In this chapter: how to bring everything covered in this book together into a plan that works: the risk matrix, the annual plan, the daily records, audits and incident investigation. At the end, Meelko's free forms to start recording today.
A plan, not a binder
Many plants have a "safety plan": a binder a consultant put together, signed once and never opened again. That is not a plan. A safety plan is a cycle that repeats: you identify the risks, decide what to do, do it, check that it was done, and fix what failed.
ISO 45001:2018, the standard for occupational health and safety management systems, is built on that cycle, known as plan-do-check-act (PDCA)1:
- Plan: identify hazards, assess risks, and set objectives and actions.
- Do: train, operate with the defined controls, maintain, and be prepared for emergencies.
- Check: measure, inspect and audit whether what was planned is being done and whether it works.
- Act: investigate incidents, correct the causes, and improve.
OSHA's Recommended Practices (2016) propose seven elements for a safety program: management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, program evaluation and improvement, and communication and coordination with contractors2. It is the same idea in different words.
You don't need to be certified to any standard to work this way. A small plant can run the cycle with a spreadsheet, a whiteboard and a monthly meeting. What matters is that the cycle keeps turning.
Step 1. The risk matrix
It all starts with knowing what can go wrong and where. Regulations require this under different names:
- The Framework Directive 89/391/EEC requires the employer to assess all risks to workers' safety and health, including those that come from equipment, substances and the layout of workplaces3.
- Argentina's Resolución SRT 905/2015 requires surveying and preparing, for each establishment, a risk map with the analysis and assessment of risks by workstation and the related preventive measures4.
- ISO 45001:2018 covers it in clause 6.1.2, hazard identification and assessment of risks and opportunities5.
How to build it
A simple and widely used method is the likelihood times severity matrix. For each workstation or piece of equipment, you list the hazards, and for each one you estimate:
- Likelihood: how often it could happen (for example, from 1 = very unlikely to 5 = almost certain).
- Severity: how serious the harm would be (from 1 = minor injury to 5 = death or destruction of the plant).
The product sets the priorities. Whatever scores high gets addressed first. The exact method is defined by the health and safety officer; what matters is that it is the same for the whole plant and that it is in writing.
An example of what some rows look like in a wood pellet plant or feed mill:
| Area / equipment | Hazard | Existing measures | Risk | Pending action | Owner | Date |
|---|---|---|---|---|---|---|
| Mill | Caught in machinery while clearing a jam | Fixed guard, emergency stop | High | Written lockout procedure and personal locks | Maintenance supervisor | March |
| Cyclone and filter | Dust explosion | Weekly cleaning | High | Explosion vent study and spark detection | Plant manager | June |
| Raw material silo | Grain entrapment | Entry prohibited | High | Entry permit and rescue equipment | Health and safety officer | April |
| Pellet mill | Noise | Hearing protectors | Medium | Noise measurement by workstation | Health and safety officer | May |
| Bagging | Strain from manual handling | Task rotation | Medium | Assess mechanical aids | Production supervisor | August |
Chapters 3 to 10 of this book are, in practice, a guide to filling in this matrix: dust, machines, electricity, noise, silos, fires, product hygiene, manual handling and protective equipment.
The matrix is reviewed at least once a year, and also whenever a new machine arrives, the process changes, or there is an incident.
Step 2. The annual plan
The matrix tells you what needs to be done. The annual plan tells you when and who. In Argentina, Resolución SRT 905/2015 requires an annual Risk Prevention Program and an annual Training Plan4. Even if your regulations don't require it, it is worth having.
A simple annual plan includes:
- the pending actions from the matrix, with an owner and a date;
- the year's training program (Chapter 11);
- the planned drills;
- scheduled inspections and maintenance of critical equipment: guards, emergency stops, fire extinguishers, detectors, explosion vents, grounding;
- measurements: noise, lighting, dust, as applicable;
- internal audits;
- a monthly follow-up meeting.
The plan has to be realistic. Ten actions that get done are worth more than fifty that stay on paper.
Step 3. Daily records
Records are the plant's memory. They prove that things were done and let you see what is failing before something happens. These are the main ones:
| Record | What it proves | Where we covered it |
|---|---|---|
| Housekeeping | That dust does not accumulate. OSHA 1910.272 requires a written housekeeping program in these plants6. | Chapters 3 and 9 |
| Maintenance | That critical equipment is checked: bearings, guards, magnetic separators, detectors. | Chapters 3, 4 and 8 |
| Lockout/tagout | Who locked out which equipment, when, and who released it. | Chapter 4 |
| Hot work permits | That welding and cutting were authorized and controlled. OSHA 1910.272 requires a permit for all hot work, with some exceptions6. | Chapters 3 and 8 |
| Confined space entries | Who went in, with what measurements, with which attendant. OSHA 1910.272 requires a permit to enter silos, hoppers and tanks, unless the employer or their representative is present for the entire operation6. | Chapter 7 |
| Training | Who is trained and authorized for each task. | Chapter 11 |
| Drills | That the emergency plan was practiced and corrected. | Chapter 11 |
| Receiving of goods | That raw materials were inspected and whatever did not comply was rejected. | Chapter 9 |
| Production and batch traceability | Where each batch came from and where it went. | Chapter 9 |
| Accidents, incidents and near misses | What happened, why, and what was corrected. | This chapter |
For accidents, several regulations require a formal record. The European Framework Directive requires keeping a list of occupational accidents and reporting them to the authorities3. In the United States, OSHA's recordkeeping standard (29 CFR 1904) requires keeping the log of injuries and illnesses (Form 300), the annual summary and the incident reports for five years7. In Argentina, Resolución SRT 905/2015 requires compiling statistics on occupational accidents and occupational diseases4.
Make the record useful
A good record is short, filled in at the time, dated and signed, and someone reviews it. A record filled in all at once at the end of the month, "just to have it," is useless. In an inspection or a lawsuit, it can work against you.
Step 4. Audits and inspections
Checking means looking methodically at whether what was planned is being done. There are two levels:
- Routine inspections. Short, frequent walkthroughs by the supervisor or the health and safety officer, with a checklist: guards in place, exits clear, fire extinguishers charged, accumulated dust, records up to date. The checklists in each chapter of this book can be used to build them.
- Internal audits. More complete reviews, at planned intervals, that check whether the system works: whether the matrix is up to date, whether the annual plan is moving forward, whether the records are real, whether corrective actions were closed. ISO 45001 requires them in clause 9.25. Ideally, they should be done by someone other than the person directly responsible for the audited area.
On top of this come external audits: the insurer, the labor authority, the health authority, customers. Each external finding is handled the same way as an internal one: it is recorded, assigned and closed.
Company management should review the results of the whole system at least once a year: incidents, audits, progress on the plan, and objectives. ISO 45001 calls this management review (clause 9.3)5. Next year's plan comes out of that review.
Step 5. Incident investigation
Every accident, and also every near miss, is information the plant paid dearly for or was lucky not to pay for. Investigating it is the only way to make use of it.
- ISO 45001 requires reporting, investigating and correcting incidents and nonconformities, and verifying that corrective actions were effective (clause 10.2)5.
- OSHA recommends that the purpose of an investigation should always be to identify root causes, and that near misses be investigated too8.
- In Argentina, Resolución SRT 905/2015 assigns the health and safety service the task of investigating accidents using the cause tree method or a similar one, identifying the causes and the corrective and preventive measures to keep them from happening again4.
How to investigate
- Respond first. Help the injured, secure the area, and notify the right people.
- Preserve and document. Photos, equipment condition, positions, the day's records.
- Interview. The injured person, the witnesses and the supervisor, separately and without looking for someone to blame.
- Find the causes. Don't stop at "the operator wasn't careful." Ask why, several times: why did they reach in, why wasn't the machine locked out, why wasn't a lock available, why had nobody noticed.
- Correct. Define actions with an owner and a date, and add them to the annual plan.
- Verify. Check afterward that the action was done and that it worked.
- Share. Tell the rest of the staff what happened and what was changed.
An investigation that ends in a penalty and nothing else teaches only one thing: don't report. One that ends in a real change teaches that reporting is worth it.
How to get started
If your plant has none of this, don't try to do it all at once. One possible order:
- Walk through the plant with the checklists from chapters 3 to 10 and write down the most serious risks.
- First solve what can kill someone: accumulated dust, silos, machine lockout, electrical panels.
- Start recording today: daily check, cleaning, maintenance, receiving.
- Build the matrix and the annual plan with a professional.
- Do the first internal audit at six months and the first management review at one year.
Meelko's free forms
So that daily records don't depend on a loose sheet of paper, we at Meelko prepared four free forms. You fill them in online and download them as PDF with a free account:
- Daily plant check: https://meelko.net/tools/daily-plant-checklist/
- Receiving inspection of goods: https://meelko.net/tools/goods-receiving-inspection-form/
- Pellet mill preventive maintenance: https://meelko.net/tools/pellet-mill-maintenance-checklist/
- Pellet quality control: https://meelko.net/tools/pellet-quality-control-sheet/
They cover four of the records in this chapter and are a good starting point. The others (permits, training, incidents) are defined by your health and safety officer according to your country's regulations.
Chapter checklist
- Do we have a risk matrix by workstation and by equipment, written and reviewed this year?
- Is there an annual plan with actions, owners and dates?
- Is there a regular meeting to follow up on the plan?
- Do we keep records of housekeeping, maintenance, lockout, hot work, confined space entries and training?
- Are records filled in at the time, and does someone review them?
- Do we record accidents, incidents and near misses?
- Is every accident investigated for root causes, with corrective actions that are verified?
- Do we carry out routine inspections with checklists?
- Was there at least one internal audit in the past year?
- Does management review the results once a year and set the next plan?
What to leave to a professional
The risk matrix, the annual plan, the training program and the investigation of serious accidents must be handled by a qualified health and safety professional who knows your country's regulations and your plant. In Argentina, for example, regulations assign several of these tasks to the establishment's health and safety service. If you decide to implement or certify ISO 45001, it is also worth getting advice.
At Meelko, we support our customers from the plant project through day-to-day operation, and the free forms are part of that support. If you want to review your project or your plant, tell us about your project.
Chapter sources
- ISO 45001:2018, Occupational health and safety management systems — Requirements with guidance for use. On the PDCA cycle in the standard: https://www.dqsglobal.com/en/explore/dqs-knowledge-center/iso-45001-explained — CEN information sheet: https://www.cencenelec.eu/media/CEN-CENELEC/AreasOfWork/CEN%20sectors/OHS/Intro/iso45001_information-sheet_2018.pdf ↑
- OSHA. Recommended Practices for Safety and Health Programs, 2016. News release: https://osha.gov/news/newsreleases/trade/10182016 — The seven elements: https://www.osha.gov/safety-management ↑
- Council Directive 89/391/EEC (Occupational Safety and Health Framework Directive), employer obligations: risk assessment and list of occupational accidents. EU-OSHA summary: https://osha.europa.eu/es/legislation/directives/the-osh-framework-directive/1 ↑
- Superintendencia de Riesgos del Trabajo. Resolución SRT 905/2015. Annex I, items 2, 13 and 15; Annex II, items 1, 4, 9 and 12. https://www.argentina.gob.ar/normativa/nacional/246509/texto ↑
- ISO 45001:2018, clauses 6.1.2 (hazard identification and assessment of risks and opportunities), 9.2 (internal audit), 9.3 (management review) and 10.2 (incident, nonconformity and corrective action). Clause titles as given in the ISO 45002:2023 guide: https://iteh.es/catalog/standards/sist/9cb2cda4-5ce4-4d52-a2fe-099a14d7cabe/sist-iso-45002-2023 — Summary of requirements: https://www.mangoapps.com/compliance-library/iso45001 ↑
- OSHA. 29 CFR 1910.272, Grain handling facilities, paragraphs (f) Hot work permit and (g) Entry into grain storage structures; housekeeping program. https://www.law.cornell.edu/cfr/text/29/1910.272 ↑
- OSHA. 29 CFR 1904.33, Retention and updating. https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.33 ↑
- OSHA. Recommended Practices — Hazard Identification and Assessment, action item 4: investigate incidents. https://www.osha.gov/safety-management/hazard-Identification ↑
