Alstom Safety Directives And Zero Deviation Policy
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Alstom Safety Directives and Zero Deviation Policy (former e-Book Instruction 9.2) Reference: <EHS-PRO-007> Version: <00>
Application date: <09/06/2015>
Purpose The purpose of this Procedure is to: 1 Set a framework of application for eleven Alstom Safety Directives focused on highly hazardous activities and their risk control, 2 Define the principles of application for the Alstom Zero Deviation Policy.
Scope Whole Alstom activities worldwide
Responsibilities for the execution of this instruction Accountable for the process: EHS V.P. Responsible for execution: Line management (Site MD / Project MD / Country MD). Contributors: EHS Regional Directors, EHS Metiers, EHS Managers, HR.
Signatures Name
Position
Date
Signature
Written by:
Florence Betton
AT EHS VP
<SEE PRISMA>
Electronic signature Prisma
Verified by:
Mathias Klemptner
<SEE PRISMA>
Electronic signature Prisma
Approved by:
Thierry Best
<SEE PRISMA>
Electronic signature Prisma
AT Human Resources SVP AT Chief Operating Officer
1/7
TRANSPORT
Ref: EHS-PRO-007
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
Contents 1
Applicable documents ............................................................................................................. 3
2
Definitions .............................................................................................................................. 3
3
Key Principles ......................................................................................................................... 4
4
Process ................................................................................................................................... 4 4.1 Alstom Zero Deviation Plan .............................................................................................. 4 4.1.1 Compliance to Requirements .................................................................................. 4 4.1.2 Management of AZDP Directives ............................................................................ 5 4.2 Zero Deviation Policy ....................................................................................................... 5 4.2.1 Stopping the activity .............................................................................................. 5 4.2.2 Unsafe Condition .................................................................................................... 6 4.2.3 Unsafe Behavior ..................................................................................................... 6
5
Attachment 1 – Just and Fair Approach .................................................................................. 6
6
Control Sheet .......................................................................................................................... 7
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
2/7
Ref: EHS-PRO-007
1
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
Applicable documents
The following documents have to be used to execute the process efficiently and are mandatory. Assessment Check-lists EHS-FRM-001 ....................... AZDP Self-Assessment Checklist EHS-FRM-008 ....................... AZDP Directives Compliance Checklists for Formal Assessment AZDP Directives EHS-PRO-011 ....................... AZDP Directive - Risk Management for High-Risk-Activities EHS-PRO-012 ....................... AZDP Directive - Control of Contractors EHS-PRO-013 ...................... AZDP Directive - Lockout Tagout EHS-PRO-014 ...................... AZDP Directive - Electrical Safety EHS-PRO-015 ...................... AZDP Directive - Machine Safety EHS-PRO-016 ...................... AZDP Directive - Work at height EHS-PRO-017 ...................... AZDP Directive - Excavation work EHS-PRO-018 ...................... AZDP Directive - Lifting Operations EHS-PRO-019 ...................... AZDP Directive - Site Vehicle Movement EHS-PRO-020 ...................... AZDP Directive - Rail Vehicle Movement EHS-PRO-021 ...................... AZDP Directive - Work in confined space
2
Definitions Abbreviation or Term
EHS Requirement AZDP AZDP Requirement AZDP Critical Requirement Deviation Life-Saving Rule Unsafe behaviour Unsafe condition
Definition Environment, Health or Safety requirement applicable through an EHS Procedure, Instruction, Work Method Statement or Standard. Alstom Zero Deviation Plan: plan focused on the control of High Risk Activities. Requirement identified in the AZDP Directives. Amongst the AZDP Requirements, some are identified as critical in AZDP Directives and highlighted in bold. They must be applied prior to any other ones A departure from a preventive and or protective measure. One rule defined for each AZDP Directive to summarize the content in a way that is simple and easy to remind for all. Live-Saving Rules are used to widely communicate about the AZDP Directives. Action or omission of worker(s) that is a deviation from the correct and safe way of behaving (ex: standing under a suspended load). Fault with the physical environment, equipment, plant, etc. that is deviation from the correct and safe condition (ex: damaged lifting sling).
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
3/7
Ref: EHS-PRO-007
3
4
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
Key Principles
Most of our Severe Accidents/Incidents and nearly all the fatalities in the past years have involved a limited number of activities known to be very hazardous. Alstom has strict requirements regarding the control of those High Risk activities.
AZDP is the plan focusing on their control. It aims at protecting all our employees and contractors worldwide from the risks they may face when working for Alstom in a factory, a workshop, a project and/or a construction site.
Alstom adopts a Zero Deviation approach regarding High Risk Activities.
Process
4.1 Alstom Zero Deviation Plan The Alstom Zero Deviation Plan consists in: - 11 AZDP Directives focused each one on one High Risk Activity. - Each Directive contains 15 to 30 strict requirements. - Among these requirements a limited number are considered as critical and are shown in bold. They must be applied with full priority. - For each AZDP Directive, a “Life-Saving Rule” summarizes the content in a way that is simple and easy to remind for all. 4.1.1 Compliance to Requirements All sites/projects are required to be compliant with AZDP requirements. Self-Assessment A self-assessment to AZDP Requirements must be led by the local EHS Manager and results posted on Alstom reporting tool on a quarterly basis as a minimum. Formal Assessment A Three Year Audit Plan is defined by Transport EHS in agreement with the Regions to audit sites/projects based on the following criteria: - Each unit is audited at least once every 3 years, - Units with a score lower than 80% are re-audited in the following year, - Units in which a severe accident related to a High Risk Activity took place are re-audited in the following year or even earlier. The audit plan covers at least all Critical AZDP Requirements and can be complemented each year by some other requirements. UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
4/7
Ref: EHS-PRO-007
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
A centrally managed pool of auditors is built to be able to deliver the audit plan. In most cases, an audit is delivered by two Alstom people: one from the concerned Region and another one external to the Region. This system aims at giving an external and different point of view on the activity audited. Check-lists have been developed to facilitate self and formal assessments of the compliance to the AZDP Directives. They are basically a copy/paste of the Group Directives in an Excel format. AZDP formal assessment checklist is derived from self-assessment checklist and focus only on audited requirements (Refer to Applicable Documents). Both assessment and self-assessment are based on field practices as observed by the assessor(s). Any deviation or non-compliance observed triggers a zero score for the corresponding requirement (1=compliant; 0=non-compliant). 4.1.2 Management of AZDP Directives The AZDP Directives are reviewed on a regular basis based on Alstom knowledge of our main risks and to incorporate any lessons learned from severe or potentially severe accidents that would have occurred.
4.2 Zero Deviation Policy When a deviation that could result in a severe accident is observed, it must trigger a systematic reaction. Zero Deviation Policy means: - The concerned activity is stopped immediately, - Causes of unsafe conditions are analyzed and treated , - Causes of unsafe acts are analyzed using a just & fair approach. Depending on the investigation conclusions, sanctions are applied. Violations to safety rules are reprimanded. 4.2.1 Stopping the activity Any person observing a High Risk Deviation (unsafe behavior or unsafe condition) should: - First, remove immediately from the danger any exposed person and stop the job, where safe to do so. - Secondly, inform the relevant supervisor / management about the reason why the job is stopped. Any employee must suspend his/her activity when being himself/herself at risk or because of putting other people in a dangerous situation.
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
5/7
Ref: EHS-PRO-007
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
4.2.2 Unsafe Condition In case of an unsafe condition, activity cannot restart until containment or corrective action has been taken. 4.2.3 Unsafe Behavior If case of an unsafe behavior, the cause for this unsafe behavior must be analyzed using the just and fair approach described in Attachment 1. If violation is confirmed, it is then the responsibility of the relevant manager to follow-up with any disciplinary measures (Verbal warning, Written Warning and Exclusion from site or Stronger/other measures). Disciplinary measures are recorded. The process of disciplinary measures has to comply with local laws & procedures and can’t be in any case a type of discrimination. Local Human Resources is the first “guardian of the rules” and is responsible for putting in place practically disciplinary measures. According to local regulations, local Employee Representatives will be informed officially in due time of the disciplinary measures.
5
Attachment 1 – Just and Fair Approach
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
6/7
Ref: EHS-PRO-007
6
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
Control Sheet
Version 0
Date
Content of Modification First issue under Transport reference and form – written from 09/06/15 Corporate e-book instruction 9.2
Author Florence Betton
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
7/7
Application date: <09/06/2015>
Purpose The purpose of this Procedure is to: 1 Set a framework of application for eleven Alstom Safety Directives focused on highly hazardous activities and their risk control, 2 Define the principles of application for the Alstom Zero Deviation Policy.
Scope Whole Alstom activities worldwide
Responsibilities for the execution of this instruction Accountable for the process: EHS V.P. Responsible for execution: Line management (Site MD / Project MD / Country MD). Contributors: EHS Regional Directors, EHS Metiers, EHS Managers, HR.
Signatures Name
Position
Date
Signature
Written by:
Florence Betton
AT EHS VP
<SEE PRISMA>
Electronic signature Prisma
Verified by:
Mathias Klemptner
<SEE PRISMA>
Electronic signature Prisma
Approved by:
Thierry Best
<SEE PRISMA>
Electronic signature Prisma
AT Human Resources SVP AT Chief Operating Officer
1/7
TRANSPORT
Ref: EHS-PRO-007
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
Contents 1
Applicable documents ............................................................................................................. 3
2
Definitions .............................................................................................................................. 3
3
Key Principles ......................................................................................................................... 4
4
Process ................................................................................................................................... 4 4.1 Alstom Zero Deviation Plan .............................................................................................. 4 4.1.1 Compliance to Requirements .................................................................................. 4 4.1.2 Management of AZDP Directives ............................................................................ 5 4.2 Zero Deviation Policy ....................................................................................................... 5 4.2.1 Stopping the activity .............................................................................................. 5 4.2.2 Unsafe Condition .................................................................................................... 6 4.2.3 Unsafe Behavior ..................................................................................................... 6
5
Attachment 1 – Just and Fair Approach .................................................................................. 6
6
Control Sheet .......................................................................................................................... 7
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
2/7
Ref: EHS-PRO-007
1
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
Applicable documents
The following documents have to be used to execute the process efficiently and are mandatory. Assessment Check-lists EHS-FRM-001 ....................... AZDP Self-Assessment Checklist EHS-FRM-008 ....................... AZDP Directives Compliance Checklists for Formal Assessment AZDP Directives EHS-PRO-011 ....................... AZDP Directive - Risk Management for High-Risk-Activities EHS-PRO-012 ....................... AZDP Directive - Control of Contractors EHS-PRO-013 ...................... AZDP Directive - Lockout Tagout EHS-PRO-014 ...................... AZDP Directive - Electrical Safety EHS-PRO-015 ...................... AZDP Directive - Machine Safety EHS-PRO-016 ...................... AZDP Directive - Work at height EHS-PRO-017 ...................... AZDP Directive - Excavation work EHS-PRO-018 ...................... AZDP Directive - Lifting Operations EHS-PRO-019 ...................... AZDP Directive - Site Vehicle Movement EHS-PRO-020 ...................... AZDP Directive - Rail Vehicle Movement EHS-PRO-021 ...................... AZDP Directive - Work in confined space
2
Definitions Abbreviation or Term
EHS Requirement AZDP AZDP Requirement AZDP Critical Requirement Deviation Life-Saving Rule Unsafe behaviour Unsafe condition
Definition Environment, Health or Safety requirement applicable through an EHS Procedure, Instruction, Work Method Statement or Standard. Alstom Zero Deviation Plan: plan focused on the control of High Risk Activities. Requirement identified in the AZDP Directives. Amongst the AZDP Requirements, some are identified as critical in AZDP Directives and highlighted in bold. They must be applied prior to any other ones A departure from a preventive and or protective measure. One rule defined for each AZDP Directive to summarize the content in a way that is simple and easy to remind for all. Live-Saving Rules are used to widely communicate about the AZDP Directives. Action or omission of worker(s) that is a deviation from the correct and safe way of behaving (ex: standing under a suspended load). Fault with the physical environment, equipment, plant, etc. that is deviation from the correct and safe condition (ex: damaged lifting sling).
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
3/7
Ref: EHS-PRO-007
3
4
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
Key Principles
Most of our Severe Accidents/Incidents and nearly all the fatalities in the past years have involved a limited number of activities known to be very hazardous. Alstom has strict requirements regarding the control of those High Risk activities.
AZDP is the plan focusing on their control. It aims at protecting all our employees and contractors worldwide from the risks they may face when working for Alstom in a factory, a workshop, a project and/or a construction site.
Alstom adopts a Zero Deviation approach regarding High Risk Activities.
Process
4.1 Alstom Zero Deviation Plan The Alstom Zero Deviation Plan consists in: - 11 AZDP Directives focused each one on one High Risk Activity. - Each Directive contains 15 to 30 strict requirements. - Among these requirements a limited number are considered as critical and are shown in bold. They must be applied with full priority. - For each AZDP Directive, a “Life-Saving Rule” summarizes the content in a way that is simple and easy to remind for all. 4.1.1 Compliance to Requirements All sites/projects are required to be compliant with AZDP requirements. Self-Assessment A self-assessment to AZDP Requirements must be led by the local EHS Manager and results posted on Alstom reporting tool on a quarterly basis as a minimum. Formal Assessment A Three Year Audit Plan is defined by Transport EHS in agreement with the Regions to audit sites/projects based on the following criteria: - Each unit is audited at least once every 3 years, - Units with a score lower than 80% are re-audited in the following year, - Units in which a severe accident related to a High Risk Activity took place are re-audited in the following year or even earlier. The audit plan covers at least all Critical AZDP Requirements and can be complemented each year by some other requirements. UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
4/7
Ref: EHS-PRO-007
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
A centrally managed pool of auditors is built to be able to deliver the audit plan. In most cases, an audit is delivered by two Alstom people: one from the concerned Region and another one external to the Region. This system aims at giving an external and different point of view on the activity audited. Check-lists have been developed to facilitate self and formal assessments of the compliance to the AZDP Directives. They are basically a copy/paste of the Group Directives in an Excel format. AZDP formal assessment checklist is derived from self-assessment checklist and focus only on audited requirements (Refer to Applicable Documents). Both assessment and self-assessment are based on field practices as observed by the assessor(s). Any deviation or non-compliance observed triggers a zero score for the corresponding requirement (1=compliant; 0=non-compliant). 4.1.2 Management of AZDP Directives The AZDP Directives are reviewed on a regular basis based on Alstom knowledge of our main risks and to incorporate any lessons learned from severe or potentially severe accidents that would have occurred.
4.2 Zero Deviation Policy When a deviation that could result in a severe accident is observed, it must trigger a systematic reaction. Zero Deviation Policy means: - The concerned activity is stopped immediately, - Causes of unsafe conditions are analyzed and treated , - Causes of unsafe acts are analyzed using a just & fair approach. Depending on the investigation conclusions, sanctions are applied. Violations to safety rules are reprimanded. 4.2.1 Stopping the activity Any person observing a High Risk Deviation (unsafe behavior or unsafe condition) should: - First, remove immediately from the danger any exposed person and stop the job, where safe to do so. - Secondly, inform the relevant supervisor / management about the reason why the job is stopped. Any employee must suspend his/her activity when being himself/herself at risk or because of putting other people in a dangerous situation.
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
5/7
Ref: EHS-PRO-007
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
4.2.2 Unsafe Condition In case of an unsafe condition, activity cannot restart until containment or corrective action has been taken. 4.2.3 Unsafe Behavior If case of an unsafe behavior, the cause for this unsafe behavior must be analyzed using the just and fair approach described in Attachment 1. If violation is confirmed, it is then the responsibility of the relevant manager to follow-up with any disciplinary measures (Verbal warning, Written Warning and Exclusion from site or Stronger/other measures). Disciplinary measures are recorded. The process of disciplinary measures has to comply with local laws & procedures and can’t be in any case a type of discrimination. Local Human Resources is the first “guardian of the rules” and is responsible for putting in place practically disciplinary measures. According to local regulations, local Employee Representatives will be informed officially in due time of the disciplinary measures.
5
Attachment 1 – Just and Fair Approach
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
6/7
Ref: EHS-PRO-007
6
Alstom Safety Directives and Zero Deviation Policy Version: 00
Date: 09/06/2015
Control Sheet
Version 0
Date
Content of Modification First issue under Transport reference and form – written from 09/06/15 Corporate e-book instruction 9.2
Author Florence Betton
UNCONTROLLED WHEN PRINTED – Not to be used before verification of applicable version number This document is the property of AlstomTransport and the recipient hereof is not authorised to divulge, distribute or reproduce this document or any part thereof without prior written authorisation from AlstomTransport Filename :EHS_PRO_007_Alstom_Safety_Directives_and_Zero_Deviation_Policy_v0.doc
7/7
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