Creating fit-for-purpose Safe Systems of Work

This article builds on a previous article which appeared in the April 2024 HEJ — titled ‘Limitations with HTMs need addressing’, written by Ashley Morpeth (Eta Projects).1 The HEJ article stated that ‘People often think that because, for example, they can demonstrate compliance with the Pressure Systems Safety Regulations (PSSR) 2000 (i.e. they have a written scheme of examination for relevant systems, and they are inspected at the required frequencies), they have covered all the bases. This isn’t necessarily true’.

The sole requirements of the Pressure Systems Safety Regulations, in relation to SSoW, are contained in Regulation 92 — Examination in accordance with the written scheme — ‘The user of an installed system and the owner of a mobile system shall, before each examination, take all appropriate safety measures to prepare the system for examination, including any such measures as are specified in the scheme of examination pursuant to regulation.’

A legal requirement

Safe Systems of Work should be part of everything we do at work, and are a requirement of the Health and Safety at Work etc Act, under Section 2,3 General duties of employers to their employees, which states: ‘It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees… the matters to which that duty extends include in particular — the provision and maintenance of plant and systems of work that are, so far as is reasonably practicable, safe and without risks to health.’

This is one of five duties contained in Section 2 that are the foundation of health and safety at work. The level of risk exhibited by the system or the task will determine the level of detail of that Safe System of Work. The higher the risk, the more involved, and the more formal, the Safe System of Work will become. This then brings in some of the requirements of the Management of Health and Safety at Work Regulations, in particular Regulation 3 — Risk assessment, Regulation 7 — Health and Safety Assistance and, Regulation 5 — Health and Safety Arrangements.

From this, we can interpret a requirement to assess the mechanical systems for risk, to appoint Authorising Engineers and Authorised Persons (where required), and to look to align the controls on certain mechanical systems with HTM 00.

When discussing the requirement for a health estate-specific Mechanical Safe System of Work, I often get the reply ‘Why reinvent the wheel?’ However, this is not reinventing the wheel. There isn’t a health estates wheel out there. At present, for a mechanical SSoW, there are only pieces out there: spokes, rims, and tyres. It is time now to fit all these pieces together, using appropriate materials, to produce a functioning and specific wheel, suitable for use within the healthcare estate.

What is a ‘a Safe System of Work’?

So, what is a ‘Safe System of Work’? One definition is: ‘A formal procedure which results from systematic examination of a system/task in order to identify all the hazards’. The SSoW defines safe methods to ensure that hazards are eliminated or risks minimised, and:

• Combines materials, people, plant, equipment, task, and environment.
• Must have a logical, well-thought-out approach.
• Should fully identify and document all the hazards, safety precautions, and safe working practices, associated with all activities performed by employees.
• Must be practical, or will be bypassed and ignored.
• Remember non-routine work, as well as normal operations.

The systematic examination could form the basis, for example, of a site survey to look at the risks exhibited by the mechanical systems, and decide what will come under the formal Safe System of Work, and what can be controlled under risk assessments and method statements.

The identification of the systems to be covered under the mechanical SSoW can be problematic. Some obvious ones are such systems as:

• Steam.
• High temperature hot water.
• Medium temperature hot water.
• Compressed gases.

Some others that need consideration are:

• The mechanical aspects of some confined spaces, such as isolation of cold-water storage tanks for the AP Confined Spaces (who may not have the mechanical and electrical isolation competence that an AP Mechanical has).
• The mechanical isolation of medical gas pipeline systems (covered in more detail later in this article).
• Low temperature hot water.
• High-pressure cold-water systems (and what is ‘high’?).
• Sterile service autoclaves, catering equipment, and lab equipment.

As regards procedures and guidance documents, there are a couple of existing documents within the NHS, SHTM 08-08 — Pressure systems: policies and guidance, and HTM 02-01 — Medical Gas Pipeline Systems, which are related to mechanical systems. However, both documents have their limitations in relation to formal SSoW.

SHTM 08-084 sets out guidance intended to allow NHS Boards to implement the PSSR requirements and procedures. It thus has its limitations as a full Safe System of Work document, so should not be considered as a complete SSoW.

Patient safety the key focus

HTM 02-01: Medical Gas Pipeline Systems5 considers patient safety, and not the safety of anyone actually working on MGPS. It says: ‘The purpose of the permit issued under this permit-to-work system is to safeguard the integrity of the MGPS, and hence, patient safety; it is not intended as a permit to protect the safety of individuals operating or working on the system.’ A mechanical SSoW may therefore also need to consider safe isolation of MGPS plant and equipment in conjunction with the AP MGPS. This will need a site protocol to be implemented to ensure co-operation and communication between the two disciplines.

The Ministry of Defence (MoD) also has a Safe System of Work document for Mechanical and Pressure Systems (JSP 375, Volume 3, Chapter 4). This was produced to get away from the old thinking of just ‘boilers and pressure systems’ in relation to PSSR. It was written to include mechanical systems based on risk assessment. However, as regards its use outside the MoD, be aware that the MoD places a caveat in Chapter 46 which excludes all liability of the Crown where the JSP 375 Volume 3 suite of documents is used for any other purpose outside the MoD. Therefore, the document cannot be used ‘as is’, but must be made specific to the non-MoD application. For example, the MoD management structure mentioned within JSP 375 does not exist outside of the MoD.

What is not often understood is the MoD structure of the Joint Service Publications (JSP) in general, and those relating to formal Safe Systems of Work in particular. There is a Chapter 2 — Common Requirements,7 which identifies the generic activities, roles, procedures, and processes that are necessary to meet the requirements of the whole Safety Management System (JSP 375 Volume 3), and the subsequent chapters define the requirements specific to identified significant risk areas. The Chapter 2 document must be referenced whenever using JSP 375, Volume 3 main chapter documents, as they contain information that may not be present in the main discipline chapter. This is generally not followed by those who plagiarise Chapter 4 outside the MoD estate.

Need for a formal procedure

So, that covers the requirement, but how do we get it in place? A formal procedure will inevitably be required. While developing this procedure, reference should be made to HSG 250 — Guidance on permit-to-work Systems.8 This describes good practice in the use of permit-to-work systems, and will help people using these systems to ensure that risks have been reduced to a level as low as reasonably practicable.

The formal procedure should also make reference to HSG 253 — The safe isolation of plant and equipment.9 This publication (free from the HSE website) provides guidance on how to isolate plant and equipment safely, and how to reduce the risk of releasing hazardous substances during intrusive activities such as maintenance. It includes a methodology for selecting ‘baseline’ process isolation standards, and outlines preventative and risk reduction measures. The Combustion Engineering Association has produced its own guidance based on HSG 253, titled BG10 — Guidance on Safe Isolation of Plant and Equipment.10

I will cover isolations in another article, but among the essentials here are accurate and up-to-date schematics, valve labelling, locking-off devices (safety locks, proprietary devices, or chain), temporary safety signs, and the availability of a suitable and sufficient number of accessible valves for isolation and draining/venting/proving.

Correctly resourced and implemented

A procedural document by itself, of course, does not constitute a SSoW; it must be resourced and implemented fully and correctly. This will involve (among other things):

• Communication: during the development of the procedures to ensure they are fit for purpose, and to ensure that it is understood by employees and contractors, and applied correctly.
• The appointment of key personnel (e.g. an Authorising Engineer) to co-ordinate the implementation.
• Assessment, training, and appointment, of enough site staff to undertake the site implementation and day-to-day operation of the SSoW.
• Regular review, monitoring, and audit.

The appointment of an Authorising Engineer Mechanical to assist with the implementation is a vital step in establishing a formal SSoW. Various Safe Systems of Work are currently being developed under the auspices of the IHEEM Health and Safety Advisory Platform (which is also developing other Safe System of Work documents). The progression to a formal document has started, and now will travel the well-trodden consultation, approval, and publication route.

References

1 Morpeth A. Limitations with HTMs need addressing. Health Estate Journal 2024; 78(4): 57-59. https://tinyurl.com/4tvxp6fm

2 Great Britain. The Pressure Systems Safety Regulations 2000. UK Statutory Instruments 2000 No 128: Part II: Regulation 9. The Stationery Office, London.

3 Great Britain. Health and Safety at Work etc Act 1974. Section 2. The Stationery Office, London.

4 Health Facilities Scotland. Scottish Health Technical Memorandum 08-08. Pressure systems: policies and guidance. Scotland: NHS National Services Scotland; July 2014.

5 Department of Health. Health Technical Memorandum 02-01: Medical gas pipeline systems. London, May 2006.

6 Ministry of Defence (MOD) Directorate of Defence Safety and Claims (DS&C). 4: Mechanical Systems — Boiler Pressure Systems. London, 2020.

7 Ministry of Defence (MOD) Directorate of Defence Safety and Claims (DS&C). 2: Common Requirements. London, 2020.

8 Guidance on permit-to-work systems: A guide for the petroleum, chemical and allied industries HSG 250 [online]. Health & Safety Executive, London, 2005. Available from: https://www.hse.gov.uk/pubns/books/hsg250.htm

9 The safe isolation of plant and equipment. HSG 253 [online]. Second Edition. London, 2006. Available from: https://www.hse.gov.uk/pubns/books/hsg253.htm

10 Combustion Engineering Association. Guidance on the Safe Isolation of Plant and Equipment (Ref: BG10). Edition 1. Combustion Engineering Association, 2023.