous work and communicate risks to workers.
  • Audit the workplace for foreseeable health and safety risks and protect workers accordingly.
  • Ensure compliance through rules and discipline.
  • Never assume that the worker will know enough about the risks involved in any given task.
  • All the elements of a “Due Diligence Program” must be in effect before any accident or injury occurs.
  • If the employer or his representative has questions about Due Diligence, he should seek legal advice and Safety guidance from the project safety team so as to ensure that all appropriate Due Diligence requirements are in place.
In conclusion, I repeat, Due Diligence is demonstrated by the actions taken before an event occurs, not after, and that signifies the role of Safety Planning as a proactive measure.


R K Poddar

Mr. R K Poddar is presently working with Simplex Infrastructures Limited (SIL) as Senior Advisor (HSE). The views expressed in this article are purely his professional and personal views which, in no way, represent his views in his official capacity.
A P MOLLER Group's acquisition of MARTIN BENCHER set to trigger pricing challenges for many project forwarders globally The process of forward integration by Major Shipping lines is slowly affecting many small and medium Forwarders. Many

Read more ...

Gati Shakti is a digital backbone on which infrastructure projects planned by the government under the ₹110 trillion National Infrastructure Plan (NIP) will be implemented by 2025. It provides an institutional framework

Read more ...

Equipment with cutting edge technologies is making tunneling smoother at RVNL’s mega railway project and helping contractors overcome geological complexities. Sandvik’s DT 821 C and DT 922i advanced automatic

Read more ...

The Metro-Rail segment in India is growing at a frantic pace with positive long-term prospects, supported by the impetus provided by the government by way of business-friendly policies and financial support. Use of advanced

Read more ...

Lucknow Metro has achieved the distinction of becoming the fastest built metro rail project in the country - both in terms of completion of construction work and execution. On 25th November 2013, LMRCL

Read more ...

India received its first mode of modern transportation in 1853 when the first railway line was laid from Bombay to Thane to boost industrial activities and ensure easy accessibility to heavy raw materials. In the following

Read more ...

The growth of the tunnel construction in the country has been driven by a robust pipeline of projects and investments in setting up hydropower projects, developing urban mass rapid transit systems, improving road

Read more ...

Stoked by their debut success with the timely completion of Kajang Line’s underground section, Gamuda Engineering found themselves pitted once more against the unique challenges of tunnelling in Kuala Lumpur

Read more ...

A tunnelling project is a race against time and costs. Getting it right from the very beginning requires knowledge, skill and experience, as well as a proper range of equipment that fulfils the customer’s tunnelling

Read more ...

The Mumbai-Nagpur Expressway is delayed until 2022. In the meantime, a machine ‘GHH IS26’ with remarkable reliability has been specially flown in from the supplier and is in operation to help complete the project

Read more ...

The project, located at the riverside of the Moscow River, passes under heavy traffic and crowded buildings. It includes two sections of a total length of 2947m. One is from Maple Avenue Station to No.2 Working Shaft

Read more ...

Pull Force is the force that a truck or prime mover can exert onto a transporter or any type of trailer. It has been a subject of much controversy and misunderstandings as truck manufacturers and end-users often do not talk

Read more ...

The first Sandvik DT922i, a computer controlled fully automatic tunneling jumbo, has been introduced by Sandvik Mining and Rock Technology in India with a vision to achieve high levels of safety, productivity and

Read more ...

Horizontal Directional Drilling is a technology in pipe and utility installation that allows greater accuracy and flexibility in placement and ends the need for costly digging, large crews, road closures and other

Read more ...

Special knowledge is required for building tunnels and wind energy plants in order to implement demanding projects. The facilities and manufacturing processes required for such projects can be adjusted well in advance for

Read more ...

The Large Hadron Collider (LHC) at CERN is the biggest particle accelerator in the world – and growing. To equip the LHC for new, more ambitious experiments in the next decade, the accelerator is currently

Read more ...

The river has its source at over 3000 meters high in the snow-covered Andes. It reaches the Pacific Ocean after 250 km. On its way, it overcomes a considerable gradient and is, therefore, ideally suited to generate electricity

Read more ...

Tan Shunhui, Chairman, CREG, discusses the competitive advantages of the company’s tunneling equipment and solutions, emerging opportunities in developing countries, factors driving its growth and success across

Read more ...

15-meter mega Slurry TBM rolled off the assembly line at CRCHI. The excavation diameter of the equipment is 15.01 m, its total length is about 130 m, total weight is about 4300 t, installed power is about 9755 kW, rated

Read more ...

Being the longest water delivery line in the history of Jilin province, transferring water from Songhua River into Central Jilin Province will transfer the largest capacity of water and cover the largest areas. The water diversion

Read more ...

Sign-up for Free Subscription
'India Construction Week'
Weekly e-Newsletter on Construction Industry
Get the latest news, product launches, projects announced / awarded, government policies, investments, and expert views.
Click here to subscribe.