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IMPLEMENTATION PLAN FOR

INITIAL STATUS REVIEW (OSHMS - MS 1722:2011)

IN MY WORKPLACE

1.0 Introduction

1.1 Organisation Profile

The Malaysian Armed Forces is divided into 3 services; Army, Navy and Air Force.

Officers in the Army itself are categorised into General Duty (GD) and Professional Duty (PD).

GD officers are given various appointments and posts throughout their carrier as they progress in

rank and carrier. So does PD officers but appointments and posts are focused on their expertise

in their subject matter. I was commissioned into the Army as a GD officer. After holding

various posts for several years, my current appointment is Training and Program Officer of the

Training Department in the Malaysian Army College (Kolej Tentera Darat - KTD) situated at

Port Dickson.

KTD is responsible to produce Army officers from graduates from the various plethora of

tertiary education institutions. Several courses are run within a year to accommodate the various

categories of Army Officers for the Malaysian Army. The organisation structure is shown in

Figure 1.1A. Basically, KTD is divided into 4 departments which is Administration, Training,

Logistic Support and Examination & Validation. Being part of the Training Department, one of

the main roles of the department is to plan and execute training for the Cadets into competent

Army Officers.

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Figure 1.1A – KTD Organisation Structure

1.2 OSH and OSHMS in KTD?

The Occupational Safety and Health Act 1994 states that it does not apply to the Armed

Forces.1 Although the Armed Forces are not legally binded by the law, KTD acknowledges the

benefit of OSH and promotes a safe and healthy working culture. The effort is demonstrated by

frequent activities of coincidentally integrating safety and health with the overall security of the

camp. There is no precise policy or committee for OSH as per required by OSHA or OSHMS but

the camp security plan and security committee has elements of OSH embedded into it. I’m not

permitted to disclose the full content of the security plan and roles of the security committee but

it is worth mentioning that elements of OSH contained are:

(i) Monitoring building condition and or structure damage.

(ii) Hygiene maintenance of drainage, kitchen, ration stores and dining hall.

(iii) Safety in military vehicle garage (tools and chemical storage, procedures and use

of PPE).

1 “Occupational Safety and Health Act 1994”, Section 1. (3), pg 188.

HQ

Admin TrainingLogistic

Support

Examination

& Validation

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(iv) Military assets (ammunition, pyrotechnics and electronic warfare equipments)

storing procedures and handling in the armory and specialized stores.

(v) Military Doctor report on occupational injuries and post mortem by investigating

accidents and deciding if the injuries can be prevented or genuinely unavoidable (due to

the nature of Army training).

2.0 Objective

The objective of this review is to prepare an ideal implementation plan and method for an

Initial Status Review (ISR) as required by MS 1722:2011. There is no specific arrangement for

an OSHMS present but the coincidental elements of OSH in KTD will be used in the ISR to

determine if the organisation is in place for MS 1722:2011.

3.0 Methodology

Methodology is the manner, method, procedure, way or approach that will be used to

attain, achieve, and accomplish the objective of this review. The method used is analytical and

applied. MS 1722:2011 OSHMS will be analysed in contrast with the current situation in KTD. A

suggested implementation plan and method for an ISR that is deemed suitable for my workplace is then

prepared and applied.

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4.0 OSHMS Guideline (MS 1722:2011)

In the case where no OSHMS exists, the ISR will serve as a basis for establishing an

OSHMS.2 The guideline mentions no specific way of conducting the ISR but rather essential

elements that should be in the ISR process. The elements indicated in the guideline comprise of:

(i) Gathering information.

(ii) Documenting report.

(iii) Report becomes basis for planning and making decisions regarding

implementation of OSHMS.

(iv) Provide a baseline from which continual improvement of the organisation’s

OSHMS can be measured.

5.0 Implementation Plan and Method for Initial Status Review

The implementation plan for the ISR follows the elements mentioned in the OSHMS

Guideline (MS 1722:2011) as shown in the flowchart in Figure 5.0A. The method in context

with the ISR is the various techniques used to gather the necessary information.

2 “Guidelines on Occupational Safety and Health Management Systems (MS 1722:2011)” (2011), pg. 27.

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Figure 5.0A – Initial Status Review Implementation Plan Flowchart

5.1 Review Items

A set of Review Items are listed and used in the ISR. The Review Items created consists

of:

(i) Safety Policy (Figure 5.1A).

(ii) Safety Organisation (Figure 5.1B).

(iii) Safety Committee (Figure 5.1C).

(iv) Safety Training (Figure 5.1D).

(v) Promotion of Safety and Health Awareness (Figure 5.1E).

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(vi) Internal Safety Rules (Figure 5.1F).

(vii) Evaluation of Occupational Hazards (Figure 5.1G).

(viii) Personal Protective Equipment (Figure 5.1H).

(ix) Emergency Preparedness (Figure 5.1I).

(x) Program on Protection of Occupational Health (Figure 5.1J).

(xi) Accident Control and Hazard Elimination (Figure 5.1K).

(xii) Inspection of Hazardous Condition (Figure 5.1L).

(xiii) Accident Investigation (Figure 5.1M).

(xiv) Safety Audit, Review and OSH Plan (Figure 5.1N).

(xv) Continual Improvement (Figure 5.1O).

REVIEW ITEM ITEM 1 : Safety Policy Yes Partially No 1. Does KTD have a safety policy? √ 2. Is the Policy endorsed by the most senior commander? √ 3. Are the HQ commanders committed to occupational safety and health? √ 4. Does HQ encourage staff to work safely and follow safety rules? √ ITEM SCORE 1 1 2

Figure 5.1A - Safety Policy

REVIEW ITEM ITEM 2: Safety Organisation Yes Partially No 5. Is there a safety organisation chart? √ 6. Are there defined responsibilities to appointments for the soldier’s occupational safety and health issues?

√

7. Is there anyone from HQ in charge of occupational safety and health issues? √ 8. Do personnel understand and perform their responsibilities on occupational safety and health?

√

ITEM SCORE 4 Figure 5.1B - Safety Organisation

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REVIEW ITEM ITEM 3 : Safety Committee Yes Partially No 9. Is there a safety committee? √ 10. Do the committee’s duties include inspecting workplaces for safety and health?

√

11. Do the committee’s duties include assistance to accident investigation? √ 12. Do the committee members review the investigation reports? √ 13. Does the committee comprise of representatives from all sub-departments? √ 14. Besides the safety committee, is there a similar functional group serving the same purpose?

√

ITEM SCORE 5 3 Figure 5.1C - Safety Committee

REVIEW ITEM

ITEM 4 : Safety Training to Personnel and Commanders Yes Partially No 15. Are soldiers provided with occupational safety and health training? √ 16. Are cadets provided with occupational safety and health training? √ 17. Are instructors provided with occupational safety and health training? √ 18. Are commanders provided with occupational safety and health training? √ ITEM SCORE 4

Figure 5.1D - Safety Training

REVIEW ITEM

ITEM 5 : Promotion of Safety and Health Awareness Yes Partially No 19. Is there any occupational safety and health program? √ 20. Is there any display of occupational safety and health signage or poster? √ 21. Does HQ actively participate and support the occupational safety and health programs?

√

22. Do personnel actively participate in the occupational safety and health programs?

√

ITEM SCORE 2 1 0 Figure 5.1E - Promotion of Safety and Health Awareness

REVIEW ITEM

ITEM 6: Internal Safety Rules Yes Partially No 23. Does KTD have safety rules? √ 24. Do all personnel know and understand these rules? √ 25. Is there any specific safety rules developed for individual hazardous activities?

√

26. Do all personnel follow the safety rules? √ ITEM SCORE 3 1

Figure 5.1F - Internal Safety Rules

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REVIEW ITEM ITEM 7 : Evaluation of Occupational Hazards Yes Partially No 27. Is there any risk assessment carried out to identify occupational hazards? √ 28. Are there any preventive measures established in accordance with the result of the risk assessment?

√

29. Do the measures include establishing safety method statements, safety procedures and guidelines?

√

30. Do all personnel implement and execute the safety measures? √ ITEM SCORE 4

Figure 5.1G - Evaluation of Occupational Hazards

REVIEW ITEM

ITEM 8 : Personal Protective Equipment Yes Partially No 31. Does KTD refer to any standards for personal protective equipments? √ 32. Are personnel provided with appropriate personal protective equipment? √ 33. Are personnel provided with relevant training about the use and maintenance of personal protective equipment?

√

34. Are personal protective equipments well maintained? √ ITEM SCORE 1 3

Figure 5.1H - Personal Protective Equipment

REVIEW ITEM

ITEM 9 : Emergency Preparedness Yes Partially No 35. Is there an emergency plan? √ 36. Does the plan include fire emergency response measures? √ 37. Are personnel provided with appropriate training for the emergency plan? √ 38. Are emergency drills conducted regularly? √ 39. Are there adequate and sufficient first aid equipment? √ 40. Are there any qualified first aider? √ ITEM SCORE 6

Figure 5.1I - Emergency Preparedness

REVIEW ITEM

ITEM 10 : Program on protection of Occupational Health Yes Partially No 41. Is there a plan to protect the occupational health of personnel? √ 42. Is there an arrangement to monitor the occupational health of personnel? √ 43. Does the occupational health plan include the safe use of chemical? √ 44. Does the occupational health plan include noise control? √ 45. Does the occupational health plan include risk assessment on the work environment such as illumination, air quality and work stress?

√

ITEM SCORE 1 4 Figure 5.1J - Program on Protection of Occupational Health

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REVIEW ITEM ITEM 11 : Program for Accident Control and Hazard Elimination Yes Partially No 46. Are there any risk assessments carried out to identify possible accident control or hazard elimination?

√

47. Does KTD establish safety and health measures in accordance with the risk assessment results?

√

48. Do personnel understand the safety and health measures? √ 49. Are all maintenance procedures provided with occupational safety and health preventive measures?

√

50. Are the accident control and hazard elimination executed? √ ITEM SCORE 5

Figure 5.1K - Accident Control and Hazard Elimination

REVIEW ITEM

ITEM 12 : Program for Inspection of Hazardous Conditions Yes Partially No 51. Are there regular safety inspections conducted? √ 52. Does KTD promptly eliminate the potential hazards identified? √ 53. Are the safety committee and personnel informed on the inspection result? √ 54. Are inspection reports kept for safety performance analysis? √ ITEM SCORE 2 2

Figure 5.1L - Inspection of Hazardous Condition

REVIEW ITEM

ITEM 13 : Accident Investigation Yes Partially No 55. Does KTD investigate all accidents? √ 56. Does KTD investigate all incidents? √ 57. Are investigation results reported in written form? √ 58. Is there any accident / incident trend analysis? √ 59. Does the safety committee participate in the investigations? √ ITEM SCORE 2 1 2

Figure 5.1M - Accident Investigation

REVIEW ITEM ITEM 14 : Safety Audits , Safety Review and OSH Plan Yes Partially No 60. Are safety audits or safety reviews conducted regularly? √ 61. Are safety audits or safety reviews conducted by external parties? √ 62. Are the safety audits or reviews used for reviewing the occupational safety and health management system?

√

63. Are the safety audits or reviews used for preparing occupational safety and health plans?

√

ITEM SCORE 1 1 2 Figure 5.1N - Safety Audit, Review and OSH Plan

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REVIEW ITEM ITEM 1 5: Continual Improvement Yes Partially No 64. Is the occupational safety and health plan reviewed periodically? √ 65. Is there anyone appointed to conduct regular review of the plan? √ 66. Is there an improvement plan formulated after the review? √ 67. Is the improvement plan implemented? √ ITEM SCORE 4

Figure 5.1O - Continual Improvement

5.2 Method of Gathering Information

The Review Items will then be summarized and become the main content of the

documented ISR report. Using the Review Items as a master guideline checklist, several

methods of gathering information are used:

(i) Interview representatives from all levels.

(ii) ISR meetings.

(iii) Conduct workshop to facilitate ISR.

(iv) Security audits and inspections.

(v) Review weapons, ammunition, explosives and pyrotechnics usage log book.

(vi) Identify hazard and risk (HIRARC).

(vii) Review OSH related documents (security policy, manual and procedures).

(viii) Observation.

(ix) Review medical records with assistance from Military Doctor (occupational

injury).

(x) Review equipment maintenance record.

(xi) Review firefighting equipment inspection record.

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(xii) Review building and structure report.

(xiii) Review hygiene maintenance record.

(xiv) Review military vehicle garage log book and storage record.

(xv) Review OSH related minutes of meeting (security meetings).

(xvi) Review standard issue equipments and items to personnel.

(xvii) Review list of logistical items and storage record.

(xviii) Conduct questionnaire.

(xix) Review training syllabus and activities log book.

5.3 Inapplicable Method of Gathering Information

The following method for gathering information was irrelevant to KTD for the ISR

because produces no information or non-existence:

(i) OSH audit.

(ii) List of non conformance report.

(iii) List of summons by authority.

(iv) List of stop work order issued.

(v) Police report from nearest Police Station.

(vi) Report and data from SOCSO.

(vii) Legal register.

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5.4 Document Report

The next important step in the ISR is to produce a report and ensure it is documented for

the next step of OSHMS and future reference. The report would be produced with the standard

generic format with a comprehensive elaboration on the findings and suggestions on approaching

to develop and implement the OSHMS (MS1722:2011). The highlight of the report would be:

(i) Result of the Review Items

(ii) Requirements to fulfill according to the MS 1722:2011 standards.

5.4.1 Result of Review Items

Every question answered with YES will get 1 score, PARTIALLY will get 0.5 score and

NO will get 0 score. Result of the Review Item is calculated and measured using Figure 5.4.1A.

In this case, KTD scored 14 YES and 14 PARTIALLY. Altogether, the Review Item total score

is 21 which indicate that KTD lacks OSHMS elements and assistance is highly needed to plan

and implement MS 1722:2011.

Total Score Result 48-67 Basic accomplishment of existing arrangement and initial requirements for MS

1722:2011 OSH Management System is in place. 28-47 Partial fulfillment of existing arrangement and initial requirements for MS

1722:2011 OSH management system. Still much room for improvement. 0-27 Absence or lack of OSHMS elements in existing arrangement. Assistance is

highly needed to plan and implement MS 1722:2011. Figure 5.4.1A – Review Item Results

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5.4.2 Requirements to Fulfill

The requirements to fulfill are based according to the MS 1722:2011 standard which is

based on the ILO-OSHMS Model as shown in Figure 5.4.2A. An MS 1722:2011 Elements

Register (Figure 5.4.2B) is then created based on the Implementation Framework (Figure

5.4.2C) and Conceptual Sub Element (Figure 5.4.2D) of the OSHMS.

Figure 5.4.2A – ILO-OSHMS 2001 Model used in MS 1722:2011

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NO MS 1722:2011 ELEMENTS ACCOMPLISHMENT STATUS

POLICY 1. HQ must produce a written OSH policy 2. HQ must commit to:

a. Promoting health and preventing accidents, diseases and other occupational health effects. b. Comply with OSHMS guideline (MS 1722:2011). c. Employees or their representatives are consulted when making OSH rules and regulations. d. Provide necessary resources to ensure that all military activities conducted are safe.

ORGANISING 3. HQ determines the responsibility, accountability and authority for

OSH.

4. Have a safety organisation chart. 5. Appoint a dedicated safety committee. 6. Develop competency by having a training plan and awareness

program.

7. Maintain a comprehensive OSHMS documentation. 8. Ensure effective OSH communication.

PLANNING AND IMPLEMENTATION 9. Hazard identification and assessment (HIRARC) is made the basis

of OSH management.

10. Preventive, protective measures from HIRARC must be implemented.

11. Maintain an emergency preparedness and response arrangement. 12. OSH management activities must be planned and monitored

(Management of Change)

13. Develop and document OSH objectives and OSH plan consistent with OSH policy.

EVALUATION 14. OSH management programs must be monitored. 15. Investigate occupational injuries, illness, deaths and their impact on

OSH performance.

16. Carry out periodic audits. 17. HQ must review OSH activities to ensure its suitability, adequacy

and effectiveness.

ACTION FOR IMPROVEMENT 18. Arrangements must be established and maintained for preventive

and corrective actions.

19. Establish continual improvement arrangement (analyse, explore improvement opportunity, create action plan, communicate action plan and monitor implementation plan).

Figure 5.4.2B – MS 1722:2011 Elements Register

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Figure 5.4.2C – MS 1722:2011 Implementation Framework

Figure 5.4.2D – Conceptual Sub-Element in MS 1722:2011

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5.5 End Result of Initial Status Review

At the end of the ISR, the report is finalized comprising of Review Items, Results of

Review Items and OSHMS Requirements to fulfill (MS 1722:2011 Elements Register). The

finalised report will then be the basis for planning and implementing the OSHMS and a baseline

for measuring continual improvement.

6.0 Findings

This ISR Implementation Plan was not executed extensively and comprehensively but a

mock up trial of the Implementation Plan was tested and produced some findings on the extent of

existing arrangement in KTD for an OSHMS. There were still many gaps and room for

improvement but implementing an OSHMS is possible and feasible. The following findings

(KTD OSHMS Approach Comparison and Adverse Repercussion for OSHMS in KTD) can also

be inserted in the ISR report because OSHMS does not exist in KTD.

6.1 KTD OSHMS Approach Comparison

The OSH situation in KTD shows the differences between the current reactive

management approach and the systematic OSHMS (MS 1722:2011) approach can be seen in

Figure 6.1A.

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CURRENT MANAGEMENT REACTIVE APPROACH

SYTEMATIC OSHMS APPROACH

Hazards are dealt with reactively. Hazards can be identified preventively. Risk controls are dependent on commanders and heads of departments.

Risk controls will be described in procedures.

Risk controls are not linked to each other. Risk controls can be linked by a common method.

OSH activity is usually ad hoc and is rarely planned.

OSH activity can be planned ahead and budgeted.

Controls are reviewed after an accident investigation.

Controls can be monitored and reviewed regularly.

OSH responsibilities are not defined. OSH responsibilities and accountability can be defined.

There is no strong foundation of OSH policy to communicate.

KTD can have own OSH policy to communicate.

Figure 6.1A – KTD OSHMS Approach Comparison

6.2 Adverse Repercussion for OSHMS

From the method of gathering information, some foresight of difficulties and

disadvantages of implementing OSHMS can be anticipated3. The summary of negative

repercussions that can be expected include the following:

(i) The difficulty of designing and implementing an OSH management system.

(ii) The need to develop and update extensive management system documentation,

commonly perceived as a sign of excessive bureaucracy.

(iii) The long amount of time required to implement due to excessive documentation

of all activities in the system and implementation of all procedures from a non-existing

solution.

(iv) The implementation of OSHMS as part of an integrated system in which the KTD

3 Danuta Koradecka, “Handbook of Occupational Safety and Health” First edition (CRC Press, 2010), pg. 612.

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quality management system is considered the most essential component, which may

diminish the importance of OSH as perceived by commanders and personnel.

(v) The need to perform time-consuming audits, which may lead to a significant

increase in the stress levels of personnel.

(vi) The need to overcome resistance against changes in KTD. This may cause a

deterioration of work performance.

(vii) Increased focus on compliance with formal OSHMS procedures and decreased

focus on human factors in OSH culture and awareness, such as the need to monitor

personnel’s safety-related behaviours and to involve them in activities to improve OSH.

(viii) Possibly difficult in keeping personnel committed on a long-term basis to

activities geared towards maintaining and improving the implemented OSHMS.

7.0 Suggestions

Although KTD as part of the Malaysian Armed Forces is not binded by law to comply

with OSHA, it is not wrong and can be considered vital to have a tailored self regulatory

OSHMS to suit KTD. Furthermore, it is very desirable to have a certification like MS 1722:2011

accreditation because the high value of benefits includes the following:

(i) Fewer occupational accidents.

(ii) Reduce occupational risks.

(iii) Boost up personnel morale.

(iv) Improve overall performance.

(v) Improve KTD image.

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The adverse repercussion of OSHMS can be alleviated by Management of Change while

indoctrinating the following mindset or principle:

(i) KTD implementing the OSHMS should not hinder work to accomplish the

mission, vision and objective of KTD and geared towards the development of continuous

improvement process.

(ii) Audits should not be viewed merely as examinations to pass or fail, but rather as a

stage in the process of OSH improvement.

(iii) Where possible, external audits (for MS 1722:2011 certification) should be based

on the results of internal audits; this includes considering the possibility of linking

external auditors to teams of internal auditors instead of increasing the total number of

audits.

(iv) The competency of external auditors and internal auditors selected to audit the

OSHMS should be equal by providing sufficient training to the appointed internal

auditor.

8.0 Conclusion

As mentioned in the findings, the extent of existing arrangement in KTD for an OSHMS

is somewhat blurry. Most of the components in the review are based on KTD activities and

programs that coincide with OSH. There are many gaps and room for improvement.

Nevertheless, implementing an OSHMS in KTD is possible and feasible. It is certainly not

wrong to implement MS 1722:2011 and acquire the certification as long as it is practicable. As

far as management systems go, the MS 1722:2011 OSHMS is not any different to the generic

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management system of the Deming Model.4 In reality, there is nothing new in particular as it is

similar to PDCA or even the KTD management system as shown in Figure 7.0A. Therefore, the

ISR could prove as a significantly important launching pad for KTD to implement MS 1722 :

2011 OSHMS and possibly acquire certification in the future.

DEMING’S PDCA MS 1722:2011 KTD MANAGEMENT SYSTEM Plan Policy

Organising Planning

Policy Structure

Do Implementation Procedures Check Evaluation

Audit Supervision

Act Action for Improvement Continuasl Improvement

Review Appraisal

Figure 7.0A – Similar Management Sytems

“Know your enemy and you have won half the battle”

SUN TZU – ART OF WARFARE

“Know your Initial Status Review and you have won half the MS 1722:2011”

ANONYMOUS MALAYSIAN ARMY OFFICER

4 Stephen Asbury and Peter Ashwell, “Health and Safety, Enviromental and Quality Audits: A Risk Based Approach”

First edition (Routledge, 2011), pg. 38.

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REFERENCE

1. Occupational Safety And Health Act 1994 and Regulations. Laws of Malaysia, Act 514.

2. MS 1722:2011 Occupational Safety and Health Management Systems – Requirements

(First Revision). Department of Standards Malaysia.

3. Guidelines on Occupational Safety and Health Management Systems. Department of

Occupational Safety and Health. Ministry of Human Resource.

4. British Standard Occupational Health and Safety Assessment Series 18001.

5. Develop a Systematic Approach to Managing OHS (BSBOHS601B). Department of

Education, Employment and Workplace Relations. Australian Government.

6. Poland OSHMS (PN-N-18000 Standards, 1999).

7. Ahmad Nazmi Bin Mohamed Ali. Lecture Notes. 2012.

8. Ir. Nimi Binti Ahmad. Lecture Notes. 2012.

9. Koradecka N. Handbook of Occupational Safety and Health. First edition. CRC Press.

2010.

10. Ausbury S. and Ashwell P. Health and Safety, Environment and Quality Audits. First

edition. Routledge. 2011.

11. Reese C. D. Occupational Health and Safety Management : A Practical Approach. First

edition. CRC Press. 2009.

12. Mohd Sadin Misnan, Abdul Hakim Mohammed dan Abdul Rahman Dalib. Pembangunan

Budaya Keselamatan di Tempat Kerja. Edisi pertama. UTM Press. 2011.