This is where we expect to be able to demonstrate more about what it is we do.
The many areas within operations are much more focused on the quality side of the standard in terms of operational planning and control, and the design and development of any activities you do in the design phase. The control of your external products and services, and production and service provisions, and how you release your products and services and controlling of non-conforming products or services within the operational activity.
It's important to recognise that within the operational planning controls, hierarchy of controls, and any plans you have in place for emergency and preparedness and response associated to that.
Your operational planning controls back in 6.1, we spoke about what processes you have in place to plan the provision of your products or services. This may be around your project planning, could be around contract management, could be around your manufacturing processes, whatever it is that's associated to your business specific to the products and services.
You've determined what your requirements are, which may be driven purely by a specification, purely by legal requirements, or by customer spec, or industry, or could be even higher than that in terms of the standard you have to achieve.
Then you look to identify within your business how you establish the criteria around how your processes identify how you get your products and services to be at that accepting standard.
What are the resources you need to ensure that your products and services conform to the requirements that you've established?
What controls you do have in place around them?
It could be that it's quite a straightforward activity i.e. going out to a site to service something, the criteria around that may be that it wasn't working, now it is working, or it could be a lot more detailed than that. You could have different steps that are your control elements to determine criteria throughout, for example, a production process. It could be around how you control ovens. It could be how you control coating, so that's much more about process efficiencies, and the methods you use in terms of implementing those controls.
It's also important in here, that part of documented information is relevant, because it shows all the way through the processes, what you've done, what you've planned to do, what you've achieved, and how those bases of what you've achieved compare to the results of what you planned to achieve.
Within your operational planning and control is also how you manage any changes, or improvements. We spoke before about change management, and within the planning phase is the processes or the procedures that you have to manage those changes, it's what actions you've taken. This is where you demonstrate, as part of your operations, how you've actually delivered those changes, those improvements through a change management process.
Within your operational plan and control you've also got to recognise what outsourced processes you need to control. That could be where you have to use a subcontractor to do certain elements, it could be something like design, it could be that they are doing part of the manufacturing, it could be that the service that's being provided is in conjunction with a subcontracting company that you have control over, that's working alongside you, or various elements of that.
This can also include, where you have risk management, health and safety management, environmental management, could be coming from an external source and providing you with guidance and support.
Within operations associated to health and safety is also the hierarchy of controls. Now, I'm not going to go into the detailed elements of this from an audit point of view, except to say that when we deliver this type of training, we often find many organisations don’t recognise the hierarchy of controls, they see that the controls associated to risks within the hierarchy of controls for occupational health and safety and environment, often jump straight to PPE.
Often the controls they see that are required are the PPE measures that are put in place, without considering the fact that that is actually the last level of control that should be put in place. It's almost your last line of defence.
What can you do as an organisation to go further up that hierarchy of control to consider;
· eliminating the hazard,
· substituting the hazard,
· possibly isolating it
so that they're not working in an area where it can bring additional risk.
Engineering controls, technology for example, new equipment, new ways of working, and, of course, additional training and administration and management around that.
I'm not going to go into the details of hierarchy of controls, because that really sits within a dedicated health and safety and environmental management training course. But it is important to recognise that the hierarchy of controls is not just associated to your business only, it is going to also associate with any external businesses that you bring in to work within your facility or work within the site that you have responsibility for, this is for example, when you're procuring contractors.
Let's take an example of bringing a contractor onto site, onto your factory, onto your facility to do an activity. You're inviting them in, and you have control over your site.
You have a number of ways that that control can be passed over, through a permitting process. But it's important to recognise that you have the systems in place to demonstrate these hierarchy of controls, or at least assess that the company that's coming in have the relevant hierarchy of controls and they can show that through their method of demonstrating their processes, their procedures, their permits, their risk assessments, etc.
It’s also important to remember that within management of change, where you are taking this approach as a result of reducing the hazard, whether it's within your facility by your workers or by a subcontracted service, that if changes take place, you look at the broader spectrum of whether those changes in a localised area associated to reducing hazard, can have a greater impact elsewhere.
For example, if a particular activity is done, and it may be that the activity, if it's changed could have a greater impact than other areas within your business from a hazard point of view.
The other thing that's also worth considering is temporary changes.
Where there are temporary activities put in place associated to short term contracted works coming in, how you recognise that in terms of those temporary changes, what additional controls may be required, that it's outside the norm of what you're doing.
Remember, we spoke before about risks associated to normal, abnormal and emergency situations. Where there’s a temporary fix or a temporary activity that's going on, you have to think about that as a slightly abnormal activity. It's not the normal processes that would be going on within your business. It's not the normal processes that would be going on at that site or on that project.
What additional controls do you need to have in place for that?
It may be that you have to isolate certain things while that temporary work is taking place. Those could be emergency controls, associated to fire for example, you may be isolating these to do this temporary work.
What additional controls do you have to put in place to cover those other risks that could be impacted?