Safety Management System (SMS)

By Andy Begg and edited by Paulo Siqueira

A New Resource on Our Website.

As part of our ongoing commitment to Safety, we are introducing a new section on SAFEX website dedicated to the Safety Management System (SMS). This article provides a brief introduction to SMS and outlines the structure you will find on the website.

What is a Safety Management System - SMS?

When conducting safety audits, one of the first questions I ask clients is:
“Do you have a Safety Management System? If so, can you provide a copy for review?”
The responses vary widely—from a confident "Yes" to a puzzled look. Some clients are unfamiliar with the term, while others may present a collection of safety-related documents, such as operating procedures and incident reports, without a clear structure. So, what exactly is a Safety Management System? There are many definitions, but one of the simplest is: In An Occupational Safety Management System (OSMS) is a structured framework designed to manage occupational safety and health risks in the workplace. 

In essence, an SMS is the backbone of an organization’s approach to safety, ensuring that operations meet specific, agreed-upon safety requirements.

What About Health (H) and Environment (E)?

Often the SMS will include H and E in a combined SHE management system but this depends on the organisation. The structure and format of separate S, H and E systems will generally be the same in any case.

In the SAFEX website we will be using the term SMS as an umbrella term to include S, H and E systems. However, the focus will be on Safety, as it remains a critical aspect of operational success and risk management.

What does an SMS look like?

Traditionally the SMS would be in the form of a multi-section hard copy manual but today will more often be in electronic form.
An SMS can be considered to answer the questions “What” and “How”:

1. What is required to be done?

This will be a collection of specific topics such as policies, standards, procedures, systems, regulatory requirements…contained in a manual or perhaps a series of manuals. Different organisations will have different ways of doing this. The OSHA PSM manual is a good example of these requirements.

2. How will it be done?

This is the tricky one as it depends on the actions of people to “do the job correctly”. It includes ensuring people have sufficient knowledge and training to implement the specific requirements above. It requires validation that this is happening and action plans to address any issues identified.

As simple as possible

The SMS is a tool to help everyone in the organisation ensure a safe workplace for everyone yet it can easily become a bureaucratic nightmare by excessive documentation and organisation requirements. One such system I am familiar with has almost 500 pages! The basic SMS should be kept as simple as possible but it can be supported by detailed technical manuals for specific pieces of equipment or operations as required.

Sections for website SMS

The SMS manual is the source of information on the organisation’s policies and procedures to help personnel maintain a safe working environment. The format and content of the manual will also reflect internal systems and the Mission, Vision, Values and ultimately the Culture. However, the format is less important that the quality of the procedures and the actions of personnel to ensure they are fully implemented and monitored to meet the Mission etc. There is no “one size fits all”. SMSs within an organisation tend to change with time/events and these changes usually involved adding more elements and/or detail to the existing system.

However, caution has to be exercised to ensure that the system does not become unworkable due to its demands and complexity. When this does happen, the system can lose credibility and become less effective. This can be witnessed in “paralysis by analysis” where so much information is required in SHE reporting and action tracking that focus on critical SHE items gets lost. This can result at best in that unsafe conditions go unnoticed and at worst an incident occurs.

A typical SMS format is shown below in the form of a continuous improvement cycle.

SMS Management System

The cycle starts with SMS policies (in some countries the definition of “policy“ will be different)

SMS Policy

The high level SMS Policy or Statement of Commitment to SMS will define the key corporately mandated SMS requirements. These will typically be in the form a statement approved by the CEO that commits the company to a number of specific requirements such as setting safety of personnel and operations as the priority, compliance with all relevant regulations, providing a safe working environment, conducting operations to minimise their environmental impact and so on.

SMS Standards

(These are sometimes referred to as “policies” or “elements”)
The SMS standards can specify what must be managed in order to achieve or comply with the Policy. These will usually be aimed at providing a safe working environment at all times and therefore will require risk assessments, safe operating procedures, permit to work, training, occupational health assessments, incident reporting and investigation, safe driving, working at height, working on customer sites, contractor safety - - - --. The ultimate list of specific requirements can be large and most SMS’s try to group these requirements into a smaller number of key standards. For example, in the OSHA PSM system there are 14 “Elements” which equate to the Standards.
The 14 elements of OSHA's Process Safety Management (PSM) are:

• Employee participation Process safety information
• Process hazard analysis Operating procedures
• Training Contractors
• Pre-startup safety review Mechanical integrity
• Hot work permit Management of change
• Incident investigation Emergency planning and response
• Compliance audits Trade secrets

Each of these elements may have several specific procedures that must be complied with. For example, Operating Procedures includes not just routine plant operation from start-up through operation to shut down, emergency shutdown, start-up after an emergency shut down but also many non-routine tasks including work at height, breaking into process lines under pressure, working on live conductors, lock out/tagout to decontamination explosive plant items - - - - -.
Implementation of PSM is an OSHA requirement for may operations in the USA and may be adopted by others.
Another general chemical SMS is the Responsible Care Management System (RCMS originally developed by the American Chemistry Council and is a voluntary programme that focusses on the following elements:

• Community awareness and emergency response
• Distribution
• Employee health and safety
• Pollution prevention
• Process safety
• Product stewardship

As with PSM each element has multiple specific requirements.
However, most other countries have regulatory SMS requirements that may not be specifically grouped like PSM or RCMS. It is up to the individual companies to decide how to implement the necessary procedures.

In the continuous improvement model described above the original system was developed by a very large global chemical company that included several ammonium nitrate and explosives manufacturing divisions – the system was therefore very comprehensive. That system is still the basis of the SMSs of several large explosives companies today.

A typical chemical industry SMS will cover many if not all the PSM requirements but will not address in detail the specific hazards associated with manufacture and handling of explosives so these have to be added as required – such as equipment decontamination and destruction of explosives, management of FISH, detonation traps and so on. A comprehensive BOS programme will address these issues so BOS is added to the “Standards”

Model Procedures

The Model Procedures are documents that help personnel to prepare specific procedures (SOP) required to meet the “Standard”. These Model Procedures will be based on guidelines that may include current industry good practices, regulatory requirements, company requirements, codes of code practice other companies and industry associations such as SAFEX, FEEM, IME etc

Local Procedures

Local procedures are the specific methods or instructions for performing specific tasks, jobs or operations based on local interpretation of the Model Procedure. They will also be used as the basis for training personnel on specific jobs
The cycle continues with the operation being done as per the SOP

Audit

The cycle is continued by audit of the activity to assess how well the SOP is being complied with and if there are any weaknesses. This would be regarded as an Operational Audit. Local Procedures should also be subject to audit to ensure they are consistent with current good practices, Codes etc – this would be Specialist Audit.
The effectiveness of the complete SMS will also be subject to audit – Management Audit.
Auditing can range from a simple Job Safety Analysis (JSA) of a specific operation versus the SOP carried out be a supervisor to a comprehensive SMS audit carried out by a team of experienced auditors over several days. Auditing is a skill that should be taught to personnel in all functions at all levels – and not just personnel in a safety department.

Improvement Plan

Any weaknesses identified in audits should generate an action and a plan for improvement.
Review of the improvement plans will identify if there are any issues that need to be addressed by the Policy Group and so the cycle continues.
There are many examples of the systems and procedures described here and some will be found (once they are loaded) in the subsequent sections of the website under the headings such as:

• Policies
• Standards
• Guidelines
• Plant or local procedures
• Maintenance Procedures
• Permit to Work
• Management of Change
• Auditing
• Training
• BOS
• Decontamination of equipment
• Management of waste explosives

In summary, the SMS is a very important tool is helping the personnel in a company, a factory or an operation to provide a safe place of work for every employee and to comply with the relevant regulatory requirements. Every organisation should have one.

Stay tuned as we develop this section, providing valuable insights, good practices, and resources to enhance workplace safety.