Pallet Labelling Compliancy
An application paper for pallet labelling. Creating compliant serial shipping container code (SSCC) labels….Pallet Labelling
Archive | May, 2011
A close shave in NZ…confined spaces
BPO Ltd of Hamilton, New Zealand, environmental consultants, purchased a confined space harness, rig and gas detector back in 2001 because it was a requirement of one of their clients. The company undertook confined space training to the AS/NZS standards for the same reason. BPO saw the equipment and procedures more as a competitive edge rather than as a necessity and, for this reason, always followed the procedures and used the equipment. The equipment was always looked after and inspection certificates were kept current. At the time, many companies regarded the whole confined space thing as a bit of an overreaction to the Aquatec disaster in Auckland.
Recently, however, they were working on a site with fermentation vessels. The job was to climb down a 2.5 m manhole and inspect the flow measurement equipment in the bottom of the manhole. They went through the normal preliminary checks of taking the gas detector down to various levels and the readings were all normal. One worker, Geoff, was bigger than the other, Greg, so Greg went down the hole and Geoff became the safety observer.
Greg was already harnessed up so, as soon as the preliminary checks were complete, he clipped himself to the confined space rig and climbed down into the hole. Greg had only been in the work space for a couple of minutes when a flush from a fermenter came down the drain. The site was quite noisy so Geoff couldn’t hear the gas detector alarming but he could see was the lights on the detector flashing, He called out to Greg for about 10 seconds but got no answer. At this point, the training took over and Greg was winched out of the manhole in a not-too-gentle fashion. Once on the surface, it became apparent that this was none too soon. Greg was only semiconscious.
Greg only took a short time to recover. In the meantime, Geoff checked the peaks on the gas detector. The O2 level had dropped from its normal 20.8% to about 15%. When the fermenter flushed out, it flushed the CO2 with it.
Greg said afterwards that shortly after the flush came through, he suddenly couldn’t get his brain to work. He could hear the alarm going off but he couldn’t remember what it was for. He couldn’t even figure out what he was doing in this manhole. Then, when he felt the winch start to haul him up he was almost grumpy because someone was disturbing his sleep.
Since this event, BPO has taken confined space entry very seriously. It now has two rigs, three MSA Altair gas detectors, two fan units for air displacement and all staff have regular training. It has also had two more events where staff have been hauled out of the work space although these were minor in comparison to the event above.
John Spokes of MSA Australia has provided some facts regarding this case. “Carbon dioxide (CO2) is predominantly the by-product of fermentation and/or bacterial activity. It is colourless and essentially odourless. At 0.5% of atmosphere it is considered chronically toxic. At 6% CO2 impairs mental capacity and at 10% it is mostly fatal.
“A 6% replacement of air by CO2 reduces O2 levels to 19.6% which may not trigger an alarm.
“The observed alarm indicates the CO2 level may have reached 28%. Without a rescue system in place and quick action, death would have occurred.
“The additional benefit of a mandown alarm to detect an unconscious worker in these circumstances is invaluable.”
“CO2 should be detected directly using accurate, fast CO2 sensors – a fact laboured in the Australian and New Zealand standards.”
Online: www.msa.net.au
Identifying the primary duty holder…
Identifying the primary duty holder under the Work Health and Safety Act….
Supply chain in high school (Trying to Sell)
Supply Chain in High School (Trying to Sell)
by Adrian Gonzalez
May 4th, 2011
“What are you trying to sell?”
That was the question the business teacher at my local high school asked me on the phone, midway through my explanation of why I had emailed her earlier in the day.
I’m not trying to sell anything, I told her, I’m just a parent who’s interested in knowing what, if anything, is being taught at the school about supply chain management, and I’d like to start a conversation about how the curriculum could be enhanced.
She had never heard of supply chain management. She asked me for proof and data that this was indeed an important business topic. And besides, what could she do anyway when the city is eliminating ten high school faculty positions and a dozen programs next year to close a $4.4 million budget gap?
Yes, reality bites.
I received many emails last month in response to my posting about bringing supply chain and logistics down to the high school level (see “A Farm System for Supply Chain and Logistics: Preparing the Next Generation of Leaders”). Most people agreed that making high school students aware of this profession is a good idea. For example, here is an excerpt from one of the emails:
There is a real need to make and present “Supply Chain and Logistics” as a very hot, interesting topic and make it relevant to students in school. I would not have thought that all the summer camps we spent growing produce [were] elements of the SCOR model. We definitely planned when to grow, we sourced it at harvest time, and we took it home and delivered it to our mom to manufacture a JIT meal. The Skinny Jeans kids favor today have a process on how they arrive on the shelf at the local mall. The latest Nike shoe everyone is wearing or craving for has a supply chain story about how it shows up at Foot Locker. Even McDonald’s, Burger King, or the movie theater has a supply chain story, [and so does] the phone [students] are using to text a thousand messages.
In line with the “baseball farm system” concept, other readers felt that focusing on vocational schools or junior/community colleges was equally, if not more, important. Here is an excerpt from a posted comment:
To me, the time to win [students] over is as sophomores or at the junior/community colleges. Students who have a good educational foundation are better prepared to think about careers that will let them excel at areas where they have both strength and interest. Some of the best high school students attend community colleges because they can’t afford the price of the major universities and want to knock out their core curriculum at a more reasonable total cost. If the strong supply chain universities target getting the best community college students to complete their degrees in our field, I think everyone wins.
And another comment sent via email:
When I think about when I started with the Kellogg Company, there are several jobs that come to mind as “entry level”—warehouse loader, unloader, material handler [etc.]. Junior colleges or vocational schools could easily build a curriculum around that by partnering with employment agencies.
It turns out that there are already examples of innovative high school and vocational teaching programs out there.
The folks at RedPrairie, for example, reminded me of the Don Frazier Supply Chain Training Center at the Applied Technology Center (ATC), a career and technical high school in Rock Hill, SC. The Frazier Center was dedicated in April 2009, a partnership between the Material Handling Industry of America (MHIA) and the Material Handling Education Foundation (MHEFI). “This new program,” the press release from 2009 states, “consists of an entry-level educational program for high school, technical and community college students who gain work-related skills and experiences in state of the art, fully-equipped working warehouse and distribution training centers that serves as a laboratory setting for the program across the nation.” Last October, RedPrairie donated an implementation and one-year contract of its On-Demand Warehouse Management solution (WMS) to the center.
Another example: Professor Robert Novack at Penn State is mentoring Sarah Griffith, a teacher at State College Area High School (SCAHS), who is developing a set of supply chain courses for her students. I spoke with Dr. Novack and Ms. Griffith a few weeks ago to learn more about the program.
My immediate takeaway was that the stars were perfectly aligned for this program to get off the ground at SCAHS. First, the school administrator, who knows Professor Novack, already recognized the importance of supply chain management, so he didn’t need to be “sold” on the matter, and he specifically hired Ms. Griffith to develop a supply chain curriculum. Second, a member of the school board has an adult son who works in the supply chain field, so there was already some appreciation for supply chain management and support at the board level too. Third, funding for the position was approved prior to budget cuts. And last, but certainly not least, Ms. Griffith is a young and dedicated educator who has invested a lot of personal time to learn about the topic and get things done with limited resources.
After working on the curriculum last summer, using Dr. Novack’s textbook as a framework, Ms. Griffith introduced “Supply Chain Management 1” this fall to 11th and 12th graders. Forty-five students took the course, with fifteen students on the waiting list. The 18-week course (taught five days a week, 47 minutes per day) covers a broad range of supply chain topics at a high level (no math
involved) and it includes guest speakers and facility tours. The course was over-subscribed in the spring too, so it’s definitely a hit with students. Ms. Griffith is now working with Dr. Novack to develop “Supply Chain Management 2,” which will take a more focused look at fulfillment management.
What am I trying to sell?
Now that I think about it, I guess I am trying to sell something, and I need to be more prepared and savvy about it, because the stars are anything but aligned in my piece of the sky.
Ms. Griffith and Dr. Novack offered some good words of advice, which I’ll summarize this way: I need advocates with influence.
Advocates from the business community, especially large, tax-paying employers in the state that through their voices, actions, and financial investments can provide the best proof to school administrators and boards that supply chain management is indeed important to business.
And advocates from local universities and colleges, particularly those with supply chain and logistics programs, that have a vested interest in getting students interested in this profession in order to attract them to their schools. University professors can serve as mentors to high school teachers, as Dr. Novack and Ms. Griffith illustrate, and they can also influence, as partners in the education system, school administrators and boards to take steps (however small) toward introducing supply chain management into the high school curriculum.
But is the sales effort even worth it? Not bothering is so tempting and easy, and budget cuts and teacher layoffs, while they present daunting challenges, also provide a wonderful excuse to do nothing.
Yes, reality bites. But do we cower and walk away? Bite back? Or change reality?
www.logisticsviewpoints.com
Grants available for workplace safety initiatives
The South Australian Government has recently announced the availability of grants to fund
workplace safety initiatives…
Japanese logistics market by end of Q2 2010
Japanese Logistics Market by the end of Q2 2010
By Mr Pelham Higgins
EXCO Rep (Japan), Supply Chain Asia
Japanese economy
Although the Bank of Japan had recently raised its economic forecast for the current fiscal year, GDP figures for Q2 2010 were disappointing. Japan’s economic growth rate was well short of expectations with real GDP rising an annualized 0.4% in Q2 2010. This was the slowest pace in three quarters compared to a revised 4.4% annualized increase in Q1 2010. Stagnant consumption, slowing industrial production and flagging exports weighed on the local economy which is already struggling with persistent deflation.
Source: Ministry of Economy, Trade and Industry
Japanese Logistics Market by the end of Q2 2010
How to find money for OHS…
It is naive to think employers are going to spend money on anything that is not justified, including OHS, and practitioners in this field need to learn to present a powerful cost-benefit analysis to management. OHS practitioners who ‘do their homework’ and speak the ‘language of management’ will be able to attract funding for occupational health and safety initiatives.
Anyone involved in procuring funds for an investment by a business knows how difficult it is to secure what they believe is needed to get their job done right; and that challenge applies equally to occupational health and safety practitioners. The good news is that the basic risk assessment tool that is so familiar to occupational health and safety practitioners can provide a very sound foundation for a compelling business case for OHS investment. But it is only the foundation. However, a much more business-oriented, five-step process is needed to build a capital expenditure proposal that will resonate with managers and employers.
Step 1: Get hard data
The process should begin with a thorough risk assessment of the business’s workplace that includes hard data to support your case.
Larger businesses may already have their own injury data, but if that is not available to you, statistics gathered by the regulators and Safe Work Australia can be utilised to your advantage. For instance, the Victorian WorkCover Authority and Workplace Health and Safety Queensland
publish industry hotspot information that will help you to identify the likely areas of concern for your business and back that up with data.
Step 2: Analyse the costs and benefits
It is quite normal for senior managers to evaluate expenditure proposals in terms of costs and savings. OHS practitioners must learn to speak that same language. There is also a new legal imperative that provides a compelling argument for investment in safety. From next year, the national work health and safety laws will require employers to demonstrate that they will ensure the health and safety of their workers and others at their place of business, as far as reasonably practicable. So a cost-benefit analysis is an important part of the decision-making exercise. You should use risk management principles that take frequency and severity into account to put a value on the risk of not undertaking the project. You should look at it from every angle – work health and safety projects also often generate measurable savings in terms of productivity.
Step 3: Prioritised recommendations
No business can hope to address every risk instantly. A useful approach is the use of the risk matrix to create a recommended program that systematically addresses high-priority risks.
Step 4: Communicate
Don’t simply email your report to management. Occupational health and safety practitioners have a responsibility to educate employers about risk management. You should talk the plan through with senior management and, if necessary, revise your report to match management expectations.
Step 5: Persevere or find another approach
Many OHS initiatives that are rejected initially are ultimately adopted, so perseverance is important. On the other hand, there is often more than one way to address safety hazards and it is also worthwhile reviewing the risk assessment to consider alternative control measures. Employers also need to be aware of the industry standard for managing the hazard and need to keep abreast of new control measures.
Of course, a lot of safety initiatives require little or no capital expenditure. Many injuries result from unsafe behaviour that stems from the attitudes and actions of managers. Workers take their cue from what managers say and do, rather than what is in the policy handbook. Perhaps the most lasting investment any organisation can make is to ensure the behaviour of its managers is consistent with its values.
*Steve Griffiths is the Principal Work Health and Safety Consultant for the Chamber of Commerce and Industry Queensland. The Chamber will present a free seminar at the Queensland Safety Show on June 22 that explains where to find grants and other funding for OHS, how to budget and how to be sure of a return on investment.
www.safetysolutions.net.au
Validating critical processes…are you covered?
A QUESTION OF VALIDATION
There are a number of processes in the Pharmaceutical, Life Science and Food industries
that require validation. It isn’t only the validation mandated by the myriad of
government regulations, it’s also a smart business practice to validate critical parts of
the manufacturing process for any business that may at some time be scrutinised by a
health department or by a drug administration department or even by the media in the
case of a food poisoning outbreak. In extreme cases these incidences have lead to
businesses having to close. So let’s look at some of the processes in a manufacturing
facility that may require some form of validation, then at the end of this paper we can
look at cost effective ways of achieving validation.
Australia to heed safety standard deadlines
The European Commission has extended the deadline for the transition from standard EN 954-1 to standards EN ISO 13849-1 and EN/IEC 62061. Gary Milburn, Rockwell Automation Area Manager – Safety, explores the implications to Australia’s industrial community.
In recent times, the functionality of industrial machinery has advanced considerably. Industrial processes are being continually enhanced with more sophisticated PLC-based technologies capable of driving throughputs and product quality to levels never thought to be possible. As a result, the functional safety standards that govern the manufacture and safety rating of such machinery and their components are evolving to accommodate the latest technological advancements. Machine builders and component manufacturers must be vigilant, and remain up to speed with changes to performance requirements and the standards that specify them.
For Australian companies – especially those with export activities – of particular interest is the impending transition from EN 954-1: 1996 ‘Safety of Machinery, Safety related parts of control systems’, to the newer EN/ISO 13849-1: 2008
‘Safety of Machinery – Safety related parts of control systems’, and EN/IEC 62061: 2008 ‘Safety of machinery – Functional safety of electrical, electronic and programmable electric control systems’. Recently, the European Commission extended the three-year transition period out to five years, revising the deadline to conform to EN/ISO 13849-1 to 31 December 2011.
With the complete withdrawal of EN 954-1 now inevitable, its continued use alone is destined to become problematic in Europe and closer to home. The soon-to-be-superseded standard is not suitable for some of the more advanced technologies that are commonly used in modern machine-control applications and safety products. In fact, the impact of the impending switchover is now being felt, with many machine-specific (C type) standards already calling for compliance with EN/ISO 13849-1 and EN/IEC 62061, with no reference to EN 954-1. Importantly, this transition has implications reaching farther than in Europe alone – Australian machine builders and component manufacturers must also prepare.
Setting the standard
In order to plan a logical course through the transition to these new standards, it is important to realise that the change affects two fundamentally different user types: the designers of safety-related subsystems, such as controller and component manufacturers, and the designers of safety-related systems, such as machine builders. Soon – if not already – working to EN 954-1 will be considered unacceptable by both groups.
In contrast to EN 954-1, EN/ISO 13849-1 and EN/IEC 62061 have been structured to accommodate the design of more sophisticated safety control system applications. In fact, EN/ISO 13849-1 is fated to become the most commonly used standard for all machine safety control systems, including complete systems, subsystems or individual components.
Both EN/ISO 13849-1 and EN/IEC 62061 incorporate a ‘probability of failure’ assessment calculation – a feature lacking in EN 954-1. Here, a performance level (PL) is assigned once a range of requirements is satisfied.
These include:
reliability data for all system components; diagnostic coverage (DC) of the system; software requirements; and protection against common-cause failure and systematic faults. It is important to note that the Category rating system will be retained.
The new standards require control system designers to calculate the performance level of their safety circuits so that the safety-rated control systems provide adequate integrity. Product-specific functional data from component suppliers may then be used in conjunction with tools such as the SISTEMA Performance Level calculation tool from IFA (formerly BGIA – the Institute for Occupational Safety and Health of the German Social Accident Insurance) to confirm that the PL rating has been achieved. For Australian machine builders and component providers, the early adoption of these newer functional safety standards is likely to yield long-term benefits.
Attention exporters
At present, Australian industry has adopted standard AS 4024.1 2006 ‘Safety of Machinery’. However, like EN 954-1, AS 4024.1 does not incorporate a probabilistic component, or require the designation of a PL. While compliance with AS 4024.1 will suffice (for the time being) for machinery destined for local use, it is a different story for local machine builders and component manufacturers with European export operations, as well as those with export aspirations.
Even though compliance with EN 954-1 is technically acceptable until the end of 2011, overseas purchasers of Australia-made machinery are more likely to demand compliance with EN/ISO 13849-1 in order to future-proof their investments. If local machine builders and component manufacturers have not already implemented internal systems to comply with EN/ISO 13849-1, or begun this process, then international purchase orders may be lost.
Interestingly, ISO 13849-1 was published in 2006, which means machine builders and component manufacturers have already had four years to bring their systems up to speed. The recent time extension to comply with the new
standards indicates that a significant number of industrial businesses and machine type C standards were not yet in a position to comply by the original 31 December 2009 deadline.
Anecdotal evidence has suggested that complying with the new standard has comprised more work on its initial implementation than first anticipated. This is especially true for small- and medium-sized machine builders with limited resources. Here, machine builders are potentially required to change their processes and designs to satisfy the new requirements. As a result, it would be prudent of Australia-based businesses to learn from the oversight of some of their European colleagues and begin the process of complying with EN/ISO 13849-1 sooner rather than later.
Global opportunities
There is the very real potential for the requirements that are outlined in the EN/ISO 13849-1 standard to become those specified in the Australian marketplace. Furthermore, with electromechanical and electronic control systems converging at a rapid rate, and the adoption of a quantifiable methodology, it makes sense for such a global harmonisation of functional safety standards to take place.
However, in the ever-changing field of functional safety standards, many businesses do not have the resources to keep abreast of new requirements, let alone to execute them in a systematic way. While the adoption of EN/ISO 13849-1 and EN/IEC 62061 will throw up some challenges, it will also present a number of opportunities for enterprising Australian companies.
As it becomes more difficult and time consuming for end users to comply, it is likely that they will look to outside contractors and experts for assistance. This presents a business opportunity for companies in this industry, system integrators in particular. By upskilling and positioning themselves as experts in EN/ISO 13849-1 and EN/IEC 62061, system integrators can relieve the workload from machine builders and end users.
Additionally, enterprising solution providers will develop tools that will enable Australian machine builders to comply with these newer standards as soon as possible. Early adopters will not only move ahead of the competition and gain a competitive advantage, they will also help to better protect workers and machinery.
Rockwell Automation has created a library of its safety products and their associated functional safety data. Users can simply drag the product model number into the SISTEMA Performance Level calculation tool and verify PL ratings automatically, a time- and labour-saving innovation. Additionally, documentation produced by this calculation tool provides proof of due diligence of the safety-rated control system design.
To access this library of functional safety data, as well as other safety standard information and tools, visit the Rockwell Automation Safety Solutions portal at
http://discover.rockwellautomation.com/EN_Safety_Solutions.aspx
Liability laws damaging the economy
Liability laws damaging the economy, survey reveals
A recent survey conducted by the Australian Institute of Company Directors revealed that the burden of OHS laws imposing personal liability on directors is stifling business decision-making and having a serious detrimental impact on key aspects of corporate performance.
Business decision-making and strategic focus:
•
More than 90% of those surveyed said that personal liability of directors had an impact on
optimal business decision-making or outcomes.
•
65% said this risk of personal liability caused them or their board to take an overly cautious
approach to business decision-making, either frequently or occasionally. 17% said this
happened frequently and only 15% said it had no impact.
•
79% said they were concerned that the time their board devotes to compliance with
regulations detracts from them focusing on issues like enhancing corporate performance and
productivity.
•
More than 90% said they are concerned about lost time and opportunity costs for companies
defending actions brought as a result of automatic liability for directors under a wide range
of legislation.
Board recruitment and retention:
•
Almost a third said they had personally declined an offer of a directorship primarily due to
the risk of personal liability.
•
More than 22% said they had resigned from a position for that reason.
•
57% said they knew of other directors who had declined an offer of a directorship because
of liability risk.
•
52% knew of someone who had resigned from a board due to liability concerns.
•
Almost three quarters of aspiring directors said the risk of personal liability had made them
reconsider directorship as a career.
Lack of business judgment defences:
•
More than 73% believe there is a medium-to-high risk of directors being found personally
liable for business decisions they made in good faith.
•
54% thought there were no reasonable defences or ‘safe harbours’ for directors making
decisions in good faith – the so-called ‘business judgment rule’.
•
More than 64% said they were seriously concerned about being subject to criminal and civil
penalties as a director.
The survey involved 623 directors from ASX 200 companies, small and medium enterprises and not-for-profit organisations, from across the institute’s membership.
The survey results highlight the impact of personal liability for directors embodied in provisions in hundreds of pieces of legislation at the Commonwealth, state and territory levels. There are more than 700 state and territory laws alone which impose personal liability on individual directors for corporate misconduct. That is, directors are liable simply because they are a director, even where they may not have had any personal involvement in a breach.
Under some legislation, the onus of proof is reversed, removing the presumption of innocence, providing very narrow legal defences and limited rights of appeal.
“This survey, and the previous Federal Treasury survey of ASX 200 directors in 2008, highlights the damaging effect of director liability provisions on our economy,” said John Colvin, CEO of the Australian Institute of Company Directors. “The time, resources and money being taken up with dealing with the risk of personal liability for directors embodied in myriad pieces of legislation around the country is getting in the way of boards doing their real job: making good business decisions which lead to more investment and jobs for Australians.
“It’s also having a chilling effect on board recruitment and retention. The survey shows that the burden of legal risk being confronted by Australian directors is stopping qualified people from taking up board seats and causing others to leave through resignation or retirement.
“In this environment, the balance of risk and reward is so tilted that it’s not surprising that many experienced and highly qualified directors are asking – is it worth it?
“This is not just about directors’ self-interest. It is about everyone’s prosperity. By encouraging an overly cautious approach to decision-making, focusing directors’ minds excessively on risk- avoidance rather than on ways to add value, and by discouraging talented people from taking up or holding directorships, these laws stifle business. And that means they undermine our economy, capital investment and job creation.”
The survey respondents singled out OHS legislation, especially in NSW, as a cause of concern, saying these laws influenced decisions about the location of investment and restricted business activity in that state. The institute says that this highlights the need for the NSW Premier, Kristina Keneally, to reconsider her decision to reverse NSW’s commitment to OHS law reform as part of the national harmonisation of OHS legislation.
The institute strongly believes there is a need for a broad-based defence or ‘safe-harbour’ for directors, consistent across Commonwealth, state and territory laws. The defence would be available when directors make commercial decisions in good faith, having informed themselves about the subject matter and having acted in the best interests of the company.
If directors’ actions meet the criteria, they should not, with benefit of hindsight, be liable for errors of business judgment. Such law reform would enable the majority of directors, who carry out their duties diligently, to better focus on strategic decision-making, thereby enhancing company performance and economic prosperity more broadly.
The survey results also highlight the need for the Commonwealth and states to complete their legislative reviews to reform and harmonise laws on director liability after conducting audits of their legislation on the basis of benchmarks agreed by the Ministerial Council for Corporations.
However, Colvin comments that there appears to have been too little progress on this process, which has been given low priority by state and territory governments. He stated that this reform was urgently required.
http://www.safetysolutions.net.au/articles/44388-Liability-laws-damaging-the-econo… 25/11/2010
