Appendix 8 – Systematic Shipboard Occupational Health and Safety Evaluation

1 Tools that may help with programme evaluation include:

.1 trend analysis of fatality, injury, illness and “near miss” incident statistics;
.2 trend analysis of records of “unsafe acts or behaviours”;
.3 review of vessel safety committee reports and recommendations; and
.4 review of hazardous condition notifications and abatement actions.

2 Performance measures that may assist in programme evaluation include:

.1 lost time incident rate;
.2 fatality rate;
.3 acute toxic exposure incidents per 1,000 employee work hours;
.4 number of non-conformities with standard operating procedures per 100 employee work hours;
.5 percentage of training required by SOHSP completed on schedule;
.6 percentage of annual respiratory fit testing completed on schedule; and
.7 percentage of annual medical monitoring exams completed on schedule.

3 The following audit tool may be used to evaluate a SOHSP. The elements scored in the audit tool are the first seven elements of a SOHSP. Some elements are further divided into factors that are individually scored. The auditor should objectively score the vessel's SOHSP on each of the individual factors and elements after obtaining the necessary information to do so.

.1 calculate the overall score, after scoring each element, as follows:
- .1 the score for the Management Commitment and Leadership Element is the lower of the two scores of the General and Implementation Factors;
- .2 the score for the Employee Participation Element is the lower of the two scores for the General and Hazard Reporting Factors;
- .3 the score for the Hazard Anticipation, Identification, Evaluation and Control Element is the average of all six Factors; and
- .4 the scores for single-Factor Elements are the scores for the Factor;

.2 the overall score is the average score of the seven Element scores and may be assigned a “verbal” description based upon the score.

Score	Level of Shipboard Occupational Health and Safety Programme
5	Outstanding Programme
4	Superior Programme
3	Basic Programme
2	Developmental Programme
1	No programme or ineffective programme

Attached tables provide the verbal descriptions for the numeric indicators above.

MANAGEMENT COMMITMENT AND LEADERSHIP
General
Management commitment and leadership is a precondition for an effective SOHSP.
1	Management demonstrates no policy, goals, objectives, or interest in occupational health and safety issues on this vessel.
2	Management sets and communicates occupational health and safety policy and goals, but remains detached from all other occupational health and safety efforts.
3	Management follows all occupational health and safety rules, and gives visible support to the occupational health and safety efforts of others.
4	Management participates in significant aspects of the ship's occupational health and safety programme. Such as ship inspections, incident reviews, and programme reviews. Incentive programmes that discourage reporting of accidents, symptoms, injuries, or hazards are absent. Other incentive programmes may be present.
5	Ship occupational health and safety issues are regularly included on agendas of management operations meetings. Management clearly demonstrates by involvement, support, and example – the primary importance of occupational health and safety. Performance is consistent and sustained or has improved over time.

MANAGEMENT COMMITMENT AND LEADERSHIP
Implementation
Implementation means tools, provided by management that include:
resources:
	budget
	information
	expertise/training
	personnel
defined and assigned responsibilities
commensurate authority to carry out responsibilities
accountability
1	Tools to implement an occupational health and safety programme are inadequate or missing.
2	Some tools to implement an occupational health and safety programme are adequate and effectively used; others are ineffective or inadequate. Management assigns responsibility for implementing a ship occupational health and safety programme to identified person(s). Management's designated representative has authority to direct abatement of hazards that can be corrected without major capital expenditure.
3	Tools to implement an occupational health and safety programme are adequate, but are not all effectively used. Management representative has some expertise in hazard recognition and applicable standards. Management keeps or has access to applicable standards on the unit, and seeks appropriate guidance for interpretation of the standards. Management representative has authority to order/purchase occupational health and safety equipment.
4	All tools to implement an occupational health and safety programme are more than adequate and effectively used. Written safety procedures, policies, and interpretations are updated based on reviews of the occupational health and safety programme. Occupational health and safety expenditures, including training costs and personnel, are identified in the vessel budget. Hazard abatement is an element in management (officers/persons in charge/supervisors) performance evaluation.
5	All tools necessary to implement a good health and safety programme are more than adequate and effectively used. Management occupational health and safety representative has expertise appropriate to vessel size and operation, and has access to professional advice when needed. Occupational health and safety budgets and funding procedures are reviewed periodically for adequacy.
EMPLOYEE PARTICIPATION
General
Employee participation provides the means through which those who actually do the work identify hazards, recommend and monitor abatement, and otherwise participate in their own protection.
1	Worker participation in workplace occupational health and safety concerns is not encouraged. Incentive programmes are present which have the effect of discouraging reporting of incidents, injuries, potential hazards or symptoms. Employees/employee representatives are not involved in the shipboard occupational health and safety programme.
2	Workers and their representatives can participate freely in occupational health and safety activities on the unit without fear of reprisal. Procedures are in place for communication between employer and workers on occupational health and safety matters. Workers are able to refuse or stop work that they reasonably believe involves imminent danger. Workers are paid while performing safety activities.
3	Workers and their representatives are involved in the occupational health and safety programme. Involved in inspection of work areas, and are permitted to observe monitoring and receive results. Workers and representatives have access to information regarding the shipboard occupational health and safety programme including occupational health and safety data trend analysis, job task analysis, and industrial hygiene sampling data. A documented procedure is in place for raising complaints of hazards or discrimination and receiving timely employer response.
4	Workers and their representatives participate in workplace analysis, inspections and investigations, and development of control strategies throughout the vessel, and have necessary training and education to participate in such activities. Workers and their representatives have access to all pertinent occupational health and safety information, including safety reports and audits. Workers are informed of their right to refuse job assignments that pose serious hazards to them pending management response.
5	Workers and their representatives participate fully in development of the occupational health and safety programme and conduct of training and education. Workers participate in audits, programme reviews conducted by management or third parties, and collection of samples for monitoring purposes, and have necessary training and education to participate in such activities. Employer encourages and authorizes employees to stop activities that present potentially serious occupational health and safety hazards.

EMPLOYEE PARTICIPATION
Hazard Reporting
A reliable hazard reporting system enables employees, without fear of reprisal, to notify management of conditions that appear hazardous and to receive timely and appropriate responses.
1	No formal hazard reporting system exists, or employees are reluctant to report hazards.
2	Employees are instructed to report hazards to management. Supervisors are instructed and are aware of a procedure for evaluating and responding to such reports. Employees use the system with no risk of reprisals.
3	A formal system for hazard reporting exists. Employee reports of hazards are documented, corrective action is scheduled, and records maintained.
4	Employees are periodically instructed in hazard identification and reporting procedures. Management conducts surveys of employee observations of hazards to ensure that the system is working. Results are documented.
5	Management responds to reports of hazards in writing within specified time frames. The workforce readily identifies and self-corrects hazards; they are supported by management to do so.

HAZARD ANTICIPATION, IDENTIFICATION, EVALUATION AND CONTROL
Anticipation, Identification and Evaluation
Anticipation and identification and evaluation of hazards involves systematic review of vessel and equipment design, review of the vessel and equipment fitness for current conditions and operations, a procurement system that requires consideration of occupational health and safety aspects of items ordered, vessel inspections, exposure assessments, job safety analyses, mechanisms for employees to report hazardous conditions and review of occupational health and safety data and records to identify trends.
1	No system or requirement exists for hazard review of planned/changed/new equipment or operations. There are no requirements to consider occupational health and safety aspect of items purchased for the vessel. There is no evidence of comprehensive inspections for safety or health hazards, exposure assessments, routine job safety analysis or occupational health and safety data trend analysis.
2	The person-in-charge of operation and/or equipment changes considers occupational health and safety implications of the changes, but has not had appropriate training to be able to identify all occupational health and safety consequences of the changes. The person responsible for procurement considers occupational health and safety issues, but has not been trained on hazards that may be encountered. Inspections for occupational health and safety hazards are conducted by vessel and corporate personnel, but only in response to accidents or complaints. The employer has identified principle occupational health and safety standards appropriate for the vessel. Supervisors dedicate time to observing work practices and other occupational health and safety conditions in work areas where they have responsibility.
3	Competent person(s) determine occupational health and safety consequences of proposed changes in high-hazard operations or equipment before the changes occur, and appropriate precautions are implemented. Competent person(s) determine occupational health and safety hazards of all items procured, and appropriate precautions are taken when the item is used. Vessel and corporate personnel with specific training in occupational health and safety hazards conduct vessel inspections. Items in need of correction are documented. Inspections include compliance with relevant regulations, industry standards and practices. Time periods for corrections are set. Current hazard analyses are written (where appropriate) for all high-hazard jobs and processes; analyses are communicated to and understood by affected employees. Hazard analyses are conducted for jobs/tasks/workstations where injury or illnesses have been recorded.
4	Competent person(s) in consultation with a qualified professional determines occupational health and safety consequences of all proposed changes in operations or equipment before the changes occur, and appropriate precautions are implemented. Competent person(s) determine occupational health and safety hazards of all items requested for procurement, identify appropriate substitutions for hazardous items, or ensure appropriate precautions are taken if a substitute cannot be identified. A qualified professional conducted a vessel inspection within the last five years, and competent person(s), trained in items identified by the qualified professional, conduct periodic inspections and appropriate corrective actions are taken promptly. The inspections are planned, with key observations or check points defined and results documented. Corrections are documented through follow-up inspections. Results are available to workers. Current hazard analyses are documented for all work areas and are communicated and available to all employees.
5	Qualified professionals in consultation with certified occupational health and safety professional(s) analyse occupational health and safety consequences of all proposed changes in operations or equipment, identify substitutions if possible or ensure appropriate precautions are implemented as the change occurs. Competent person(s) in consultation with qualified professional(s) or certified occupational health and safety professional(s), as needed, identify occupational health and safety hazards of all items requested for procurement and obtain substitutes for hazardous items. Regular inspections are planned and overseen by certified safety or health professionals. Statistically valid random audits of compliance with all elements of the shipboard occupational health and safety programme are conducted. Observations are analysed to evaluate progress. Documented workplace hazard evaluations are conducted by certified occupational health and safety professional(s). Corrective action is documented and hazard inventories are updated.

HAZARD ANTICIPATION, IDENTIFICATION, EVALUATION AND CONTROL
Control – General
Workforce exposure to all current and potential hazards should be prevented or controlled by using engineering controls whenever feasible and appropriate, work practices and administrative controls, and personal protective equipment.
1	Hazard control is seriously lacking or absent from the vessel.
2	Hazard controls are generally in place, but effectiveness and completeness vary. Serious hazards may still exist. Employer has achieved general compliance with applicable standards regarding hazards with a significant probability of causing serious physical harm. Hazards that have caused past injuries on the vessel have been corrected.
3	Appropriate controls (engineering, work practice, and administrative controls, and PPE) are in place for significant hazards. Some serious hazards may exist. Employer is generally in compliance with voluntary standards, industry practices, and manufacturers' and suppliers' safety recommendations. Documented reviews determining the need for machine guarding, energy lockout, ergonomics programme. Materials handling procedures, blood borne pathogen programme. Confined space entry programme. Hazard communication, and other generally applicable programmes have been conducted. The overall programme tolerates occasional deviations.
4	Hazard controls are fully in place, and are known and supported by the workforce. Few serious hazards exist. The employer requires strict and complete compliance with all applicable regulations, consensus standards and industry practices and recommendations. All deviations are identified and causes determined.
5	Hazard controls are fully in place and continually improved upon based on workplace experience and general knowledge. Documented reviews of needs are conducted by certified occupational health and safety professionals.

HAZARD ANTICIPATION, IDENTIFICATION, EVALUATION AND CONTROL
Control – Maintenance
An effective shipboard occupational health and safety programme will provide for vessel and equipment maintenance, so that hazardous breakdowns are prevented.
1	No preventive maintenance programme is in place; breakdown maintenance is the rule.
2	There is a preventive maintenance schedule, but it does not cover everything and may be allowed to slide or performance is not documented. Safety devices on machinery and equipment are generally checked before each shift.
3	A preventive maintenance schedule is implemented for areas where it is most needed; it is followed under normal circumstances. Manufacturers' and industry recommendations and consensus standards for maintenance frequency are followed. Breakdown repairs for safety related items are expedited. Safety device checks are documented. Ventilation system function is observed periodically.
4	The employer has effectively implemented a preventive maintenance schedule that applies to all equipment. Vessel experience is used to improve safety-related preventative maintenance scheduling.
5	There is a comprehensive safety and preventive maintenance programme that maximizes equipment reliability.

HAZARD ANTICIPATION, IDENTIFICATION, EVALUATION AND CONTROL
Control – Medical Programme
An effective shipboard occupational health and safety programme will include a suitable medical programme where it is appropriate for the nature of the hazards.
1	Management is unaware of, or unresponsive to occupational medical surveillance needs. Required medical surveillance, monitoring and reporting are absent or inadequate.
2	Required medical surveillance, monitoring, removal, and reporting responsibilities for applicable standards are assigned and carried out, but results may be incomplete or inadequate.
3	Medical surveillance, removal, monitoring, and reporting comply with applicable standards. Employees report early signs/symptoms of job-related injury or illness and receive appropriate treatment.
4	Health care providers provide follow-up on employee treatment protocols and are involved in hazard identification and control on the vessel. Medical surveillance addresses conditions not covered by specific standards. Employee concerns about medical treatment are documented and responded to.
5	Health care providers periodically observe the work areas and activities and are fully involved in hazard identification and training.

HAZARD ANTICIPATION, IDENTIFICATION, EVALUATION AND CONTROL
Control – Emergency Preparedness – Planning and Drills
There should be appropriate planning, training/drills, and equipment for response to emergencies.
1	Little or no effort to prepare for emergencies.
2	Emergency response plans for fire, chemical, and weather emergencies as required by regulation are present. Training is conducted as required by the applicable regulation. Some deficiencies may exist.
3	Persons with specific training have prepared emergency response plans. Appropriate alarm systems are present. Employees are trained in emergency procedures. The emergency response extends to spills and incidents in routine operation. Adequate supply of spill control and PPE appropriate to hazards on ship is available.
4	Abandoned ship drills are conducted in accordance no less than annually. The plan is reviewed by a qualified occupational health and safety professional.
5	Vessel personnel with emergency response assignments have adequate training. All potential emergencies have been identified. Emergency response plans and performance are re-evaluated at least annually and after each significant incident. Procedures for terminating an emergency response condition are clearly defined.

HAZARD ANTICIPATION, IDENTIFICATION, EVALUATION AND CONTROL
Control – Emergency Preparedness – First Aid
First aid/emergency care should be readily available to minimize harm if an injury or illness occurs.
1	First aid/emergency care cannot be ensured.
2	First aid/emergency care is available on every shift.
3	Personnel with appropriate first aid skills commensurate with likely hazards on the vessel and as required by applicable regulations are available. Management documents and evaluates response time on a continuing basis.
4	Personnel with certified first aid skills are always available on-ship; their level of training is appropriate to the hazards of the work being done. Adequacy of first aid is formally reviewed after significant incidents.
5	Personnel trained in advanced first aid and/or emergency medical care are always available on-ship.

OCCUPATIONAL HEALTH AND SAFETY TRAINING
General
Occupational health and safety training should cover the occupational health and safety responsibilities of all personnel who work on the vessel or affect its operations. It is most effective when incorporated into other training about performance requirements and job practices. It should include all subjects and areas necessary to address the hazards on the vessel.
1	Vessel personnel depend on experience and peer training to meet needs. Master/person-in-charge/ others in supervisory positions demonstrate little or no involvement in occupational health and safety training responsibilities.
2	Some orientation training is given to new hires. Some safety training materials (e.g., pamphlets, posters, videotapes) are available or are used periodically at safety meetings, but there is little or no documentation of training or assessment of worker knowledge for a given topic. Masters/persons in charge/and others in supervisory positions generally demonstrate awareness of occupational health and safety responsibilities, but have limited training themselves or involvement in the ship's training programme.
3	Training includes regulatory rights and access to information. Training required by regulations is provided to all vessel employees. Supervisors attend training in all subjects provided to employees under their direction. Vessel personnel can generally demonstrate the skills/knowledge necessary to perform their jobs safely. Records of training are kept and training is evaluated to ensure it is effective.
4	Knowledgeable persons conduct occupational health and safety training that is scheduled, assessed, and documented, and addresses all necessary technical topics. Employees are trained to recognize hazards, violations of regulations, and vessel practices. Employees are trained to report violations to management. Training is followed up with performance observation and feedback. All crew – including supervisors and masters/persons in charge – can demonstrate preparedness for participation in the overall occupational health and safety programme. There are easily retrievable scheduling and record keeping systems.
5	Knowledgeable persons conduct occupational health and safety training that is scheduled, assessed, and documented. Training covers all necessary topics and situations, whether addressed in regulations or not, and includes all persons on the vessel (unlicensed personnel to the master or person-in-charge, contractors, and temporary employees). Employees participate in creating ship-specific training methods and materials. Employees are trained to recognize inadequate responses to reported programme violations. Retrievable record keeping system provides for appropriate retraining, makeup training, and modifications to training as the result of evaluations.

RECORD KEEPING
Data Collection and Analysis
An effective shipboard occupational health and safety programme will collect and analyse injury, illness, and “near miss” incident data for indications of sources and locations of hazards, and jobs that experience higher numbers of incidents. By analysing injury, illness and “near miss” incident trends over time, patterns with common causes can be identified and prevented.
1	Little or no collection and/or analysis of injury, illness or “near miss” incident data. Exposure monitoring is not conducted or documented.
2	Injury, illness and “near miss” incident data is collected and analysed, but not widely used for prevention. CG-2692 is completed for all reportable marine casualties. Exposure records and analysis are organized and are available to safety personnel.
3	Injury, illness, and “near miss” incident logs and exposure records are kept, are audited by shore-side management personnel, and are essentially accurate and complete. Rates are calculated so as to identify high-risk areas and jobs. Liability claims are analysed and the results are used in the programme. Significant analytical findings are used for prevention.
4	Shore-side management and vessel master/person-in-charge and supervisors can identify the frequent and most severe problem areas, the high-risk areas and job classifications, and any exposures that exceed relevant or company standards. Data are fully analysed and effectively communicated to employees. Injury, illness and “near miss” incident data are audited and certified by a responsible person.
5	All levels of management and the workforce are aware of results of data analyses and resulting preventive activity. External audits of accuracy of injury, illness and “near miss” incident data, including review of all available data sources are conducted. Scientific analysis of health information, including non-occupational databases is included where appropriate in the programme.

CONTRACT AND THIRD PARTY PERSONNEL
General
An effective occupational health and safety programme protects all personnel on the vessel, including the employees of contractors, subcontractors and third party personnel. It is the responsibility of shore-side management and the vessel master or person-in-charge to address contractor safety and third party safety.
1	Shore-side management and the vessel master or person-in-charge make no provision to include contractors and third party personnel within the scope of the vessel's occupational health and safety programme.
2	Vessel safety policy requires contractor and third party personnel to conform to applicable regulations and other legal requirements.
3	The master/person-in-charge designates a representative to monitor contractor and third party occupational health and safety practices, and that individual has authority to stop contractor practices that expose host or contractor employees to hazards. Management informs contractor and employees of hazards present at the facility.
4	Shore-side management investigates a contractor's occupational health and safety record as one of the bidding criteria. Shore-side management contacts third party personnel management if necessary to correct unsafe third party behaviour.
5	The vessel's occupational health and safety programme ensures protection of everyone aboard including full-time employees, temporary employees, contractors, and third party personnel.

FATALITY, INJURY, ILLNESS AND INCIDENT INVESTIGATION
General
An effective shipboard occupational health and safety programme will provide for investigation of accidents and “near miss” incidents, so that their causes, and the means for their prevention, are identified.
1	No investigation of accidents, injuries, near misses, or other incidents is conducted.
2	Some investigation of incidents takes place, but root cause may not be identified, and correction may be inconsistent. Supervisors prepare injury reports for lost time incidents greater than 72 hours.
3	All “recordable incidents” are documented in a log. Reports are generally prepared with cause identification and corrective measures prescribed.
4	“Recordable incidents” are always investigated, and effective prevention is implemented. Reports and recommendations are available to employees. Trained safety personnel systematically review quality and completeness of investigations.
5	All loss-producing accidents and “near-misses” are investigated for root causes by teams or individuals that include trained safety personnel and employees.