Final report salehuddin emoshm 7

IMPROVEMENT OF SELF REGULATORY PRACTICES IN OCCUPATIONAL

SAFETY AND HEALTH MANAGEMENT SYSTEM AND SAFETY PLANNING

AT SHELL OIL REFINERY PORT DICKSON

SALEHUDDIN BIN ABDUL KADIR

A project report submitted in fulfillment of the

requirements for the award of the degree of

Executive Master of Occupational Safety and Health Management

School of Graduate Studies

Universiti Teknologi Malaysia

DECEMBER 2013

ii

DECLARATION

I declare that this thesis entitled “Improvement Of Self Regulatory Practices In

Occupational Safety And Health Management System And Safety Planning At Shell

Oil Refinery Port Dickson” is the result of my own research except as cited in the

references. The project report has not been accepted for any degree and is not

concurrently submitted in candidature of any other degree.

Signature : ..............................................

Name : SALEHUDDIN BIN ABDUL KADIR

Date : 15 DECEMBER 2013

iii

DEDICATION

To my family

Nurshamshida Bt Md Shamsudin

Ayra Natasha Bt Salehuddin

Arissa Hannah Bt Salehuddin

To my parents

Normah Bt Mohamad

Abdul Kadir bin Taib

For the strength to be strong For the will to carry on

For truth that will never change I turn to them

When I lose the will to win -

They’re always giving me encouragement When I’m down –

They’re always pushing me to the top. I can do anything

Cause their love is so amazing

iv

ACKNOWLEDGEMENTS

Highest level of gratitude to:

Allah the Most Compassionate.

My Family.

My Parents.

My Supervisor Prof. Dr. Nik Hasnaa Nik Mahmood.

My Co-Supervisor Nelidya Md Yusof

Hj Musa Mustafa – Shell Refining Company, Port Dickson

Zackaria Abdullah – Shell Refining Company, Port Dickson

Zulkarnain Mohd Said – Shell Refining Company, Port Dickson

Dr. Mohd. Nizam Jemoin – Shell Refining Company, Port Dickson

Rossyu Hazlin Bt. Ab. Rahim – Shell Refining Company, Port Dickson

Ashari Ishak – Shell Refining Company, Port Dickson

Siti Elina Abdul Rahman – MISC Berhad (Validator)

Engineering Safety Officer – Sime Darby (Validator)

Everyone directly involved with this research project.

Everyone indirectly involved with this research project.

v

ABSTRACT

Occupational Safety and Health Management Systems should be constantly

improved to avoid unnecessary incidents that could cause injuries, death and

financial lost by self regulation as required by legislation. Even the leading

Occupational Safety and Health role model which is the oil and gas industry

experience minor and catastrophic incidents. On that note, the project will identify,

examine and improve the current benchmark practice in the oil and gas industry. The

literature reviews was defined, analyzed and synthesized into various themes into a

conceptual framework. This project adopts the qualitative Grounded Theory Method

of open, selective and theoretical coding whilst constant comparison inductive

deductive of Spradley’s Semantic Relationship Criteria method supported by

quantitative descriptive statistics which is suitable for configuring the case study

approach and uses methodological triangulation to analyze data from many sources.

The triangulation method aids to the development of the research design framework

which includes; (1) examining documentation, (2) interview, (3) questionnaire and;

(4) observation. The data analysis from the rich data produces an emerging theory of

THOUGHT PROCESS encompassing compliance rigidness, objectivity,

involvement, financial consideration and additional suggestions. The emerging

theory is integrated into the Occupational Safety and Health Management System

producing an improved management system. This new discovery has potential to

further evolve and mature for the benefit of all stakeholders and the body of

knowledge.

vi

ABSTRAK

Sistem Pengurusan Keselamatan dan Kesihatan Pekerjaan seharusnya

sentiasa diperbaiki untuk mengelakkan kejadian yang boleh mengakibatkan

kecederaan, kerugian harta dan nyawa melalui usaha sendiri seperti yang tertakluk

dalam undang-undang. Industri minyak dan gas yang merupakan pengamal hebat

sistem ini juga mengalami kemalangan yang kecil dan besar. Oleh itu, projek ini

akan mengenalpasti, mengkaji dan menambahbaik apa yang sedang diamalkan oleh

industry minyak dan gas. Kajian lepas dihalusi, dianalisis dan disintesis beberapa

tema kepada sebuah kerangka konsep. Projek ini menggunakan kaedah kualitatif

Grounded Theory iaitu mengekod secara buka, pilihan dan teori sambil perbandingan

berterusan induktif deduktif dari kaedah Spradley’s Semantic Relationship Criteria

yang disokong oleh statistic deskriptif kuantitatif yang sesuai untuk mengkonfigurasi

pendekatan kajian kes dan menggunakan triangulasi metodologi untuk analisa data

dari sumber pelbagai. Ini akan bantu pembentukkan bentuk rangka kajian yang

melibatkan; (1) pemeriksaan dokumentasi, (2) temuramah, (3) kaji selidik dan;

(4) pemerhatian. Analisa data menghasilkan teori THOUGHT PROCESS yang

merangkumi pematuhan teguh, objektif, keterlibatan, pertimbangan kewangan dan

saranan tambahan. Teori ini diintegrasi ke dalam Sistem Pengurusan Keselamatan

dan Kesihatan Pekerjaan menghasilkan sistem pengurusan yang lebih baik.

Penemuan baru ini mempunyai potensi untuk evolusi dan matang untuk kebaikan

semua pihak dan bidang ilmu yang berkaitan.

vii

TABLE OF CONTENTS

CHAPTER TITLE PAGE

DECLARATION ii

DEDICATION iii

ACKNOWLEDGEMENTS iv

ABSTRACT v

ABSTRAK vi

TABLE OF CONTENTS vii

LIST OF TABLES xi

LIST OF FIGURES xii

LIST OF ABBREVIATIONS xivxiv

LIST OF APPENDICES xv

1 INTRODUCTION 1

1.1 Introduction 1

1.2 Background of Problem 1

1.3 Problem Statement 3

1.4 Research Objectives 5

1.5 Research Questions 5

1.6 Scope 6

1.7 Significance of the Project 6

1.8 Definition of Terms 6

1.9 Summary 7

viii

2 LITERATURE REVIEW 8

2.1 Introduction 8

2.2 ‘Funnel’ Analysis 9

2.2.1 Management Theories 10

2.2.2 OSHMS 13 2.2.3 OSHMS Self Regulation 14 2.2.4 OSHMS Issues 16 2.2.5 OSHMS Issues in Oil and Gas Industries 18

2.3 Synthesis 20

2.4 Conceptual Framework 24

2.5 Summary 24

3 RESEARCH METHODOLOGY 25

3.1 Introduction 25

3.2 Research Design 25

3.2.1 Qualitative 27

3.2.1.1 Qualitative Case Study 28

3.2.1.2 Triangulation 29 3.2.2 Quantitative 30

3.3 Population and Sample 31

3.3.1 Sampling for Interview 31 3.3.2 Sampling for Questionnaire 31

3.4 Data Collection and Analysis 32

3.4.1 Examine OSHMS Documentation 33

3.4.2 Interview 36

3.4.3 Questionnaire 37

3.4.4 Observation 38

3.5 Data Analysis 38

3.5.1 Qualitative Analysis 38

3.5.2 Quantitative Analysis 40

3.6 Propose OSHMS Arrangement 40

3.7 Summary 40

ix

4 DATA COLLECTION AND ANALYSIS 41

4.1 Introduction 42

4.2 OSHMS 43

4.2.1 SRC HSEMS 43 4.2.2 Comparison to MS 1722:2011 45

4.3 Qualitative Data Analysis 46

4.3.1 Open Coding 47

4.3.1.1 Documentation 47 4.3.1.2 Interview 50 4.3.1.3 Questionnaire 50 4.3.1.4 Observation 51

4.3.2 Selective Coding 52

4.3.2.1 Compliance Rigidness 52 4.3.2.2 Objectivity 54 4.3.2.3 Involvement 55 4.3.2.4 Financial Implication 56

4.3.3 Theoretical Coding 57

4.4 Quantitative Data Analysis 59

4.4.1 Reliability 60

4.4.2 Descriptive Results 61

4.4.2.1 Compliance 62 4.4.2.2 VMO 63

4.4.2.3 Form 64

4.4.2.4 Policy 65 4.4.2.5 Arrangement 66 4.4.2.6 Implementation 67 4.4.2.7 Financial Implication 68 4.4.2.8 Financial Consideration 69

4.4.3 Overall Descriptive Results 70

4.5 Additional Findings 70

4.5.1 Other Improvement Suggestions from Data 71 4.5.2 SRC Positive Aspects in OSHMS 72

4.6 Summary 73

5 CONCLUSION AND RECOMMENDATION 74

5.1 Introduction 75

5.2 Integration of Findings 76

x

5.2.1 Improvised OSHMS 77 5.2.2 Approach to Implement Improvised OSHMS 78

5.3 Validation 83

5.4 Contribution 83

5.5 Conclusion 84

5.6 Limitations 84

5.7 Implication 85

5.8 Recommendation for Future Work 85

REFERENCES 86

Appendices A - O 91-120

xi

LIST OF TABLES

TABLE NO. TITLE PAGE

2.1 Tabularized Synthesis 20 ..

3.1 Research Type 27 ....

3.2 Case Study Configuration 29 ....

3.3 Triangulation Types 30 ....

3.4 Summarized Sampling Techniques 31

3.5 Examine OSHMS Documentation 34

3.6 Questionnaire Design 37 ....

3.7 Likert-Item Scale 37 ....

3.8 Relationship in Coding 39 ....

4.1 QSR NVivo 8 Functions Used in Coding Process 46 ....

4.2 Themes Identified During Documentation Open Coding 48 ....

4.3 Reliability Statistics 61 ....

4.4 Overall Descriptive Results 61

4.5 Quantitative Analysis Supporting Qualitative Findings 70

xii

LIST OF FIGURES

FIGURE NO. TITLE PAGE

1.1 Distribution of incidents from the WOAD ...................................... 4

2.1 “Funnel” analysis ............................................................................. 9

2.2 Maslow’s hierarchy of needs ......................................................... 10

2.3 Deming’s PDCA cycle .................................................................. 11

2.4 ILO OSHMS elements ................................................................... 11

2.5 OSHMS MS 1722 implementation framework ............................. 12

2.6 OSH strategic drivers for the national OSH master plan ............... 15

2.7 Stability versus flexibility in OSHMS ........................................... 17

2.8 Conceptual framework ................................................................... 23

3.1 Research design ............................................................................. 26

3.2 Triangulation for research .............................................................. 30

3.3 Interview plan ................................................................................ 36

3.4 Qualitative data analysis ................................................................ 39

3.2 Inductive and deductive coding ..................................................... 40

4.1 SRC HSSEMS Visualized Elements ............................................. 44

4.2 Comparison to MS 1722:2011 ....................................................... 45

4.3 Nodes Identified During Open Coding Process ............................. 50

4.4 SRC PD Safety Induction Coding in NVivo 8 .............................. 51

4.5 Generated Model for Selective Coding Skeleton .......................... 52

4.6 Cenerated Model for Compliance Rigidness Selective Coding .... 53

4.7 Generated Model for Objectivity Selective Coding ...................... 54

4.8 Generated Model for Involvement Selective Coding .................... 55

4.9 Generated Model for Financial Implication Selective Coding ...... 56

4.10 Generated Model for THOUGHT PROCESS Theoretical Coding 58

4.11 Pie Chart of Position/Department of Survey Respondents ............ 59

4.12 Pie Chart of Departments of Survey Respondents ........................ 60

4.13 Comply Bar Graf ........................................................................... 62

xiii

4.14 Vision Bar Graf .............................................................................. 63

4.15 Form Bar Graf ................................................................................ 64

4.16 Policy Bar Graf .............................................................................. 65

4.17 Arrangement Bar Graf ................................................................... 66

4.18 Implementation Bar Graf ............................................................... 67

4.19 Finance Bar Graf ............................................................................ 68

4.20 Consideration Bar Graf .................................................................. 69

4.21 Generated Model for Additional Improvement Suggestions ......... 71

4.22 Generated Model for Positive SRC Aspects .................................. 72

5.1 Integration of Findings in SRC HSSEMS ..................................... 75

5.2 Proposed Improvised 6 Step OSHMS ........................................... 76

5.3 HSSEQ Liaison Contact Person – Hj Musa Mustafa on the Left . 84

xiv

LIST OF ABBREVIATIONS

ALARP - As Low As Reasonably Practicable

BS - British Standard

CEO - Chief Executive Officer

CSDS - Chemical Safety Data Sheet

DOSH - Department of Occupational Safety and Health

EQA - Environmental Quality Act

ERP - Emergency Response Plan

FMA - Factory and Machinery Act

HAZOP - Hazard Operability

HIRARC - Hazard Identification, Risk Assessment and Risk Control

HR - Human Resource

HRA - Hazard Risk Assessement

HSSE & SP - Health, Safety, Security, Environment and Social Performance

HSSEMS - Health, Safety, Security and Environment Management System

HSSEQ - Health, Safety, Security, Environment and Quality

ILO - International Labor Organisation

JHA - Job Hazard Analysis

MBO - Management by Objective

MD - Managing Director

MS - Malaysian Standard

MSDS - Material Safety Data Sheet

OHD - Occupational Health Doctor

OHSAS 18001- Occupational Health and Advisory Services 18001

OHSAS - Occupational Health and Safety Advisory Service

OSH - Occupational Safety and Health

OSHA - Occupational Safety and Health Act

OSH-MP 15 - Occupational Safety and Health Master Plan - 2015

OSHMS - Occupational Safety and Health Management System

SHO - Safety and Health Officer

SRC - Shell Refining Company

VMO - Vison, Mission and Objective

WOAD - World Oil and Gas Database

xv

LIST OF APPENDICES

APPENDIX NO. TITLE PAGE

A Interview Questions 91

B Questionnaire Form 92

C Observation Checklist Recording Form 94

D QSR NVivo 8 Generated Project Summary Report 95

E NVivo Nodes Used in Open Coding 100

F Interview Transcript with SHO 101

G Interview Transcript with Head of HSSEMS 105

H Interview Transcript with HR Representative 108

I Interview Transcript with Occupational Health Nurse 111

J Interview Transcript with OHD 113

K Observation Notes for Safety Induction 116

L Observation Notes for HSSE Meeting 117

M Selective Coding in NVivo 8 118

N Validation E-mail from HSE Manager MISC Bhd. 119

O Validation E-mail from Safety Officer Sime Darby 120

CHAPTER 1

INTRODUCTION

1.1 Introduction

OSH has been recognized as a vital element in the working environment at

the global scale including Malaysia. The OSH Master Plan in Malaysia was created

to supplement the national OSH legislative framework and boost the OSH

performance of the country (Ministry of Human Resource, 2001). The national OSH

act states employers must practicably ensure the OSH of its workers (Occupational

Safety and Health Act, 1994). Even a Malaysian standard has been developed as a

choice to implement OSHMS in the workplace (Department of Occupational Safety

and Health, 2011). Locally, the oil and gas industry spearheads the self regulation of

OSH including OSHMS. But unsafe incidents at the international and national level

in the oil and gas industry still occur which proves there are still room for

improvement. Since OSHMS is a universally utilized system used by all, the oil and

gas will be the best platform to further enhance the self regulatory practice for the

benefit of all industries.

1.2 Background

A good implementation of OSH in industries will avoid the loss of lives and

money. There are many integral aspects of OSH such as safety engineering, OSHMS,

system safety, process safety and behavior-based safety. From the many aspects,

2

OSHMS is considered the foundation and backbone of OSH implementation and

directly affect other safety aspects. This integral aspect is applied in industries such

as oil and gas, nuclear power, aerospace, aeronautical, construction and

manufacturing. Consequently, the oil and gas industry being one of the most

dangerous and hazardous industries has become one of the leading industries in

implementing OSHMS.

The oil and gas industry consists of many important organizational roles from

the financial administration to the processing of the oil and gas itself. Among the

several significant components pertaining safety in the oil and gas industry involves:

1. Upstream (exploration, development and production).

2. Downstream (oil tankers and refineries).

3. Pipeline.

4. Marine.

5. Services and Supply

Downstream is considered one of the important components, considering it is

the turning point when extracted crude oil is processed into useable hydrocarbon

products. SRC Berhad of Shell Malaysia is a leading downstream company in

implementing the downstream component winning numerous awards in OSH at the

national and international level. Therefore, it is a great platform to conduct the

research in regards of OSHMS.

All the above components involved are not exempted from implementing a

self regulatory practice of OSHMS. Self regulation is defined here as a regulatory

process whereby an industry sets and enforces rules and standards relating to the

conduct of field in the industry (Gupta, 1986). In the context of Malaysia, it implies

that the primary responsibility for formulation and enforcement of regulatory

standards lies with the organization of the industry with guidance from DOSH. This

gives freedom to organizations to decide and enforce a workable OSHMS within its

capabilities and means.

3

The main objective of OSHMS and safety planning is to provide a holistic

fundamental foundation of the OSH self regulatory practices that will spearhead

OSH at the workplace. Having a good self regulatory practice in OSHMS safety

planning will be the key factor to ensure the success of OSH and fulfill the

requirements of the following:

1. National OSH Master Plan 2015.

2. Laws on OSH - FMA 1967, Petroleum Act 1984 and OSHA 1994.

3. Laws related to OSH - Employment Act 1955, EQA 1974, etc.

4. DOSH legislations - regulations, order and code of practice.

5. OSHMS guidelines - OHSAS, MS 1722, etc.

1.3 Problem Statement

OSHMS is a vital element in managing safety systems for the oil and gas

industry. A weak OSHMS may cause negative implications afterwards. Atherton

and Gill (2008) have noted several devastating international oil and gas industry

incidents such as Bleve LPG France 1966, Whiddy Ireland 1979, Bhopal India 1984,

PEMEX LPG Mexico 1984, BP Grangemouth USA 1987, BP Grangemouth

Scotland 1987, Shell Depot France 1987, Piper Alpha UK 1988, FCCU France 1992,

AVON Tosco USA 1997, ESSO plant Australia 1998, Tupras Refinery Turkey 1999,

PETROBRAS Brazil 2001, Motiva Delaware USA 2001 and BP Texas USA 2005.

Many of these incidents and major accidents have caused fatalities and big financial

lost due to factors involving OSHMS and safety planning in particular.

Christou and Konstantinidou (2012) from the European Commision has

produced a joint research report of world safety in oil and gas operations. The report

uses data from WOAD as being one of the most reliable and most complete

databases of failure, incidents and accidents in the oil and gas sector. From the

analysis, 83% of the hazardous events have caused either accidents or incidents of

hazardous situation as shown in Figure 1.1. One of the findings from the report

4

states clearly that failures of OSHMS are almost always the underlying cause of

major accidents which sometimes relate to design, failure to identify hazards, unsafe

operations or lack of adequate response procedures.

Figure 1.1: Distribution of Incidents from the WOAD 2012

A lot of case studies have been made on the operation of extracting crude oil

from offshore such as the Piper Alpha UK 1998 incident. But another component

that should not be taken lightly is the processing at oil refineries. Incidentally, many

of the oil and gas industry incidents mentioned by Atherton and Gill (2008)

happened at oil refineries. Besides the abovementioned, an incident happened at an

oil refinery at Shell Port Dickson in May 2011 where a leakage for unprocessed fuel

occurred during the plant’s maintenance (Reuters, 2011). Luckily, the news article

reports that immediate measures were taken and did not involve any injuries or

fatalities. The source of the leakage has been rectified, but the occurrence of such

incidents proves there is room to improve and avoid such incidents from happening

in the future through OSHMS and safety planning.

5

1.4 Research Objectives

To avoid broad connotation from the title of the research, the objectives of

this project will focus primarily on the following:

1. Examine the current practice of OSHMS safety planning in Shell Port

Dickson.

2. Compare the current practice with DOSH guidelines for OSHMS.

3. Identify possible room for improvements for OSHMS safety planning.

4. Propose a modified or enhanced OSHMS safety planning

method/model validated by experts.

1.5 Research Questions

Based on the research objectives, the following research questions will be the

backbone of the whole project:

1. What are the current practices in OSHMS safety planning Shell Port

Dickson?

2. What are the results of comparison from OSHMS guideline by

DOSH?

3. What are the rooms for improvement in the current practices?

4. How the current self regulatory practice in OSHMS safety planning

can be improved?

6

1.6 Scope

This research project will be focusing the aspect of continuous OSHMS

safety planning of an oil refinery situated at Port Dickson under Shell Malaysia. This

narrows down the research to OSHMS and safety planning and does not cover safety

design and safety process. The limitation and boundary will depend on how much

access to the required research data is given by Shell Port Dickson throughout the

project.

1.7 Significance of the Project

This research project will optimistically increase the efficiency of OSHMS

and result in lower accidents or incidents. It will benefit many parties including

Shell oil refinery of Port Dickson, other related industries and OSH at the national

level. This research project will also greatly benefit the field of OSH through the

following:

1. Enhance current approaches to self regulatory in OSH.

2. A practical alternative method/model for safety systems.

3. Valuable research outcome for added value to OSHMS.

4. Contribution to the OSH body of knowledge.

1.8 Definition of Terms

The definitions of terms for the title of the project are conceptually defined

for better comprehension of the research project:

7

Assessment – a justified judgment of data towards a specific or stated goal (Taras

2005).

Self Regulatory – OSH practices applied with own effort as stated in the OSH act; It

shall be the duty of every employer and every self-employed person to ensure, so far

as practicable, the safety, health and welfare at work of all his employees.

(Occupational Safety and Health Act, 1994).

Occupational Safety and Health Management System – A set of interrelated or

interacting elements used to establish occupational safety and health policies,

objectives and to achieve those objectives (Department of Standards Malaysia,

2005).

Safety Planning – Addresses activities including the assessment or arrangement for

the development and implementation of OSHMS.

1.9 Summary

OSHMS safety planning should be constantly improved to avoid unnecessary

incidents that could cause injuries, death and financial lost. This component is

justified through several rules, regulations and national policies. Therefore, the

research will identify, examine and improve the current practice through an

improvised method or model. For the purpose of this project, the research will be

done at a Shell oil refinery in Port Dickson. This project will greatly benefit the

OSH body of knowledge and many parties involving OSH. Though several

definitions of terms are explained to align the meaning of the research title to the

research project, the following chapters are also arranged in a sequential order to

easily understand the flow of the research project.

8

CHAPTER 2

LITERATURE REVIEW

2.1 Introduction

The literature review identifies relevant theories and relates to the concepts

used in the study. It covers all forms of literature materials ranging from past

research to books that have connection and in conjunction with this particular

research and field of knowledge. Furthermore, the review may identify deficiencies,

reveal inconsistencies and discern knowledge that should be created or improved

with respect to the latest development of the topic (Kee & Hoon, 2009).

Throughout the process, specific attention is given to self regulatory practices

in OSHMS for the oil and gas industry. Equally important is the research objective

providing the axis to align the critical analysis of the materials systematically

according by theme. The correlation of each thematic analysis will also result in

identifying the appropriate related research gaps. Consequently, the thematic

analysis is then synthesized to produce the conceptual framework which will be the

solid foundation and the center of gravity for the following chapters.

2.2 “Funnel” Analysis

The reviews of literature

approach to zoom in and filter onto the desired state conveying the research title and

objective. The flow of this chapter comprises of funneled subject area and

management theories actin

2.1, followed by synthesis resulting in a conceptual model.

Analysis

reviews of literatures are analyzed using the widely used “



management theories acting as the top foundation for the funnel as shown in

, followed by synthesis resulting in a conceptual model.

Figure 2.1: “Funnel” analysis

MANAGEMENT THEORIES

OSH MANAGEMENT

SYSTEM (OSHMS)

OSHMS SELF

REGULATION

OSHMS

ISSUES

OSHMS

ISSUES IN

OIL& GAS

9

analyzed using the widely used “funnel”



g as the top foundation for the funnel as shown in Figure

2.2.1 Management Theories

In theory, OSHMS is basically derived from management theories which

originate from the management and business management school of thought. This

predicament is similar to foundations of other management systems. Yates (2011)

revealed many theories which functions as the underpinning and basis of OSHMS,

starting with the importan

shown in Figure 2.2

justifies the realization of OSH in the workplace and OSHMS as a way to administer

and manage OSH.

Yates (2011) identifies other theories that are applied directly or indirectly

with OSHMS. Among the theories

Hezberg motivational theory, (3) Deming cycle, (4) management by objective, (

contigency theory, (6) chaos theory and; (7) management s

theory applied in OSHMS is Deming’s PDCA c

Figure 2.3. OSHMS follows the path of many other management systems such as

Management Theories


e from the management and business management school of thought. This



starting with the importance of safety and health in Maslow’s Hierarchy of Needs

Figure 2.2. Safety being the second most important needs of a human


Figure 2.2: Maslow’s hierarchy of needs


with OSHMS. Among the theories explained are; (1) Mcgregor’s t

Hezberg motivational theory, (3) Deming cycle, (4) management by objective, (

contigency theory, (6) chaos theory and; (7) management styles. The most prominent

lied in OSHMS is Deming’s PDCA cycle as shown in

. OSHMS follows the path of many other management systems such as

10


e from the management and business management school of thought. This



ce of safety and health in Maslow’s Hierarchy of Needs

. Safety being the second most important needs of a human



explained are; (1) Mcgregor’s theory X and Y, (2)

Hezberg motivational theory, (3) Deming cycle, (4) management by objective, (5)

tyles. The most prominent

ycle as shown in

. OSHMS follows the path of many other management systems such as

11

‘total quality management’ with this particular theory and gives great emphasis on

the concept of improving the current state to a better condition. The adaptation for

the PDCA cycle into OSHMS for ILO and MS 1722 can be seen in Figure 2.4 and

Figure 2.5.

Figure 2.3 : Deming’s PDCA cycle

Figure 2.4: ILO OSHMS elements

12

Figure 2.5 : OSHMS MS 1722 implementation framework

The Offshore Petroleum Industry Training Organisation aka OPITO Oil and

Gas Academy of UK curriculum similarly teaches OSHMS with the abovementioned

theories in Henri Fayol’s Theory (OPITO Oil and Gas Academy, 2013). However,

there is one conflicting theory in the syllabus called ‘paternalistic management’.

This type of management theory underlines management by having the best interest

towards employees without consulting the employees. This may result in

management not having precise depiction or feedback from employees and might

cause inaccurate assumptions by top management.

Since OSHMS is new and still have room to develop and mature, there are

many other management theories that have big potential to be tapped and applied in

OSHMS. Many of these theories are not given consideration possibly because of

unsuitability or overlooked upon. For example, Simon (1960) introduced ‘decision

theory of management’ by looking at management as a decision making open-ended

subjective thought process. Another example, Hale (1997) presented a concept

through a problem solving cycle in modeling safety management systems and

13

recommends future work in this matter. Unfortunately, there is scarce literature in

enhancing OSHMS through other theories in the OSH body of knowledge which has

high potential to be exploited and integrated.

2.2.2 OSHMS

From the management theories postulated previously, many OSHMS

strategies and standards has been developed from the past couple of decades.

Podgorski (2010) and Robson (2006) classifies 4 levels of OSH management

strategies; level 1 as being passive, level 2 as reactive, level 3 as proactive and level

4 as proactive through continuous improvement originating from Deming’s PDCA

cycle. Furthermore, the level 4 strategy have been realized into many standards such

as BS 8800, OHSAS 18001, ILO-OSH 2001 and MS 1722. In addition, ‘behavior

based safety management’ has also been integrated into current OSHMS

(Podgorski, 2010). Currently, many industries have already adopted and integrated

these strategies, models and standards into their organization.

Redinger & Levine (1998) propose a set of assessment criteria to be used as

OSHMS auditing instruments. They further highlight that auditing involves

measurement towards standards and compliance to items in the form of checklists.

This has been applied through ‘guidelines in OSHMS’ produced by DOSH by setting

out a set of guidelines in implementing OSHMS that includes examples of forms and

checklists to be applied in OSHMS. These assessment instruments are rigidly

structured in the form of checklists and forms and are considered best practices in the

industries that will greatly determine the attainment of the desired OSHMS standard

certification. But, the drawback with these assessment instruments is that there is no

room for consideration towards unforeseen factors or in the event of unexpected

occurrence that is not included in the OSHMS forms and checklists. This is in

contrast with the required thought process in ‘decision theory management’.

Furthermore, an OSHMS standard has to be generalized for compatibility with any

industries.

14

Grote (2011) supports OSHMS generalization that requires universal

compatibility and high configuration according to the nature of the industry itself. In

addition to being generalized, the necessity for OSHMS to be taken into account

from the aspect of financial cost is also imperative. Pomfret (1978) quoted Drucker

(1954) regarding economical factors as the main drive towards successful

management. OSHMS models and standards do not consider financial cost or

economic factors that are interrelated with the finance of the organization.

Rationally, disregarding financial implication in OSHMS will cause trivial or

marginal focus for top management in the implementation of OSHMS. This

contradicts from Frick (2011) on OSHSMS obligation as a tripartite involvement

involving the government, employers and employees.

2.2.3 OSHMS Self Regulation

A tripartite involvement for OSHMS initiates from the government setting

the regulation for OSH and OSHMS implementation. Frick (2011) and Robson

(2006) clarifies OSHMS as being either mandatory or voluntary. This has already

been applied in Malaysia by the government through specific OSH regulations,

OSHA and empowerment of implementing OSH through self regulation. Grote

(2011) points out that the majority of industries often give more emphasis on external

legal regulations when compared to self regulation. When in fact, a mindset of self

regulation should spearhead OSHMS while at the same time comply with external

regulations.

Gupta and Lad (1986) acknowledge the fact that governments should provide

guidelines to enforce self regulation that will produce the formulation of the

organization’s OSHMS. The formulation can be put together to adhere any OSHMS

standards for certification. Together, it is also ideal for government representatives

to validate and endorse the formulation and arrangement of OSHMS. In Malaysia,

involvement of government is attained from DOSH from the Ministry of Human

Resource.

15

Besides DOSH, the essence of OSHMS self regulation is constituted by the

law through a section in OSHA which states: It shall be the duty of every employer

and every self-employed person to ensure, so far as practicable, the safety, health

and welfare at work of all employees (Occupational Safety and Health Act, 1994).

This particular mention in the OSHA is aligned with the National OSH Master Plan

vision for self regulation through enforcement as shown in Figure 2.6.

. Figure 2.6: OSH strategic drivers for the national OSH master plan

Unfortunately, many industries perceive self regulation in OSH and OSHMS

as only an industry standard and liability rather than an asset due to legal compliance.

According to Bennet (2002), this has resulted in ‘compliance mentality’ and

detrimental to continual improvement since the improvement stops at compliance.

Industries tend to lose focus on continual improvement caused by complying with

the chosen OSHMS standard. This defeats the purpose of the originating PDCA

cycle in the first place. A possibility to overcome this dilemma is by integrating the

16

concept of focusing in a well articulated thought process in the OSHMS that takes

consideration of legal regulations as the guideline and boundary.

2.2.4 OSHMS Issues

The loss of focus and ‘mental compliance’ has resulted in many OSHMS

issues discussed by scholars in the field. Fernandez-Muniz (2006) addresses an issue

in safety management that links to organizational safety performance indicators

which is usually measured by number of accidents, injury and illnesses. These

numbers are collected by reports and may be inaccurate due to unreported cases.

Robson (2006) and Redinger (2002) agrees that OSHMS effectiveness judged from

illness, injury and fatality rates may trigger suppression of reports and cause

inaccurate measurements. Frick (2011) further claims that accident reports are often

suppressed to maintain the image of OSHMS excellence adhering to the OSHMS

standards certification.

The next issue is the rigidness outcome of OSHMS which contradicts with

the nature of how OSHMS should be implemented. Grote (2011) states that OSHMS

need for stability outweighs flexibility which causes rigid standardization as shown

in Figure 2.7. This may cause overlooking circumstances that are not in the self

regulated OSHMS standard. Logically, there is a need for a balanced stability and

flexibility in the arrangement of OSHMS. Makin and Winder (2007) reflected the

ideal organization to implement OSHMS is a “thinking organization” with a more

flexible feedback control and holistic involvement from tripartite parties.

17

Figure 2.7: Stability versus flexibility in OSHMS

Involvement from employees as part of the tripartite cooperation is another

issue in OSHMS. Hasle (2011) concluded that workers lose influence in the process

of the arrangement of OSHMS. Frick (2011) points out that this is a result of a top-

down approach in implementing OSHMS. This issue is confirmed by Saurin and

Cambaria (2005) empirical studies on the need of a holistic participatory

involvement, especially by the employees. Due to this, it is confirmed when

Podgorski (2010) mentions the possibility of less employee involvement due to

bureaucratic implementation as one of the disadvantages of the current application

OSHMS standards.

Other issues listed by Podgorski (2010) are OSHMS losing focus caused by

integration with quality and environmental management systems, neglecting the

financial implication in the arrangement of OSHMS and questioning the

effectiveness of OSHMS. Even Frick (2011) questions the effectiveness by

revealing several examples in the industries where major accidents still occur even

when OSHMS standards are complied. Both Podgorski (2010) and Frick (2011)

justifies that there is much room and need to further develop and enhance the current

OSHMS to a better level. Hale (2009) reaffirms by confirming the sparse literature

on the effectiveness of OSHMS and intervention options by organizations including

the oil and gas industries to improve on.

18

2.2.5 OSHMS Issues in Oil and Gas Industries

The review of literatures for OSHMS in oil and gas continues by elaborating

and emphasizing OSHMS issues from the perspective of the oil and gas industries.

Atherton and Gil (2008) collected case studies of incidents in the oil and gas

industries and conclude that accidents are always directly or indirectly contributed by

OSHMS factors. Mearns and Flin (1995) refer to the supervisor as playing a key role

in translating OSH policy into a safe, effective and productive behavior at the

worksite and evaluating the means which is critical for OSHMS. Furthermore,

Mearns, Whitaker and Flin (2003) relates to the actual practices, roles and functions

associated with OSHMS that has been overtaken by a complacent routine ‘paper

system’ which impairs the dynamic nature of OSHMS. Improvements in the

arrangement of OSHMS are needed to depict the actual practices, roles and functions

associated to OSHMS. Besides the significance of roles and functions of

appointments, operational aspects in OSHMS could also provide safety indicators for

preventing offshore oil and gas deepwater blowouts (Skogdalen, Utene & Vinnem,

2011).

Within the operational aspects of OSHMS are the hazard identification tools

such as HAZOP, JHA and HIRARC. Avila, Pessoa and Andrade (2013) states that

HAZOP only identifies common human error slips neglecting mistakes resulted from

making wrong decisions and recommends different strategies involving decision

making. Rizwan and Al-Marri (2012) observes JHA in OSHMS are viewed by

employees in the oil and gas industry as a form that is required to be filled rather than

a useful tool in the OSHMS. Another questionable related issue is the status of

prioritization for OSHMS regarding safety measures as the last consideration in

operational aspects of the industry and OSH related matters. Khan and Amyotee

(2002) comments that in the typical approach, safety measures are considered as a

last add-on control measure. Even a paper presented by Reyes and Watt (2002) on

suggesting their ‘systemic safety management system’ sequenced OSH policy as the

last consideration to an effective OSHMS. Consequently, these issues created a

cascading effect similar to Heinrich’s ‘domino theory’ as stated in new

19

methodologies for assessment (Srivastava & Gupta, 2010). The issues involved in

the cascading effect may also include the level of involvement from employees.

Vinnem (2010) recommended the main thrust for offshore emergency

preparedness in view of rare accidents is by evaluation involvement from multiple

sources of input. This can be achieved by a holistic involvement in the arrangement

of OSHMS. Hovden et al. (2007) related findings on OSH representative influence

in OSH matters are caused by limited understanding of employers towards OSH, late

involvement in decision making and insufficient influence in the arrangement of

OSHMS. Rundmo, Hestad and Ulleberg (1998) also discovers job stress is due to

less opportunity to influence decisions and rarely consulted before the decision

making process. Antonsen, Skarholt and Ringstad (2011) concludes that the negative

outcome of less employee participation in OSHMS results in disempowerment and

increased bureaucracy.

Antonsen, Skarholt and Ringstad (2011) also mention other OSHMS issues in

the oil and gas industry in their case study by criticizing that the OSHMS

arrangement is not based on any economic rationality that can hinder the

implementation when not endorsed by top management due to minimal involvement

from the financial department. Whereby another issue by Watson (1993) claims

numerous OSHMS being utilized for safety improvements have varying degrees of

success. Some being successful and many are unsuccessful. Albeit all the issues for

OSHMS in the oil and gas industry, there are success stories for the ability to be

creative outside from the OSHMS ‘paper system’ and ‘compliance mentality’ under

extreme pressures in a crisis situation. The summary of the story is as followed:

A crew was trapped in fire. The foreman named Wagner ordered his men to lie down

in ashes which are inflammable material. The crew that followed his orders survived.

Those that did not suffered injury or death. This action by the foreman was not

outlined in any SOP, routine, training and OSHMS (Antonsen, Skarholt & Ringstad,

2011).

20

2.3 Synthesis

According to the Oxford Dictionary, synthesis is a combination of elements

to form a connected whole. This definition confirms the higher level of synthesis in

contrast of analysis which is basically making sense out of the complex or into

something understandable. Thus the synthesis is performed towards the findings of

the analytical assessments from the “funneled” literature review.

The previous analysis uncovers a certain recurring correlation among the

literatures that can be categorized into different unique themes and requires further

synthesis. In order to achieve this, synthesis is achieved through a series of

deduction from the theories, identified themes and analytical assessments to

produced synthesized results. The outcome is shown in Table 2.1. These results

become the ultimate ingredient to develop the conceptual framework.

Table 2.1: Tabularized Synthesis

THEME SUMMARIZED ANALYTICAL

ASSESSMENTS

RESULT

Theory OSHMS theories originate from

business management theories. (1) Main

theory directly related to OSHMS is the

Deming PDCA Cycle. (2) Majority of

other theories are supportive in nature to

OSHMS or only related to leadership

aspects of management.(3) Strong

potential to fully exploit Decision

Theory (Simon, 1960) and

Management by Objectives (Drucker,

1954).

Research takes high

consideration towards

Decision Theory and

Management by

Objectives.

21

Table 2.1: Continued Self

Regulatory

Confirms the importance of applying

self regulatory with certain guidelines

and compliance to government OSH

regulation.

Already applied in

Malaysia (Occupational

Safety and Health Act,

1994).

Focus (1) Considerations towards OSH are

usually last. (2) “compliance mentality”

detriment the element of continual

improvement in PDCA.

‘Management by

objective’ can realign the

loss of focus.

Rigidness Overwhelmingly implied in the

literatures by: (1) Improving and

upgrading assessments, audits hazard

identification tools and the OSHMS

itself. This does not promote

consideration for elements outside of the

tools and processes. (2) OSHMS focus

on documentation resulted a ‘paper

system’ and ‘mental compliance’

neglecting the spirit and heart of OSH

(3) Suppression of incident report to

achieve good track record. (4) Success

stories for thinking out of the box.

‘Decision theory’ as an

open-ended subjective

thought process in

management can

overcome the rigidness

application for OSHMS.

Involvement (1) Tripartite involvement conveyed in

regulation. (2) High bureaucracy. (3)

OSHMS applied top-down. (4)

Insufficient influence and late

involvement from employees.

Requires a “holistic

involvement” from all

relevant parties for all

levels and aspect of

OSHMS.

22

Table 2.1: Continued

Cost Economical results are the main drive

for top management but OSHMS is not

based on economic rationality.

Need to integrate

“financial implications”

to OSHMS.

Integration Integration of OSHMS with other

management systems such as quality

and environment.

Already applied in

majority of industries in

Malaysia.

Generalization Supportive for generalization of

OSHMS to suit all industries.

Already realized though

OSHMS guidelines by

DOSH. Integration of

‘decision theory’ will

achieve greater

configurability in

OSHMS.

Other Issues Recurring emphasis on importance to

improve current OSHMS and sparse

literature regarding the issue.

Justifies this research.

Questionnable ‘Paternalistic theory’ regarding

management without consultation from

employees but for the interest of

employees at heart.

Will not take this into

consideration of the

research due to conflict

with the other literatures

and “holistic

involvement” requiring

involvement of

employees.

2.4 Conceptual Framework

A conceptual framework, either graphically or in narrative form justifies the

relationship between several interrelated concepts to be used in the research (Kee

Hoon, 2009). From the synthesis, the main elements assimilated into the conceptual

framework are ‘decision

involvement” and “f inancial

illustrated in Figure 2.

thought process to overcome

‘Management by o

objectivity including a

involvement while giving consideration to th

consideration.

Conceptual Framework


relationship between several interrelated concepts to be used in the research (Kee


ecision theory’, management by objective

“f inancial implications”. The finalized conceptual framework is

illustrated in Figure 2.8. ‘Thought Process acts as the underlying philosophy in the

to overcome compliance rigidness for the OSHMS arrangement

objective’ is in the OSHMS arrangement itself

including a well articulated “holistic participation

while giving consideration to the “financial cost”

Figure 2.8 : Conceptual framework

23


relationship between several interrelated concepts to be used in the research (Kee &


bjective theory’, “holistic

. The finalized conceptual framework is

as the underlying philosophy in the

for the OSHMS arrangement and

is in the OSHMS arrangement itself to ensure

holistic participation” to ensure

to ensure financial

24

2.5 Summary

Elements of the literature review have been defined accordingly. The

literatures collected analyzed by the “funnel” approach of the subject matter starting

from management theories to OSHMS issues in oil and gas. Analyses from the

literatures are then synthesized into various themes to find recurring correlation.

Relevant themes that facilitate in achieving the research objectives are then

visualized into a conceptual framework that becomes the core fundamental and act as

the launching pad for Chapter 3.

25

CHAPTER 3

RESEARCH METHODOLOGY

3.1 Introduction

This chapter describes the research methodology used to ensure the validity

and trustworthiness of the findings. When embarking on the research methodology,

it is crucial to inquire the research method to be adopted. The three inquiry method

consists of ‘positivist method’, ‘interpretative method’ and ‘critical method’.

Piaw (2012) points out that researcher who want to improve the social conditions of

mankind usually use the ‘critical method’ which involves the use of multiple sources

as the basis of their comparative studies and is generally regarded as qualitative

research and can be supported by quantitative elements. This research’s inquiry

method is critical method because of the above reason and research questions from

chapter 1.

3.2 Research Design

The result of a research is determined by the research design and method

which in turn are determined by the aim of the research. No one research design can

be used for all research, but a research can be conducted using several research

designs. Research designs are categorized as qualitative or quantitative and

experimental or non-experimental. The research design for this research is mixed

method qualitatative-quantitative and non-experimental as shown in Figure 3.1.

Figure 3.1: Research design

26

27

3.2.1. Qualitative

Qualitative research is employed where data cannot be explained by

quantitative and requires in depth analysis as shown in Table 3.1. Since the

fundamental core of this study mainly involves analytical comparison of multiple

sources, then it is established that the research is mainly qualitative research. This

establishment fits in congruence with the foundation of OSHMS theory in

management or social science. Although the research is qualitative in nature, it can

still be supported by elements of quantitative where the amount of data is sufficient

to further strengthen its validity. The tool that is be used in the qualitative analysis is

the software QSR NVivo 8.

Table 3.1: Research Type

Objective Question Type of Data

Examine the current

practice in OSHMS

safety planning in Shell

Port Dickson.

What are the current

practices in OSHMS safety

planning Shell Port

Dickson?

Qualitative

Compare the current

practice with DOSH

guidelines for OSHMS.

What are the results of

comparison from the

DOSH OSHMS guideline?

Qualitative

Identify possible room

for improvements for the

OSHMS safety planning.

What are the rooms for

improvement in the current

practices?

Qualitative that can

be supported with

quantitative data or

stand on its own.

Propose a modified or

enhanced OSHMS safety

planning method/model

validated by qualified

person in the field.

How the current self

regulatory practice in

OSHMS safety planning

can be improved?

Qualitative

28

Piaw (2012) further describes qualitative research as:

1. Research does not have a control and treatment group, thus no pre-test

or post-test.

2. Conducted when the treatment cannot be implemented..

3. To study the relationship between independent and dependent variables

without manipulating the variables.

4. Therefore qualitative is a non-experimental research.

3.2.1.1 Qualitative Case Study

There are many non-experimental research to choose from comprising of

survey research, field research, case study, action research and historical research. It

is important for this research to be configurable in nature and highly flexible when

required to be mixed with any other research methodologies to strengthen the

validity. Case study is chosen for the reason that it suits the research objectives and

adaptable to diverse sources of rich in-depth data. According to Glaser and Strauss

(1967), the discovery and research of something which is grounded in rich data is

called Grounded Theory Method or Study. Urquhart (2013) continues by explaining

that a qualitative case study by critical method can use the Grounded Theory Method

which finds gaps and themes using the literature review or Grounded Theory Study

where the literature review is done after the data analysis. This research will use the

Grounded Theory Method in the coding process after the literature review and

collection of data. The configuration of the case study is in Table 3.2. Suffice to

say, case study requires great emphasis on the process of gathering information from

diverse sources from different perspectives known as triangulation.

29

Table 3.2 : Case Study Configuration

CASE STUDY CATEGORY SUITABILITY

Intrinsic: Understand a particular case in-depth Partly

Instrumental: Collect rich data related to a theory Partly

Collective: Combination of Intrinsic and Instrumental to form a

theory on a larger scale

Yes

CASE STUDY FUNCTION SUITABILITY

Exploratory: Pioneer research or pilot study to determine if

further study is required

No – time

constraint

Explanatory: Explain a phenomenon or test validity of a theory No

Descriptive: Theory used to guide researcher on study Yes

Descriptive: Understand by describing Yes

Comparison: Understand by comparing Yes

Correlation: Understand the cause and effect No

Action: Understand changes under special action No

Field: Observe in natural setting Yes

Developmental: Understand over a period of time No

Historical: Understand past to predict future No

3.2.1.2 Triangulation

When collecting qualitative data using the triangulation technique, a

phenomenon is viewed from different perspectives, with each perspective detected

by using a different methods (Kee & Hoon, 2009). This has been widely agreed

upon in other fields of knowledge such as ‘quality management’ by quality guru

Dr. Howard Gitlow and coined as a different terminology called paradigm

(Covey, 2004). Further on, Denzin (1978) identified 4 types of triangulation as

shown in Table 3.3. The type of triangulation used in this research is methodological

triangulation by reason of suitability with the research objectives and questions. The

triangulation of the research is shown in Figure 3.3.

30

Table 3.3 : Triangulation Types

TYPE SUITABILITY

Data Triangulation Involves time, space and individuals.

Investigator Triangulation Involves multiple researchers.

Theory Triangulation Involves multiple theories.

Methodological

Triangulation

Involves multiple methods to gather data: interviews,

observations, questionnaires and documents

Figure 3.3: Triangulation for research

Assessment of Shell PD

OSHMS

Examine Documents

Interview

Observation

Survey Questionnaire

31

3.2.2 Quantitative

Quantitative is associated with numerical data which is stated precisely

(Piaw, 2012). In qualitative research, when the research sample is large and the data

is homogenous, it can be quantified using descriptive statistics. Data is collected and

basic statistics such as frequency, percentage, mean standard deviation and

description score are reported. In this research, descriptive statistics are used for the

research survey samples in the overall qualitative study further strengthening the

validity of the qualitative study. The tool that will be used in the quantitative analysis

is the software IBM Statistics 21.

3.3 Population and Sample

In the context of this research project, the population is the total of all the

individuals working in the oil refinery at Shell Port Dickson. Due to limitation from

Shell to disclose particulars of their employees, appropriate samples are used to

represent the homogenous population for the interview and questionnaires. The

sampling procedure is shown in Table 3.4 and further elaborated.

Table 3.4: Summarized Sampling Technique

RESEARCH

ACTIVITY/INSTRUMENT

PROCEDURE

Interview Non-Probability Sampling : purposive Sampling and;

continue with snowball sampling if required.

Questionnaire 1. Identify population size.

2. Determine sample size by using Krejcie and Morgan.

3. Non -Probability Sampling : convenience Sampling.

32

3.3.1 Sampling for Interview

Piaw (2012) elaborates that interview samples are based on non-probability

sampling procedures. Among the seven procedures, this research uses purposive

sampling and snowball sampling. Purposive sampling meaning that the subjects are

chosen as respondents based on certain characteristics. Snowball sampling is when

after an interview is completed, the subject is asked to recommend another possible

subject with suitable characteristics defined by the researcher if required.

The purposive sampling involved subjects chosen as repondents because they

have certain characteristics that suits the requirement of this research. Snowball

sampling for similar characteristic was conducted when the chosen subject is not

available or not allowed to be interviewed by any reason. The purposive samples

conducted in no particular order are:

1. Head Operational HSE.

2. Head of HSSEMS.

3. OHD.

4. Occupational Health Nurse.

5. HR representative.

3.3.2 Sampling for Questionnaire

The number of samples used in qualitative research is usually small

(Piaw, 2000). A small sample is sufficient due to the homogenous characteristisc of

the population regarding direct or indirect involvement with OSHMS. Piaw (2012)

further explains that expenditure of time, cost and number of researchers should also

be considered in determining sample sizes. The procedure used to determine the

sample size for the distribution of questionnaires are; (1) Identify the Population

Size. N = population size and; (2) Determine sample size using Krejcie and Morgan

sample size determination table. In SRC PD, the estimated population size is 250.

Therefore, the sample size should be 256. But due to constraints by SRC PD, onl a

total of 25 samples responded to the questionnaires.

33

3.4 Data Collection and Analysis

The data collection and analysis comprises of; (1) examine OSHMS

documentation; (2) interview; (3) questionnaire and; (4) observation. Each of these

activities use different instruments and seperate initial analysis before combining into

a final domain analysis. Each activity is explained in the following pages.

3.4.1 Examine OSHMS Documentation

This process involves: (1) acquiring OSHMS and related documentations

from Shell Port Dickson; (2) study the documentation, and; (3) comparison with

OSHMS standard. The relevant OSHMS documentations were acquired and studied

will be conducted in several steps for greater efficiency at a manageable level as

shown in Table 3.5. Once the documentation is acquired and studied, a comparison

is performed towards relevant external OSHMS standards and at the same time

considering the elements of ‘self regulation’ that they practice. The related

documentation for comparison includes: (1) OSHMS MS 1722 and; (2) Guidelines

for OSHMS MS 1722. Throughout the data collection phase, a total of 67

documents were acquired for the analaysis.

The process of examining OSHMS documentation itself answers the first two

research questions research objectives:

What are the current practices in OSHMS safety planning Shell Port Dickson?

and

What are the results of comparison from the DOSH OSHMS guideline?

34

Table 3.5: Examine OSHMS Documentation

STEPS OSHMS & RELATED DOCUMENTS

SELECTIVE CODING THEMES TO CONSIDER IF APPLICABLE

Com

plia

nce

Rig

idne

ss

Obj

ectiv

ity

Fin

anci

al

Cos

t

Invo

lvem

ent

Step 1 Policy

& Organisation

Company policy. OSH policy. Company organisation structure.

Roles and responsibilities of each department / section.

HSSEQ department organisation structure, appointments, roles and responsibilities.

OSH committee organisation structure.

OSHMS standards certification main documents.

OSH related minutes of meeting.

Step 2 Manual,

Procedures & Plans

Initial Review Initial documentation for OSHMS arrangement.

Periodic OSHMS arrangement

OSH manual. OSH related procedures. OSHA related legal register.

OSH training procedures and records.

Permit to work procedures. OSH related plans. OSH related

35


STEPS OSHMS & RELATED

DOCUMENTS

THEMES TO CONSIDER IF

APPLICABLE

Com

plia

nce

Rig

idne

ss

Obj

ectiv

ity

Fin

anci

al C

ost

Invo

lvem

ent

Step 3

Audits,

Reviews,

Records &

Forms

HIRARC forms or similar

tools (JHA,JSA, etc.)

Incident reports.

Audit reports and reviews

Incident statistical report.

Worker’s compensation

claims procedures.

Work environment

monitoring.

Inspection, calibration and

equipment maintenance

records.

OSH performance data.

Incident investigation

reports.

Exposure assessment.

Medical surveillance

documents.

ERP drill report.

Toolbox meeting record.

Step 4

Other

related

documents

Other OSH and OSHMS

related documentations.

3.4.2 Interview

The interview method is one of the methods of collecting data in this

research. Based on the research objective and conceptual framework revolving

themes, the questions in the interview

face-to-face individually.

the needs of the research. According to Piaw (2013), the appropriate number of items

for an individual interview is

3.3 and interview questions

reliability, all interview

The interview

method. The constant comparative method involves breaking down the data into

discrete ‘incidents’ (Glaser

continually comparing specific incidents in the data, the coding process refines these

categories, identifies their properties, explores their relationships to one another and

integrates them into the desired result.

Interview



themes, the questions in the interview was in semi-structured form

face individually. In addition, questions were added or dropped according to


for an individual interview is 8-15 questions. The interview plan is shown in

and interview questions based on the interview plan in Appendix A

interviews were recorded with an audio recorder.

Figure 3.3 : Interview plan

The interview was transcribed to be analysed using the constant comparative

The constant comparative method involves breaking down the data into

discrete ‘incidents’ (Glaser & Strauss, 1967) and coding them to categories. By


ies their properties, explores their relationships to one another and

integrates them into the desired result.

36



structured form and conducted

added or dropped according to


15 questions. The interview plan is shown in Figure

Appendix A. For

to be analysed using the constant comparative

The constant comparative method involves breaking down the data into

Strauss, 1967) and coding them to categories. By


ies their properties, explores their relationships to one another and

37

3.4.3 Questionnaire

The questionnaire was designed by the researcher in consideration of the

main important themes synthesized from Chapter 2. Types of questions were based

on the information of the underlying theme as shown in Table 3.6 and the type of

questions was Likert-Type. The questionnaire was then constructed as in

Appendix B. Unfortunately, due to the time limitation of the project, a pilot test for

the questionnaire was not done.

Table 3.6 : Questionnaire Design

UNDERLYING THEME TYPE OF QUESTIONS

Focus in OSHMS with ‘mental compliance’ or ‘thought process’.

Likert-Type Measure level of flexibility or rigidness of OSHMS arrangement. Financial consideration in OSHMS. Level of involvement for employees towards OSHMS arrangement.

Data from Likert-Type questions was converted using descriptive statistics to

calculate the mean score and interpreted accordingly with the underlying theme. The

Likert-Type question was scaled from one to five representing the intent of the

respondent as shown in Table 3.7.

Table 3.7: Likert-Item Scale

Likert- Scale Interpretation

5 Strongly Agree

4 Agree

3 Somewhat Agree

2 Disagree

1 Strongly Disagree

38

3.4.4 Observation

The two types of observation methods are systematic observation and

participant observation (Piaw, 2012). The method used in this research is participant

observation where the observer as a participant and his status as the researcher is

known to the participants. The observation instrument is a structured observation

form as in Appendix C. Sampling for observation was based on activities or events

that are related to the research. Therefore, quota sampling was used to determine the

events to observe. Two observations were conducted in this research; (1) Safety

induction for 1 day from 0900H to 1700H and; HSSE meeting for the duration of 2

hours. Data were recorded using digital camera and audio recorder then filled up the

observation forms which then was analyzed qualitatively.

3.5 Data Analysis

As mentioned, the data analysis was conducted qualitatively and

quantitatively based on the source of the data. Qualitative analysis was utilized for;

(1) Documentation; (2) Interview and; (3) Observation and quantitative analysis

utilized questionnaire type of data.

3.5.1 Qualitative Analysis

The qualitative data analysis implemented Grounded Theory Method coding

and Spradley’s Semantic Relationship Criteria. Various data gathered from the

previous processes are then constant comparatively coded as recommended by

Glaser (1967) as shown in Figure 3.4 via:

1. Open Coding – Attaching codes identified categories.

2. Selective Coding – Clustering categories into themes.

3. Theoretical Coding – Semantic Relationship of themes and categories

into one emergent framework/theory/model.

Spradley (1980) defines

data that symbolically contains all the previous levels of categorizat

relationship in the theoretical coding is

criteria’.

From ‘Spradley’s

coding are linked by relation

Nvivo. The theoretical coding

in Figure 3.5. For reliability, the coding process

rationally by referring, comparing and

theories. From the results of the

be answered which is:

What are the rooms for improvement in the current practice?

Data Open Coding

Documentation Sub Theme

Data Questionnaire

Data Observation

Sub Theme

Data Interview

Spradley (1980) defines semantic relation as a categorization summary of

data that symbolically contains all the previous levels of categorizat

relationship in the theoretical coding is based on ‘Spradley’s

Figure 3.4 : Qualitative data analysis

Spradley’s semantic relation criteria’, the results

linked by relation as shown in Table 3.8 or a generated model by QSR

theoretical coding was coded by ‘inductive’ and or ‘deductive

. For reliability, the coding process was based on social

rationally by referring, comparing and relating with past literature and related

theories. From the results of the theoretical coding, the third research question will

be answered which is:


Table 3.8 : Relationship in Coding

Open Coding

Relationship Selective Coding

Relationship

Sub Theme

1

Associated Theme 1 Is a reason for doing

Is a kind of Is a place for doing

Sub Theme

2

Is a place in Is used for

Is a part of Is a way to do

Is a result of Theme 2

Is a step inIs a cause of Is a stage in

Is an attribute of

Is a characteristic of

39

as a categorization summary of

data that symbolically contains all the previous levels of categorization. The

Spradley’s semantic relation

s of the theoretical

or a generated model by QSR

deductive’ as shown

based on social-scientific proof

relating with past literature and related

, the third research question will


Relationship Theoretical Coding

Is a reason for doing

Is a place for doing

Is used for

Is a way to do

Is a step in Is a stage in

Is a characteristic of

40

Figure 3.5: Inductive and deductive coding

3.5.2 Quantitative Analysis

The quantitative analysis was conducted by applying descriptive statistics to

the result of the likert-type questionnaires. By combining the questionnaire results of

all the respondents, the mean score, percentage and frequency was calculated and

translated in comparison with the qualitative analysis. This is how the quantitative

analysis supports the qualitative findings.

3.6 Propose OSHMS Arrangement

A modified or enhanced OSHMS safety planning method/model validated by

qualified expert is then proposed from the result of the data synthesis which will

answer the fourth research question:

How the current self regulatory practice in OSHMS safety planning can be

improved?

3.7 Summary

This research adopts the critical study that is generally known as qualitative

method. The qualitative method supported by quantitative is suitable for this

41

configurable case study approach and uses methodological triangulation that analyses

data from many sources. This triangulation method aids to the development of the

research design framework which includes; (1) examining documentation,

(2) interview, (3) questionnaire and; (4) observation. Firstly, examining the

documentation will be conducted in several progressive steps and finally compared

to DOSH OSHMS guidelines. Next is the population sampling for interview and

questionnaire. Interviews are analyzed using the constant comparative method and

questionnaires using descriptive statistics. Observation is then conducted as a

participant observer and also analyzed using the constant comparative method. The

final data synthesis combining all data analysis from varied sources is by using

Grounded Theory method coding and Spradley’s Semantic Relationship Criteria.

Whereby, the quantitative data will be analyzed using descriptive statistics to

compare and support the qualitative analysis. Finally, based on the Chapter 2

conceptual framework and the results of the data synthesis, a modified or enhanced

OSHMS is proposed.

.

42

CHAPTER 4

DATA COLLECTION AND ANALYSIS

4.1 Introduction

This chapter discusses the data collection analysis from the acquired rich data

of the research. Presented are the findings from the aspect of the OSHMS for SRC,

comparison with MS 1722:2011, qualitative data analysis/synthesis coding,

quantitative analysis to support the qualitative findings and any other additional

findings. As a rule of thumb, the analysis will focus on the Research Question

derived from Chapter 1:

1. What are the current practices in OSHMS safety planning Shell Port Dickson?

2. What are the results of comparison from the DOSH OSHMS guideline?

3. What are the rooms for improvement in the current practice?

4. How the current self regulatory practice in OSHMS safety planning can be

improved?

43

4.2 OSHMS

According to the DOSH (2011) from the Ministry of Human Resource in

their Guidelines on Occupational Safety and Health Management Systems; OSHMS

is a set of interrelated or interacting elements to establish and implement OSH

policy, objectives and to achieve those objectives. OSHMS is part of the

organization’s overall management system used to manage OSH risks. A

management system should include organizational structure, planning activities,

responsibilities, practices, procedures, processes and resources.

4.2.1 SRC HSSEMS

The current practice of OSHMS used in SRC is called HSSEMS which

combines matters in addition to OSH consisting of Security and Environment.

Referring to the SRC (2013) HSSEMS, their OSHMS covers the activities of SRC

and defines the overall manner by which SRC manages HSSE & SP activities and

also describes how the HSSE & SP risks of its activities are managed in a manner

consistent with the principles and standards set out in Manufacturing, Business and

Downstream SRC. Contractors carrying out activities in SRC are required to manage

HSSE & SP in a systematic manner that is consistent with the SRC HSSE & SP

standards and procedures.

This HSSEMS applies to arrangements for the assessment and management

of the physical asset security risks for manufacturing sites. This document does not

apply to business related security issues such as theft, fraudulent activities or

information technology. Advice on these types of security matters is provided by

Shell Malaysia Security Advisor. This HSSEMS complements the existing SRC PD

Management System. The HSSEMS manual aims to:

1. Provide guidance on all aspects of the HSSEMS within the refinery.

2. Demonstrate that HSSE & SP management controls are in place within the

organization, supported by procedure and documentation.

44

3. Assure management that major hazards are identified and the corresponding

risks effectively managed to ALARP in the various refinery activities.

Figure 4.1: SRC HSSEMS Visualized Elements

A summarized visualized of the eight elements from the SRC HSSEMS is

shown in Figure 4.1. The first element of HSSEMS is Leadership and Commitment

which describes the demonstration of leadership of SRC leadership team on the field

and the link of MD towards Shell HQ Malaysia. The second element is Policy and

Strategic Objectives outlines the compliance of SRC towards local

regulations/legislations, Shell’s control framework and other requirements. The third

element covers Organization, Responsibilities, Resources, Competence, Standards

and Documentation which defines the HSSE organization structure, role of HSSE

appointments, resources and competence in training, internal/external

communication and the management of standards/documents/procedures in SRC.

The fourth element is Hazards and Effects Management which includes HRA and

JHA which is similarly close to HIRARC.

The next important

consisting of HSSE planning, ERP,

CSDS/MSDS. The sixth element is Implementation, Monitoring and Reporting

explaining the HSSE key performance indicators and

reporting/investigation.

external, HSSE walkabout and performance data verification.

Management Review

process.

4.2.2 Comparison to MS 1722:2011

SRC uses OHSAS 18001

MS 1722:2011. Since Shell is a global company, it is logical that SRC opted for

OHSAS 18001 for their OSHMS accreditation as it is an internationally

well known OSHMS standard.

MS 1722:2011 and this comparison would provide useful insight on SRC HSSEMS

towards Malaysia’s own MS 1722:2011. Figure 4.2 describes how SRC HSSEMS

addresses the requirements of the core elements in MS 1722:2011.

The next important element is the fifth element; Planning and Proced

consisting of HSSE planning, ERP, crisis management and legal requirements

The sixth element is Implementation, Monitoring and Reporting

explaining the HSSE key performance indicators and

reporting/investigation. The seventh element is Audits ranging from internal,

external, HSSE walkabout and performance data verification. The last element is the

Management Review where the HSSEMS is reviewed through an annual assurance

Comparison to MS 1722:2011

SRC uses OHSAS 18001 as the certification for OSHMS standards and not


OHSAS 18001 for their OSHMS accreditation as it is an internationally

well known OSHMS standard. Nevertheless, OHSAS 18001 is similar in nature with



e requirements of the core elements in MS 1722:2011.

Figure 4.2 : Comparison to MS 1722:2011

45

element is the fifth element; Planning and Procedures

crisis management and legal requirements of

The sixth element is Implementation, Monitoring and Reporting

explaining the HSSE key performance indicators and incident

The seventh element is Audits ranging from internal,

The last element is the

where the HSSEMS is reviewed through an annual assurance

as the certification for OSHMS standards and not


OHSAS 18001 for their OSHMS accreditation as it is an internationally accepted and

Nevertheless, OHSAS 18001 is similar in nature with



e requirements of the core elements in MS 1722:2011.

46

Based on the results of the comparison, many of the components in MS

1722:2011 can be found in SRC HSSEMS. Besides the commonality of the

visualization in the figure, there are also several components of MS 1722:2011 that is

not found in SRC HSSEMS; (1) Initial Review is not part of the HSSEMS, as

explained by the SRC HSSE representative, the initial review was disposed because

of company policy of disposing documents when reached a certain number of years;

(2) The Objectivity and Program is not in the HSSEMS, due to change of the SRC

HSSE objectives that change annually during the annual management

review/meetings; and (3) The Management of Change is not mentioned in the

HSSEMS, but there is a separate document of form/checklist on Management of

Change in SRC. In a nutshell, SRC HSSEMS is similar to MS 1722:2011 but

organized in a different order. There is also several lacking components of MS

1722:2011 in the HSEMS.

4.3 Qualitative Data Analysis

The research is a qualitative case study applying methodological triangulation

involving multiple sources of data gathering consisting of documentation, interview,

observation, survey questionnaire and observation. Grounded Theory Method of

doing a literature review before the data analysis is applied and not Grounded Theory

Study which does the literature review after the data analysis. The coding conducted

is by constant comparative simultaneously inductive and deductive. The tool used in

the coding process in QSR Nvivo 8 by the use of nodes, trees, relationhip and models

generated by the software as shown in Table 4.1. The project summary report of the

qualitative analysis generated by the software is in Appendix D.

Table 4.1 : QSR NVivo 8 Functions Used in Coding Process

Coding Process QSR NVivo 8 Functions Open Coding Nodes

Selective Coding Trees Theoretical Coding Relationship

Models

47

4.3.1 Open Coding

Open coding is attaching codes or sub themes which relates to the identified

categories based on the conceptual framework produced in the literature review. In

other words, it is basically labeling the data accordingly to the suitability of the

research. The function used in NVivo 8 for open coding is nodes for each of the

source of data; (1) Documentation; (2) Interview; (3) Questionnaire and;

(4) Observation. A nodes summary report is generated by NVivo 8 in Appendix E.

4.3.1.1 Documentation

Throughout the data collection, a total of 41 documents were acquired from

SRC PD. Not all of the requested documents were received due to the fact that some

of the data in the unreleased documents were confidential to Shell. Nevertheless, the

documents attain will have to make do and is actually rich data to proceed with the

open coding. The open coding summary of documentation can be referred to in

Appendix D and summarized open coding according to selective coding themes in

Table 4.2. The documentation that was not able to be acquired:

1. Initial Review

2. Initial Documentation for OSHMS arrangement.

3. Audit reports and reviews.

4. Worker’s compensation claim procedures.

5. Work environment monitoring.

6. Inspection, calibration and equipment maintenance records.

7. Incident investigation reports.

8. Exposure assessment.

9. Medical surveillance documents.

48

Table 4.2 : Themes Identified During Documentation Open Coding

STEPS OSHMS & RELATED DOCUMENTS

SELECTIVE CODING THEMES TO CONSIDER IF APPLICABLE

Com

plia

nce

Rig

idne

ss

Obj

ectiv

ity

Fin

anci

al

Cos

t

Invo

lvem

ent

Step 1 Policy

& Organization

Company policy. n/a yes No n/a OSH policy. n/a yes No n/a Company organisation structure.

n/a yes n/a yes

Roles and responsibilities of each department / section.

n/a not all n/a yes

HSSEQ department organisation structure, appointments, roles and responsibilities.

n/a yes no yes

OSH committee organisation structure.

n/a yes no not all

OSHMS standards certification main documents.

yes yes no no

OSH related minutes of meeting.

yes yes no yes

Step 2 Manual,

Procedures & Plans

Initial Review SRC disposed Initial documentation for OSHMS arrangement.

SRC disposed

Periodic OSHMS arrangement (through management review)

not accessible

OSH manual. yes yes no no OSH related procedures. yes yes no no OSHA related legal register.

yes yes no no

OSH training. yes indirect no yes Permit to work procedures. yes yes n/a yes OSH related plans. yes yes no yes

49


STEPS OSHMS & RELATED

DOCUMENTS

THEMES TO CONSIDER IF

APPLICABLE

Com

plia

nce

Rig

idne

ss

Obj

ectiv

ity

Fin

anci

al C

ost

Invo

lvem

ent

Step 3 Audits,

Reviews, Records &

Forms

HIRARC forms or similar

tools (JHA,JSA, etc.)

room to loosen

yes no no

Incident reports. yes yes no No

Audit reports and reviews not accessible

Incident statistical report. not accessible

Worker’s compensation

claims procedures.

not accessible

Work environment

monitoring.

not accessible

Inspection, calibration and

equipment maintenance

records.

not accessible

OSH performance data. yes not updated in OSHMS

no no

Incident investigation

reports.

not accessible

Exposure assessment. not accessible

Medical surveillance

documents.

not accessible

ERP. yes yes no yes

Toolbox meeting record. not accessible

Step 4 Other related

documents

Other OSH and OSHMS

related documentations.

yes yes no no

50

4.3.1.2 Interview

The interviews were conducted semi-formally based on purposive sampling

then snowball sampling. Unfortunately, out of the seven targeted samples to

interview, only three purposive samples were interviewed and two snowball samples

based on recommendation. The other interviewees that were not interviewed due to

reasons of unavailability and their tight schedule were; (1) HSSEQ Manager; (2) HR

Manager; (3) Financial Department Manager and; (4) SRC MD. The interview was

conducted with the design of questions and intent based on the conceptual

framework from the literature review. The interviews were recorded by audio and

transcribed in; (1) Appendix F – SHO; (2) Appendix G – Head of HSSEMS;

(3) Appendix H – HR Representative; (4) Appendix I - Occupational Health Nurse

and; (5) Appendix J - OHD. A total of 67 open codes were identified using NVivo as

shown in Figure 4.3.

Figure 4.3 : Nodes Identified During the Open Coding Process

4.3.1.3 Questionnaire

In the survey questionnaire, there were two qualitative questions that were

subjective and open ended asking for the respondents’ suggestion to improve on the

current SRC HSSEMS. While the majority of the respondents answered, there were

typically some who did not. The answers given can be grouped into 5 similar

suggestions and have been coded into Nvivo 8. The 5 similar suggestions were:

1. Increase communication.

2. Increase site visit.

3. Improve internal audit.

51

4. Improve reward and recognition system.

5. Add more awareness campaign.

4.3.1.4 Observation

The observation conducted involves participation observation as per

convenient quota sampling. Throughout the data collection, only two events were

given access by SRC to participate in observation. Although only two events were

observed, but really meaningful and full of rich data that is related to the research

conducted. The events were safety induction and HSSEQ meeting. The safety

induction was video recorded as shown in Figure 4.4, HSSEQ meeting audio

recorded and both recordings translated onto an observation form in Appendix K and

Appendix L which is designed based on the conceptual framework in the literature

review. The observation form is then coded in Nvivo 8.

Figure 4.4 : SRC PD Safety Induction Coding in NVivo 8

52

4.3.2 Selective Coding

Continuing the coding process from the open coding is selective coding

which involves the clustering of codes into themes identified from the conceptual

framework from the literature review. The identified main themes to cluster and

categorized from the open coding will be placed under either; (1) Compliance

Rigidness; (2) Objectivity; (3) Involvement and; (4) Financial Implication. For

Selective Coding, NVivo uses the function of trees as shown in Appendix M in

clustering the previous open codes. A generic model is then generated based on the

associated main themes for the selective coding as shown in Figure 4.5.

Figure 4.5: Generated Model for Selective Coding Skeleton

4.3.2.1 Compliance Rigidness

For the theme identified compliance rigidness from the constant comparison

inductive and deductive coding, the generated model form NVivo is shown in

Figure 4.6. The relationship using the Spradley’s Semantic Relationship Criteria is

identified as “ is a cause of ”.

53

Figure 4.6: Generated Model for Compliance Rigidness Selective Coding

Based on the analysis, compliance rigidness in SRC is a cause of treating the

HSSEMS as a mother document that must be “religiously” followed. This translates

to the reliance on safety tools (JHA, JSA, checklists, etc.) whereby the tools are used

which is checklist natured with little space to allow thought process. For example,

the rigid categorizations specified as high hazard as specified in their HEM. These

assessments such as reviews and tools are used on a needs basis.

54

This scenario has evolved to a reactive mindset where actions are taken to

avoid incident that has happened in SRC and other similar industries from happening

again in the future rather than preventing an incident from happening in the first

place. This has also embedded a compliance mindset to comply rules, regulations

and legislations. When the mindset of compliance have been incepted, this triggers

the absence of continuous improvement which is the heart of OSHMS whereby what

is needed is only complying to regulation.

4.3.2.2 Objectivity

For the theme identified compliance rigidness from the constant comparison

inductive and deductive coding, the generated model from NVivo is shown in Figure

4.6. The relationship using Spradley’s Semantic Relationship Criteria is identified as

“ is a characteristic of ”.

Figure 4.7: Generated Model for Objectivity Selective Coding

55

Based on the analysis, objectivity is a characteristic of lack of objective

translated or dissipated throughout SRC where the top management intent and

objective is occasionally not successfully absorbed down to the bottom employees.

This not only applies to SRC but also to contractors working at SRC due to lack of

emphasis on objectivity during the procurement and contract management. When

lack of emphasis on the objectivity, the focus diverts on past experience, lesson

learnt and maintaining what is considered an acceptable level of safety. This will

obstruct the nature of continuous improvement in the long haul.

4.3.2.3 Involvement

For the theme identified involvement, from the constant comparison

inductive and deductive coding, the generated model from NVivo 8 is shown in

Figure 4.8. The relationship using Spradley’s Semantic Relationship Criteria is

identified as “ is a characteristic of “.

Figure 4.8: Generated Model for Involvement Selective Coding

56

Based on the analysis, involvement is a characteristic of SRC relying heavily

on the top-down approach where eventually bottom loses initiative to simultaneously

contribute a bottom-up feedback for a complete synergy in a successful OSHMS.

For example, some departmental role and task have not included elements of their

commitment to OSHMS. Delegating the responsibility of ownership may impede the

sense of belonging to a certain extent. Questions may arise such as ‘Why should I

mind about other safety issues when it is not under my responsibility?’ As a result,

OSH has become a non-holistic accountability and lacks comprehensive inclusive

involvement participation. Therefore deepens the challenge of involvement in

OSHMS.

4.3.2.4 Financial Implication

For the theme identified financial, from the constant comparison inductive

and deductive coding, the generated model from NVivo 8 is shown in Figure 4.8.

The relationship using Spradley’s Semantic Relationship Criteria is identified as “ is

a characteristic of “.

Figure 4.9: Generated Model for Financial Implication Selective Coding

57

Based on the analysis, financial is a characteristic of and possibly caused by

lack of financial needs channel involving OSH matters. This may be rooted by lack

of financial consideration by SRC in spending OSH matters because of Shell having

a big budget and always have no problems in spending in any OSH related matters.

This might not be the case for small companies where budget is conserved as much

as possible and will avoid spending in any way possible.

In SRC, there is no specific cost analysis before spending in any safety

measures. Basically, when there is a need, just spend. Nevertheless, there is in the

documentation regarding cost of loss calculations but there is no angle in terms of

cost benefit analysis. The approach of spending when obliged or when the need

arises can only be achieved by an organization with big financial resource like Shell.

4.3.3 Theoretical Coding

The final step is theoretical coding where the previous selective codes are

once again constant comparison by inductive and deductive using Spradley’s

Semantic Relationship Criteria of the themes and categories into one emergent

framework /theory/model. The relationship of; (1) Associated; (2) Is a cause of and;

(3) Is a characteristic of; is embedded into the overall final finding.

The result of analysis is subjectively synthesized based on the conceptual

framework and past related theories from the literature review. The generated model

of the overall qualitative data analysis is shown in Figure 4.10. The model clearly

relates all the qualitative findings into one central core, which is defined by the

researcher as the THOUGHT PROCESS that is needed to improve OSHMS and

safety planning in SRC and also other industries.

58

Figure 4.10: Generated Model for THOUGHT PROCESS Theoretical Coding

59

4.4 Quantitative Data Analysis

The quantitative analysis in this mixed method research design is intended to

support the qualitative analysis and findings. Descriptive statistics is used based on:

(1) mean; (2) frequency and; (3) percentage. The survey questionnaire in

Appendix B is also designed according to the conceptual framework in the literature

review and be constant comparatively support the qualitative findings. The number

of sample is determined by using the Krejcie Morgan table where the suitable

number of sample is 256 and convenient sampling due to the dispersal of the

questionnaire can only be done by the appointed liaison contact person by SRC.

Unfortunately, the completed respondent questionnaire received at the end of the

data collection is only a mere 25. From the 25 samples, there were 18 different

positions and appointments where the majority is supervisor which is 20% from the

correspondence as shown in Figure 4.11. From the 25 samples, there were 9 different

departments where the majority is QHSSE which is 20% from the correspondence as

shown in Figure 4.11.

Figure 4.11: Pie Chart of Position/Appointment of Survey Respondents

20%

4% 4% 4%

4%

4%

4%

4%

4%

8%

8%

8%

4%

4%

4% 4%

4%

4%

60

Figure 4.12: Pie Chart of Departments of Survey Respondents

4.4.1 Reliability

Reliability test used for the quantitative analysis is Cronbach’s Alpha which

is commonly used as an estimate of the reliability for a sample of correspondence. A

pilot test was not done due to the hardship of getting respondents survey

questionnaire back. The result of the reliability test is 0.58 and when the figure is

rounded results in 0.6 and is considered acceptable by Sekaran (2003) because within

the range of 0.6 to 0.7. Reliabilities which are less are considered poor and a higher

value have a better reliability. Bearing in mind that the number of sample is a narrow

range has deflated the value of alpha and that there is a possibility that if the number

of sample is bigger could result in the increase of the value of alpha.

40%

20%

12% 8%

4%

4%

4%

4% 4%

61

Table 4.3: Reliability Statistics

Reliability Statistics

Cronbach's

Alpha

Cronbach's

Alpha Based on

Standardized

Items

N of Items

.583 .353 9

4.4.2 Descriptive Results

Based on the number of sample N, the mean and standard deviation is as

shown in Table 4.4. Referring to the values based on likert-scale ranging from value

1 to 5 which the interpretation from strongly disagree to strongly agree. The eight

likert type questions were based on the conceptual framework of the literature review

consisting of the items in Table 4.4.

Table 4.4: Overall Descriptive Results

Questionnaire Item

N Mean

Comply

25 4.4400

Vision

25 4.9200

Form

25 4.7600

Policy

25 4.0000

Arrangement

25 4.4400

Implementation

25 4.8000

Finance

25 4.7200

Consideration 25 4.3600

62

4.4.2.1 Compliance

The statement for this item in the survey questionnaire is as follows:

Occupational Safety and Health is only complying and conforming to regulation.

The item relates and supports compliance rigidness from the conceptual framework

of the literature review. From the results shown in Figure 4.13, the majority of 72%

correspondences strongly agree with a mean score of 4.4. This outcome supports the

qualitative findings on the compliance rigidness mindset.

Figure 4.13: Comply Bar Graf

63

4.4.2.2 VMO


Occupational Safety and Health is not in the Mission and Vision of Shell.

The item relates to objectivity from the conceptual framework of the literature

review. The results in Figure 4.14 show the majority of 92% correspondences

strongly agree with a mean score of 4.92. This outcome does not support the

qualitative findings on the objectivity . This shows that employees and or contractors

at SRC is aware that the VMO contains OSH matters and the real concern is how

much of the VMO is embedded in their hearts and mind in dealing with their

everyday work since the qualitative findings translates that objectivity is an issue to

be concerned with.

Figure 4.14: Vision Bar Graf

64

4.4.2.3 Form


Occupational Safety and Health Management is only filling out forms and checklists.



correspondences strongly agree with a mean score of 4.76. This outcome supports

the qualitative findings on the compliance rigidness mindset.

Figure 4.15: Form Bar Graf

65

4.4.2.4 Policy


I only take action from the safety policy and identified hazards.



correspondences strongly agree with a mean score of 4.0. This outcome supports the

qualitative findings on the compliance rigidness mindset that the majority of

employees and or contractors are “only” alert to what is stated in the policy and

identified hazard stated by SRC. But what about the possibility of hazards that has

not been identified?

Figure 4.16: Policy Bar Graf

66

4.4.2.5 Arrangement


I’m not involved in the planning and arrangement of the Safety and Health

Management System.

The item relates and supports involvement from the conceptual framework of the

literature review. From the results shown in Figure 4.17, the majority of 76%

correspondences strongly disagree with a mean score of 4.44. This outcome supports

the qualitative findings that employees and or contractors are not really holistically

involved in the arrangement of OSHMS in SRC.

Figure 4.17: Arrangement Bar Graf

67

4.4.2.6 Implementation


I’m involved in implementing Safety and Health matters.

The item relates and supports involvement from the conceptual framework of the

literature review. From the results shown in Figure 4.18, the majority of 88%

correspondences strongly agree with a mean score of 4.8. This outcome combined

with the previous arrangement findings indicates that the majority of employees and

or contractors are only involved in implementing OSH and not in the arrangement

and planning of it.

Figure 4.18: Implementation Bar Graf

68

4.4.2.7 Financial Implication


Occupational Safety and Health Management System affects Shell’s finance.

The item relates and supports financial implication from the conceptual framework


correspondences strongly agree with a mean score of 4.72. This result shows that the

majority of employees and or contractors are aware that financial costs are involved

in OSH matters. But what is concerning that there are also a percentage of 4%

strongly disagree. This indicates a small minority thinks that OSH does not give any

financial implication.

Figure 4.19: Finance Bar Graf

69

4.4.2.8 Financial Consideration


The Safety and Health Management System should include more financial

consideration.

The item relates and supports financial implication from the conceptual framework


correspondences strongly agree with a mean score of 4.3. This result shows that the

majority of employees and or contractors should include more financial

consideration. This could be caused due to the qualitative findings that SRC takes for

granted with the big financial resource to spend that there is no specific dedicated

channel to budget OSH besides the management periodic reviews.

Figure 4.20: Consideration Bar Graf

70

4.4.3 Overall Descriptive Results

From the 8 questions of the survey questionnaire and constant comparison of

related themes from the conceptual framework, the quantitative analysis supports the

qualitative findings as shown in Table 4.5.

Table 4.5: Quantitative Analysis Supporting Qualitative Findings

QUALITATIVE

SELECTIVE CODING

THEME

QUANTITATIVE

ITEMS

SUPPORTIVE?

Compliance Rigidness Compliance Yes – 72%

Form Yes – 80%

Policy Yes – 68%

Objectivity VMO Yes – 92%

Involvement Arrangement Yes – 76%

Implementation Yes – 88%

Financial Cost Financial Implication Yes - 84%

Financial Consideration Yes – 64%

4.5 Additional Findings

Besides from the finding of the qualitative and quantitative analysis based on

the conceptual framework, there are also additional findings that were not identified

in the gaps in the literature review. These additional findings can be classified into

two groups; (1) Other improvement suggestions from the raw data and; (2) SRC

positive aspects in OSHMS.

71

4.5.1 Other Improvement Suggestions from Data

The beauty of the qualitative analysis conducted has resulted in findings that

were outside of the conceptual framework from the literature review. It was

discovered that the initial review of HSSEMS was absent due to SRC’s policy of

document lifespan disposal resulting in gaps in requirement of identifying the

foundation of the OSHMS. The initial review is considered an important integral

aspect in an OSHMS as made known by MS 1722:2011. The next discovery is that

there was room to improve of several issues such as; (1) Lack of continuous

HSSEMS successor for smooth legacy; (2) Lack of the ‘Health’ matters and more to

‘safety’ in the overall OSHMS as mentioned by the OHD; (3) Lack of recognition to

internal auditors and; (4) Lack of a map/diagram in the ERP document. Lastly, there

were also challenges in commitment, implementation and questionable competencies

as what is also currently happening in other industries. An Nvivo generated model of

the abovementioned is shown in Figure 4.21.

Figure 4.21: Generated Model for Additional Improvement Suggestions.

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4.5.2 SRC Positive Aspects in OSHMS

Not all of the findings from the rich data is negative in nature. It is not

surprising that SRC as one of the leading organization for OSH in the Malaysian

industries have many positive aspects that are exemplary as shown in the generated

model in Figure 4.22. These include a well established organization structure, a

complete concise supporting plans, procedures as well as documents and of course a

well defined policy that actually allows a thinking culture in terms of OSH. But as

we know from the findings, the ultimate challenge is translating these positive

aspects into a completely fulfilled realization.

Figure 4.22: Generated Model for Positive SRC Aspects.

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4.6 Summary

OSHMS in SRC is called HSSEMS which integrates elements of

environment and security and was examined and compared tom MS 1722:2011 on

the OSHMS aspect. Although similar in nature, some of the elements of MS

1722:2011 were absent. The qualitative Grounded Theory Method of open, selective

and theoretical coding combining Spradley’s Semantic Relationship Criteria in

deductive inductive constant comparison fulfills the literature review conceptual

framework of the four identified themes of; (1) Complliance Rigidness;

(2) Objectivity; (3) Involvement and; (4) Financial implication analysis. From the

aspect of quantitative data, the analysis supports and confirms the qualitative

findings. Besides the aforementioned, there were also additional findings from the

rich data for other themed improvement suggestions and positive exemplary aspects

of SRC.

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CHAPTER 5

CONCLUSION AND RECOMMENDATION

5.1 Introduction

This final chapter embodies the pinnacle of the research by fulfilling the last

research objective and research question of what can be improved in the current

OSHMS generally to all industries and specifically SRC. The findings from the data

analysis were integrated into a proposed improvised OSHMS and the approach to

implement it. Next, the improved OSHMS is validated by subject matter experts in

the field. The contribution of this OSHMS will be elaborated and the conclusion of

the research. Constraints and limitation throughout the research is addressed briefly

and the implication of the research. Last but not least is the recommendation for

future work.

5.2 Integration of Findings

The findings from the data collection and analysis are integrated into the SRC

HSSEMS as their OSHMS to produce a modified improvised OSHMS as shown in

Figure 5.1. This includes the Thought Process of the 4 conceptual framework

themes, absent items from comparison to MS 1722:2011 and additional findings.

Approaches to implement the improvised OSHMS are then concisely elaborated.

Figure 5.1

5.2.1 Improvised OSHMS

The integration of the finding in the current SRC HSSEMS has resulted into a

new proposed improvised OSHMS as shown in Figure

a rearrangement of SRC HSSEMS and modified

elements of all the findings from the previous where the items are bolded and

italicized; (1) Specified Dynamic Objective; (2) Synergistic; (3)

Deduction; (4) Initial Review; (5) Financial Analysis; (6) Recognition; (7) Legacy;

(8) Management of Change and; (9) Competency

conceptual model is symbolized by the heart shaped

symbolizing it as embedding in the heart and soul of the OSHMS throughout the 6

distinct steps.

Figure 5.1: Integration of Findings in SRC HSSEMS

Improvised OSHMS


new proposed improvised OSHMS as shown in Figure 5.2. The conceptual model is

a rearrangement of SRC HSSEMS and modified into 6 distinct steps to


italicized; (1) Specified Dynamic Objective; (2) Synergistic; (3) Beyond Compliance


(8) Management of Change and; (9) Competency Reassurance. At the center of the

conceptual model is symbolized by the heart shaped THOUGHT PROCESS

it as embedding in the heart and soul of the OSHMS throughout the 6

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: Integration of Findings in SRC HSSEMS


The conceptual model is

6 distinct steps to include added


Beyond Compliance


At the center of the

THOUGHT PROCESS

it as embedding in the heart and soul of the OSHMS throughout the 6

Figure 5.2

5.2.2 Approach to Implement Improvised OSHMS

The approach to implement the proposed improvised OSHMS is similar to

how SRC HSSESMS

6 distinct steps, elements from the findings have been integrated in each of the steps.

Referring to Figure 5.2, only the integrated finding

the center thought process for each step will be elaborated

Step 1: Policy – Specified Dynamic Objective

In the current SRC HSSEMS, there is already a strategic

touches the objectives as a general concept statement which actually translates in

aiming to achieve the policy at all tier policy levels. But it does not state what the

current objective and goal regarding OSH matters. This does not

have the specific measurable objective, because SRC do

accordingly from time to time but it is not mentioned in the OSHMS.

Figure 5.2: Proposed Improvised 6 Step OSHMS.

Approach to Implement Improvised OSHMS


how SRC HSSESMS or any other OSHMS is conducted. Following the order of the


Referring to Figure 5.2, only the integrated finding which is bold and italicized and

center thought process for each step will be elaborated:

Specified Dynamic Objective.

In the current SRC HSSEMS, there is already a strategic



current objective and goal regarding OSH matters. This does not imply that it doesn’t

have the specific measurable objective, because SRC does update the objectives


76

OSHMS.


Following the order of the


which is bold and italicized and

objective item that



imply that it doesn’t

update the objectives


77

The specified objective must be inserted in the OSHMS and because it is ever

changing, it is also dynamic in nature. Hence the given item name, specified

dynamic objective. To differentiate this objective from the strategic objective, it

could be defined as ‘The specific, measurable, time-bound activities which the

employers develop for the purpose of improving working conditions’. Clear

objectives can lead to measurable goals and enable the organization to determine

whether or not it is being effective in achieving these goals. An example would be –

We will provide a workplace with decrease incidents and injuries result by 10% each

year.

Step 2: Organizing – Synergistic Structure.

Originally, HSSEMS for SRC is a well defined organization structure. The

modification is from the aspect to redefine the functionality of the organization

structure into a holistic involvement by everyone in SRC. Redefining of the

organization structure in terms of employee participation is where employees are

involved in some way with the decision-making regarding safety and health issue.

Employee participation can take in many forms, where there such as through

participation in safety circles which meet regularly in small groups to discuss ways in

which OSH can be improved.

Holistic participation involves; (1) The sharing of relevant information about

OSH and welfare with employees; (2) Giving employees the opportunity to express

their views and contribution; (3) Resolution of OSH and welfare issues and; (4)

Valuing the views of employees and taking them into account. Participation enables

employees to contribute to the decisions that that affect their safety, health and

welfare. It helps employers and employees to work together to seek resolution in a

synergistic structure.

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Step 3: HEMP – Beyond Compliance Deduction.

SRC’s own Hazard Effect and Management Procedure using JHA and HRA

is similar in nature to the HIRARC in MS 1722:2011. It is identifying hazards in the

workplace, estimation/evaluation of risks levels taking into account the existing

controls and establishing a risk control according to the level of risks identified. But

the effectiveness of HEMP depends on the quality of the evaluation which is

subjective and qualitative in nature and usually conforms to compliance of

regulations and legislations. Therefore, a beyond compliance deduction approach

is most suitable to think out of the box from the compliance mindset.

A deduction is a clear and concise way of thinking, which suggests a logical

line of action that is to be taken to attain an objective within the resources available.

Deductions may be extracted from a fact, assumption, assessment, etc. Due to this,

deductions can only be extracted when combined professional knowledge is used to

analyze the facts. Without such knowledge, the end product could be invalid or

unsound. As an example, to extract deductions, the following question may be

asked:

“So what can be done to attain the objective with the resources available, supported

by who, when, where, etc.?”

“Besides regulation and legislations, is there any way to increase the safety and

health beyond what is stipulated?”

The questions mentioned above were just examples. As a guideline,

deductions can be identified by the following characteristics;

1. Positive – Avoid suggesting what is not to be done but what should be done.

2. Quantitative – Deductions will have to be exact and quantified. It must be

firm, accurate, exact and specific or at least within specific restrictions.

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3. Practical – Deductions should be viable, credible, practical and valid answers

to solve the problem or stain the objective. Deductions must not be beyond the

capabilities, resources and laws of physics but always within their limitation. This

entails a thorough knowledge of roles, tasks, organization, capabilities and allocation

of resources.

4. Logical – Deductions must be logical to address the workplace.

5. Originality – Every situation is different from the last and this demands an

original deduction to attain the present objective. What was successful the last time

may not be the answer this time and every deduction must be extracted from present

facts in the present situation/environment.

6. Particular – Deductions are extracted to solve a particular problem.

Therefore deductions cannot be general answers in the form of an advice,

information and opinion. To be a definite deduction, it must not be drawn directly

from regulation, plans and procedures. This will be important to achieve beyond

compliance mindset. A bad example of deduction would be, “PPE must be worn”.

A better example would be, “A PPE that is not expired should be worn in Zone A

from 9 to 5 pm”.

7. Related – Deductions must be extracted from related information and can be

traced back to this information. This means that it is supported by that information.

Therefore deductions must be extracted from what is available and not from what is

desired and not available.

Step 4: Planning – Initial Review and Financial Analysis.

MS 1722:2011 has an initial review in their standards but there is absence of

initial review in the HSSEMS for SRC. The actual initial review for SRC has

actually been disposed due to its procedure to dispose documentation after a certain

amount of time. Another causing factor is the lack of legacy from previous

successors for important appointments/positions such as the Head of HSSEMS.

80

With this scenario, the initial review item is added in the improvised

OSHMS. The result of the initial review should be documented in the OSHMS to be

used as a basis for making decisions regarding the implementation of the OSHMS

and provide a baseline from which continual improvement of the organizations’

OSHMS can be measured. The initial review should include; (1) Method of

conducting initial review; (2) Sources of information; (3) Findings on current status

and; (4) Recommendations.

Another item inserted in step 4 of the improvised OSHMS is financial

analysis. A dedicated place for financial considerations for OSH in OSHMS would

be very beneficial rather than relying on the annual or periodic management

meetings. Scenarios might happen where financial needs in OSH arise where it was

not previously budgeted. This is the advantage of having financial analysis inserted

in the OSHMS. Methods of financial analysis such as cost benefit analysis could be

used or any other method of financial costing and implication that is appropriate.

Step 5: Implementation – Recognition and Legacy.

During the implementation, OSH matters are inserted in KPI and results in

compliance to ensure the desired KPI is achieved. Besides KPI, another additional

way to enhance the commitment for workers regarding OSH is by recognition. The

recognition could be in the form of rewards and appraisal. Workers will sincerely

involve themselves in the OSHMS process besides compliance in an enjoyable fun

manner rather than it being a burden. For example, one of the employees in SRC

was appointed as internal auditor for OSHMS but considers it a burden because was

not given any recognition of it. The method of recognition will depend on the

available resources and feasibility of the organization to conduct it on what level.

Nevertheless the recognition item is an important aspect to promote culture and must

be done for all types and sizes of industry.

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Step 6: Audit & Review – Management of Change and Competency Reassurance.

The item management of change addresses OSH concerns and issues

associated with the installation of new processes or modification of existing

processes or operations (internal changes), or changes in legislations or voluntary

code of practices (external changes). Organizational merger may introduce new

work processes activities and accommodation of new set of employees which may

introduce new or additional hazards and risks.

The management of change process should include consideration on issues

related to whether there are changes in hazards, risks and controls. When new safety

and health procedures and processes are required to be implemented, management

should ensure their affected employees or persons are informed of the changes before

those changes are implemented.

Competencies reassurance is an item to reassure all competencies of workers

regarding OSH. Although employees that are competent have attended and used

their competency skill, management of change might affect the condition of their

worksite and require a reassurance program conducted internally by SRC. This is to

avoid unwanted incidents to happen that is caused not because the worker is

incompetent but the changes that lack consideration for the ability to do their

competency in the new setting or condition.

Thought Process.

Thought process is applied throughout the 6 step in the improvised OSHMS.

It is the embodiment in the improvised OSHMS where clear thinking is required

when conducting each specific step or the whole OSHMS in a big picture. To

achieve the level of holistic thought process, it is necessary to have:

1. An Open Mind – Thought process must be approached with an open mind.

There must be no possible or preconceived solutions before making the appreciation.

The solution must be no possible or preconceived solutions. At first sight, an answer

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may be obvious as there is a tendency to decide from the routine or complacency.

However, deeper consideration from other factors such as time, finance and

resources may reveal a better solution or otherwise.

2. Accuracy – Correct and positive information will lead to correct thought

process whilst false information will only lead to false thought process. Therefore,

information is the factor must be true, accurate, detail or at least reliable to draw

deductions from. Information must be carefully examined to eliminate false or

unnecessary ones in the factors for those that do not lend a thought process relevant

to the objective. Ideally, concrete undeniable facts must be used as the basis of

thought process. However, when time and resources do not permit the gathering of

such facts or data, then one will have to rely on other forms of information, such as

assumptions, presumptions, assessments, conclusions, opinions, forecasts, evidences,

conclusions, predictions, estimates, beliefs and interpretations. In using information

that is not facts; judgment must be used based on common sense, knowledge, skill

and expert specialist advice to reach a reasonable accurate and true premise.

3. Validity. Thought process must be logical and argued critically to fully

justify its attainment of the objective. This means that every thought process is an

answer that will assist in attaining the objective. This will eventually lead to a valid

OSHMS that can be successfully executed by workers. In essence, this means that

thought process must be practical within the capability of resources.

4. No Ambiguity. Thought process must be approached with an objective

attitude. Factors, deductions, time, finance, etc must be supported by figures,

designation with its exact role and tasks allotted by its specific technical

terminologies. In short, there must be no ambiguities.

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5.3 Validation

The ideal method for validation of the proposed improved OSHMS by

applying and testing it in SRC or any industry for that matter. Unfortunately the time

to conduct a test is not feasible. Finding an organization or industry that is willing to

apply an untested OSHMS itself would prove to be a challenge in itself. With these

constraints in picture, the only viable option is to find qualified professionals who are

experts in the subject matter to validate the improvised OSHMS. The following are

Subject Matter Expert practioners that have validated the research.

1. HSE Manager, MISC Berhad – Appendix N.

2. Engineering Safety Officer, Sime Darby Energy & Utilities – Appendix O.

The subject matter experts opinions are that theoretically, the proposed

improvised OSHMS is possible to be done and suggests that it needs to be tested out

in real life with proper planning and time to absorb the full function of the new

OSHSMS. The intention of improving the SRC HSSEMS is considered a good

approach and might be a valuable reference in the future.

5.4 Contribution

Firstly is the contribution to the body of knowledge The information from

this research contributes to all the stakeholders who are covered under OSHA 1994

that is involved directly or indirectly in OSHMS in general. The stakeholders consist

of many but not limited to:

1. SRC PD

2. Oil and gas industry.

3. Other industries.

4. OSH training centers.

5. DOSH.

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5.5 Conclusion

The current OSHMS system by itself is positive, good and matured, but there

is still room to improve based on the conceptual framework of literature review and

findings from data analysis. The combined research sources have been synthesized

to produce the improvised OSHMS. By any means, applying the new OSHMS

would also be a heavy task for an organization. That is why suggestions for the

approach to implement the new OSHMS were detailed out for a smoother transition.

It also requires involvement from highly knowledgeable and skilled people. All in

all, the new OSHMS is just an inception that could open the doors to many new

possibilities.

5.6 Limitation

The biggest limitation for this research project is regarding accessibility of

data for certain aspects of this research. Specifically, the lack of adequate sample

received from correspondence of the survey questionnaire from the required number

referring to the Krejcie and Morgan table. This predicament illustrates the challenge

for quantitative data collection even to conduct a pilot survey. Besides the

mentioned, access to interviewees was also limited to the availability of the

individuals. Time is also another factor where the nature of a research project for

this module is only 6 months is inadequate to truly saturate the qualitative data and

test the proposed improvised OSHMS. But with all due respect the contact liaison

person as the representative from HSSEQ SRC appointed to me is ever so helpful

and really appreciated as shown in Figure 5.3

Figure 5.3: HSSEQ Liaison Contact Person - Hj Musa Mustafa on the Left

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5.7 Implication

Likewise, OSHMS has been applied in most of our industries and

establishments. It has been found that there are many variants in OSHMS standards

being used throughout the world. In view of this, there should be an approach to

embed THOUGHT PROCESS throughout all the OSHMS within the industries and

establishments. If the integration of thought process has been truly integrated in

OSHMS, it will definitely make the continuous improvement in OSH to be more

achievable in a well articulated manner. A wise general named Sun Tzu (400-

320BC) in his book The Art of War states that “The wise general in his deliberation

must consider both favorable and unfavorable factors. By taking into account the

favorable factors, he makes his plan feasible; by taking into account the unfavorable,

he may resolve difficulties”. A THOUGHT PROCESS is not an end task by itself.

Ultimately, it is only the process of logical thought and sound reasoning to reach a

solution to attain the objective

5.8 Recommendation for Future Work

This research hopefully has provided a foundation and launching pad to

enhance OSHMS and safety planning. It is highly recommended that for future work

that the proposed improved OSHMS to be tested in real industries and

establishments. From there, the OSHMS can be further improvised and enhanced

with newer insight from the results of tests conducted at the industries. At the end of

the day, the OSHMS is just a means to protect the welfare of everyone that is

working from the aspect of OSH and hopefully, the prototype of the improvised

OSHMS in this research will mature and evolve into something legendary and

become a legacy for future generations to come.

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APPENDIX A: Interview Questions

Research Topic

ASSESSMENT OF SELF REGULATORY PRACTICES IN OCCUPATIONAL SAFETY AND HEALTH MANAGEMENT SYSTEM AND SAFETY PLANNING

AT SHELL OIL REFINERY PORT DICKSON

Research Guarantee to Respondent’s

1. The respondent’s participation is voluntary. 2. All information given by respondents will be kept confidential. 3. Respondents shall receive a copy of the final research report. 4. The researcher shall make every effort to produce a research which will benefit all parties and the participants of the study. 5. The researcher or interviewer is trained and obeys the ethics of research.

The interview will commence with a preliminary discussion to ensure mutual understanding on the research project conducted. 1. From your perspective, describe the Occupational Safety and Health Management

System for Shell Refining Company in Port Dickson? 2. Is it an asset or liability? Please elaborate. 3. How do you relate it towards the company’s Mission and Vision? 4. What is your involvement in the arrangement of it? 5. How do you contribute towards the implementation? 6. How is the arrangement and implementation conducted from your point of view? 7. Are there any further considerations for the arrangement and implementation besides

compliance to regulations and standards? 8. Are there any financial considerations towards the arrangement and implementation? 9. What financial elements can be considered (or additional considerations) for the current

Occupational Safety and Health Management System? 10. What are your suggestions to improve the current Occupational Safety and Health

Management System?

____________________ ___________________ Signature of Respondent Signature of Researcher Name: Name: Appointment: Date:

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APPENDIX B: Questionnaire Form

This is a questionnaire for a research in Occupational Safety and Health Management System in Shell Oil Refinery Port Dickson. The aim of this research is to identify possible room for improvements in Occupational Safety and Health Management System. Your cooperation to participate in this questionnaire is much appreciated and will greatly benefit the outcome of this research. Borang kaji selidik ini adalah adalah sebahagian daripada kajian Sistem Pengurusan Keselamatan dan Kesihatan di Shell Port Dickson. Tujuan kajian ini adalah untuk mengenalpasti ruang untuk penambahbaikan Sistem Pengurusan Keselamatan dan Kesihatan Pekerja . Kerjasama anda untuk mengambil bahagian dalam kaji selidik ini amat dihargai dan amat berguna untuk hasil akhir kajian.

Research Topic / Topik Kajian

ASSESSMENT OF SELF REGULATORY PRACTICES IN OCCUPATIONAL SAFETY AND HEALTH MANAGEMENT SYSTEM AND SAFETY PLANNING AT SHELL OIL REFINERY PORT DICKSON

PENILAIAN TERHADAP AMALAN PERANCANGAN DAN PERLAKSANAAN BAGI SISTEM PENGURUSAN KESELAMATAN DAN KESIHATAN PEKERJAAN DI SHELL PORT DICKSON

Guarantee to Respondent’s / Jaminan kepada Peserta

1. The respondent’s participation is voluntary. Penyertaan peserta adalah secara sukarela. 2. All information given by respondents will be kept confidential. Semua maklumat peserta adalah rahsia. 3. The researcher shall make every effort to produce a research which will benefit all parties and the participants of the study. Penyelidik akan berusaha untuk menghasilkan kajian yang menguntungkan semua pihak termasuk peserta kaji selidik ini. 4. The researcher or interviewer is trained and obeys the ethics of research. Penyelidik telah dilatih dan mematuhi etika dalam melaksanakan sesebuah kajian.

Background Information / Latar Belakang Peserta Appointment / Jawatan : ____________________________________________________________

Department / Bahagian : ____________________________________________________________

Briefly describe your role and responsibility Terangkan tugas dan tanggungjawab anda dengan ringkas _________________________________________________________________________________

_________________________________________________________________________________

Instruction / Arahan Please select your level of agreement with the following statements by circling the number for each item below and answer the two last questions briefly. Sila bulatkan nombor berdasarkan tahap persetujuan anda terhadap pernyataan-pernyataan yang disenaraikan di bawah dan jawab dua soalan terakhir dengan ringkas.

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1. Occupational Safety and Health is only complying and conforming to regulation. Keselamatan dan Kesihatan Pekerja bukan hanya mematuhi dan memenuhi keperluan undang-undang.

Disagree Tidak setuju

1 2 3 4 5 Agree Setuju

2. Occupational Safety and Health is in the Mission and Vision of Shell. Keselamatan dan Kesihatan Pekerja tidak termasuk dalam Misi dan Visi Shell.



3. Occupational Safety and Health Management is only filling out forms and checklists. Pengurusan Keselamatan dan Kesihatan Pekerjaan adalah lebih dari mengisi borang.



4. I only take action from the safety policy and identified hazards. Saya hanya mengambil tindakan berdasarkan polisi keselamatan dan bahaya yang dikenalpasti.



5. I’am not involved in the planning and arrangement of the Safety and Health Management System. Saya tidak terlibat dalam perancangan Sistem Keselamatan dan Kesihatan Pekerja.



6. I’am involved in implementing Safety and Health matters. Saya terlibat dalam perlaksanaan perkara-perkara yang melibatkan Keselamatan dan Kesihatan.



7. Occupational Safety and Health Management System affects Shell’s finance. Sistem Pengurusan Keselamatan dan Kesihatan Pekerjaan memberi kesan kepada kewangan Shell.



8. The Safety and Health Management System should include more financial consideration. Sistem Keselamatan dan Kesihatan Pekerja perlu memberikan pertimbangan kewangan yang lebih.



What is your involvement in the Occupational Safety and Health Management System? Apakah penglibatan anda dalam Sistem Pengurusan Keselamatan dan Kesihatan Pekerjaan? ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ From your opinion, how can Occupational Safety and Health be improved? Pada pendapat anda, bagaimana Keselamatan dan Kesihatan Pekerja boleh ditambah baik? ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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APPENDIX C: Observation Checklist Recording Form

Research Topic


AT SHELL OIL REFINERY PORT DICKSON Date: Activity: Location: Respondent Groups: OBSERVATION ITEMS YES NO N/A

Refers to company mission, vision and policy directly or indirectly.

Notes: Clear objective or goal driven activity.

Notes: Routine complacency.

Notes: Promotes improvisation for OSH and/or improvement for OSHMS.

Notes: Room for flexibility in arrangement or implementation.

Notes: Includes consideration towards financial implication

Notes: Participant’s room for input in activity:

Low 1 2 3 4 5 High

Holistic participation for decision or arrangement: Low 1 2 3 4 5 High

Participant’s level of influence in activity: Low 1 2 3 4 5 High

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APPENDIX D: QSR NVivo 8 Generated Project Summary Report

Generated: 19/11/2013 4:35:06 PM

Project: Improvement of Self Regulatory Practices in OSHMS and Safety Planning at SRC PD Description Improvement of Self-Regulatory Practices in OSHMS and Safety Planning at SRC

PD. Based on the research objectives, the following research questions will be the backbone of the whole project: (1) What are the current practices in OSHMS safety planning Shell Port Dickson? (2) What are the results of comparison from OSHMS guideline by DOSH? (3) What are the rooms for improvement in the current practices? (4) How the current self regulatory practice in OSHMS safety planning can be improved? Users Name Initials Salehuddin SALEHUDDIN Created On 14/11/2013 1:47:48 AM

Modified On 19/11/2013 4:20:19 PM Location N:\SAMBUNG STUDY\modul 12 - project paper dissertation (ems

2106)\data\NVIVO\OSHMS.nvp By SALEHUDDIN By SALEHUDDIN Attributes Documentation Items40 1 - VMO Picture 10 - policy-stop_work Document 11 - organisation Picture 11 - organisation video Video 12 - shell org Document 13 - qhsse org Document 14-16 - Role & Task Document 17 - HSSE Committee Meeting 350 Document 18 - HSSE Committee Meeting 350 Document 19 - PINM Statistical Analysis YTD Document 2 - policy-hsse Document 20 - minimum_health_management_standard Document 21 - HSEMS vs OHSAS18001 Document 22 - hsse_ms_manual Document 23 - oil_spill_response_plan Document 24 - Crisis Management Plan Document 25 - ERP Emergency Response Plan Document Project Summary Report Page 1 of 7

26 - business_continuity_contigency_plan Document 27 - Permit To Work System Document 28 - RamGuide Document 29 - Job Hazard Analysis Document 3 - policy-drugs Document 30 - Hazard & Effect Management Process Document 31 - Management of SRC Refined Products & Hazardous Substances Document 32 - Precautions Against H2S Poisoining Document 33 - Unsafe Act Auditing Document 34 - External Audit Action Item Closure Procedure Document 35 - checklist for new recruit Document 36 - RFW-P108-F01 Customer Survey Document 37 - RFW-P106-F01 Management of Change Form Document 4 - policy-er Document 41 - HSSE Document Master List Document 42 - HSEMS vs ISO14001 (updated1) Document 43 - doc Control pROCEDURE Document 44 - Internal Audit records procedure Document 5 - policy-hiv_aids_hepatitis Document 6 - policy-mobile_phone Document 7 - policy-sexual_harassment Document 8 - policy-smoking Document 9 - policy-vehicle Document

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Free Nodes Items 46 Allows Thought Process Free Node Assesment on Needs Basis Free Node Big Financial Resource Free Node Checklist Focused Thought Process Free Node Commitment Challenge Free Node Compliance Mindset Free Node Departments Role and Task Free Node Example Safety Spending Free Node Financial Needs Channel Free Node Focus on Maintaining Free Node Focus on Past Experience Free Node Gaps in Requirement Free Node Implementation Challenge Free Node Initial Review Unidentified During Data Collection Free Node Involvement Challenge Free Node Lack Financial Consideration Free Node Project Summary Report Page 2 of 7

Lack Ground Map to Support ERP Document Free Node Lack Health Matters in OSHMS Free Node Lack Improvement Mindset Free Node Lack Involvement Free Node Lack Objectivity Free Node Lack of Initial Review Reference Free Node Lack of Legacy Free Node Lack Procurement and Contract Involvement Free Node Lack Recognition Free Node Lesson Learnt Basis Free Node Loss Costing but no Cost Benefit Free Node Mother Document Free Node No Specific Cost Analysis Free Node Non Holistic Accountability Free Node QHSSE SRC PD Organisation Free Node Questionnable Competency Free Node Reactive Mindset Free Node Reliance on Tools Free Node Responsibility to Ownership Free Node Rigid to Categories for High Hazard Free Node Shell Organisation Free Node Spend when Obliged Free Node SRC PD Organisation Free Node Supporting Document Free Node Supporting Plan Free Node Supporting Policy Free Node Supporting Procedure Free Node Top Down Approach Free Node Top Intent not Absorbed Down Free Node Well Defined Policy Free Node Internals Items Sub-folders 4

Interviews Items 5 1 - Operational HSE Audio 2 - Head of HSSEMS Audio 3 - HR Rep (Op Training Coordinator) Audio 4 - OHN Audio 5 - OHD (Physician) Audio

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Models Items 8 Compliance Rigidness Dynamic Model Financial Cost Dynamic Model Involvement Dynamic Model Objectivity Dynamic Model Positive Aspects Dynamic Model Suggestions from Data Dynamic Model THOUGHT PROCESS Dynamic Model THOUGHT PROCESSES Dynamic Model Observation Items 2 meeting hssseq Audio safety induction FULL Video Relationship Types Items 3 Associated Relationship Type is a Cause of Relationship Type is a Characteristic of Relationship Type Relationships Items 50 Compliance Rigidness (is a Cause of) Assesment on Needs Basis Relationship Compliance Rigidness (is a Cause of) Checklist Focused Thought Process Relationship Compliance Rigidness (is a Cause of) Compliance Mindset Relationship Project Summary Report Page 4 of 7

Compliance Rigidness (is a Cause of) Lack to Improve Mindset Relationship Compliance Rigidness (is a Cause of) Mother Document Relationship Compliance Rigidness (is a Cause of) Reactive Mindset Relationship Compliance Rigidness (is a Cause of) Reliance on Tools Relationship Compliance Rigidness (is a Cause of) Rigid to Categories for High Hazard Relationship Financial Cost (is a Characteristic of) Big Financial Resource Relationship Financial Cost (is a Characteristic of) Example Safety Spending Relationship Financial Cost (is a Characteristic of) Financial Needs Channel Relationship Financial Cost (is a Characteristic of) Lack Financial Consideration Relationship Financial Cost (is a Characteristic of) Loss Costing but no Cost Benefit Relationship Financial Cost (is a Characteristic of) No Specific Cost Analysis Relationship Financial Cost (is a Characteristic of) Spend when Obliged Relationship Improvement Suggestions From Data (Associated) Commitment Challenge Relationship Improvement Suggestions From Data (Associated) Gaps in Requirement Relationship Improvement Suggestions From Data (Associated) Implementation Challenge Relationship Improvement Suggestions From Data (Associated) Initial Review Unidentified During Relationship Data Collection Improvement Suggestions From Data (Associated) Lack Ground Map to Support ERP Relationship Document Improvement Suggestions From Data (Associated) Lack Health Matters in OSHMS Relationship Improvement Suggestions From Data (Associated) Lack of Initial Review Reference Relationship Improvement Suggestions From Data (Associated) Lack of Legacy Relationship Improvement Suggestions From Data (Associated) Lack Recognition Relationship Improvement Suggestions From Data (Associated) Questionnable Competency Relationship Involvement (is a Characteristic of) Departments Role and Task Relationship Involvement (is a Characteristic of) Involvement Challenge Relationship Involvement (is a Characteristic of) Lack Involvement Relationship Involvement (is a Characteristic of) Non Holistic Accountability Relationship Involvement (is a Characteristic of) Responsibility to Ownership Relationship Involvement (is a Characteristic of) Top Down Approach Relationship Objectivity (is a Characteristic of) Focus on Maintaining Relationship Objectivity (is a Characteristic of) Focus on Past Experience Relationship Objectivity (is a Characteristic of) Lack Objectivity Relationship Objectivity (is a Characteristic of) Lack Procurement and Contract Involvement Relationship Objectivity (is a Characteristic of) Lesson Learnt Basis Relationship Objectivity (is a Characteristic of) Top Intent not Absorbed Down Relationship Positive (Associated) Allows Thought Process Relationship Positive (Associated) QHSSE SRC PD Organisation Relationship Positive (Associated) Shell Organisation Relationship Positive (Associated) SRC PD Organisation Relationship Positive (Associated) Supporting Document Relationship

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Positive (Associated) Supporting Plan Relationship Positive (Associated) Supporting Policy Relationship Positive (Associated) Supporting Procedure Relationship Positive (Associated) Well Defined Policy Relationship THOUGHT PROCESS (Associated) Compliance Rigidness Relationship THOUGHT PROCESS (Associated) Financial Cost Relationship THOUGHT PROCESS (Associated) Involvement Relationship THOUGHT PROCESS (Associated) Objectivity Relationship

Survey Items 11 Random Respondent 1 Document Random Respondent 10 Document Random Respondent 11 Document Random Respondent 2 Document Random Respondent 3 Document Random Respondent 4 Document Random Respondent 5 Document Random Respondent 6 Document Random Respondent 7 Document Random Respondent 8 Document Random Respondent 9 Document Tree Nodes Items 54 Allows Thought Process Tree Node Assesment on Needs Basis Tree Node Big Financial Resource Tree Node Checklist Focused Thought Process Tree Node Commitment Challenge Tree Node Compliance Mindset Tree Node Compliance Rigidness Tree Node Departments Role and Task Tree Node Example Safety Spending Tree Node Financial Cost Tree Node Financial Needs Channel Tree Node Focus on Maintaining Tree Node Focus on Past Experience Tree Node Gaps in Requirement Tree Node Implementation Challenge Tree Node Improvement Suggestions From Data Tree Node Initial Review Unidentified During Data Collection Tree Node Involvement Tree Node Involvement Challenge Tree Node Project Summary Report Page 6 of 7

Lack Financial Consideration Tree Node Lack Ground Map to Support ERP Document Tree Node Lack Health Matters in OSHMS Tree Node Lack Involvement Tree Node Lack Objectivity Tree Node Lack of Initial Review Reference Tree Node Lack of Legacy Tree Node Lack Procurement and Contract Involvement Tree Node Lack Recognition Tree Node Lack to Improve Mindset Tree Node Lesson Learnt Basis Tree Node Loss Costing but no Cost Benefit Tree Node Mother Document Tree Node No Specific Cost Analysis Tree Node Non Holistic Accountability Tree Node Objectivity Tree Node Others Tree Node Positive Tree Node QHSSE SRC PD Organisation Tree Node Questionnable Competency Tree Node Reactive Mindset Tree Node Reliance on Tools Tree Node Responsibility to Ownership Tree Node Rigid to Categories for High Hazard Tree Node

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Shell Organisation Tree Node Spend when Obliged Tree Node SRC PD Organisation Tree Node Supporting Document Tree Node Supporting Plan Tree Node Supporting Policy Tree Node Supporting Procedure Tree Node THOUGHT PROCESS Tree Node Top Down Approach Tree Node Top Intent not Absorbed Down Tree Node Well Defined Policy Tree Node

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APPENDIX E: NVivo Nodes Used in Open Coding

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APPENDIX F: Interview Transcript with SHO

Interview with SHO (Operational HSSE) – Zulkarnain Mohd Said

Q.1 From your perspective, describe the Occupational Safety and Health Management System for Shell Refining Company in Port Dickson? Actually kita ada manual…..ok I tunjuk you manual and kita based on HSEMS. Actually HSEMS tu, Hj dah bagi kat saya. Dah bagi dah? Actually HSEMS tu, Hj dah bagi kat saya. Saya dah ada. Dia combine Environment dan Quality. Just nak tau your perspective and how does it stand with the other management system. Adakah dia merge, standalone atau support other management sytems. Kita gunakan kita punya management system where actually this is our mother document. The challenge is more towards implementation where you need high commitment. The important thing in Shell, we do not have that much problem especially from top management because what drives to make sure this is happening or materialize is high commitment from top management. So Shell actually, how is really work is because the top management really play their part to make sure that this is materialize. So the challenge actually is how we want to make sure that this control frame for this management system is really being practiced accordingly to what have been stipulated in this document is to make sure that we continuous effort and monitoring. So, in Shell we have very good initiative….. we have very good I would say, many essential tool that help to make this happen. But the challenge is how we want to actively use this tool and make sure that we have a really close look….....errr plan to check. So sometime we have so many initiatives and if doesn’t

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stay alive, then the PDCA cycle will not work. So, the challenge is to make sure that everything we do, we must have a really close look to ensure that it is really effective. So for example we have an audit tool. We have a lot of audit tool……we have internal, we have external…… but the important thing is to make sure that this is going on. So if I give you some sort of general statement or how we want to manage HSE Management System is we want to make sure that a close look is being sustained. To make sure that it is sustained, the resource is very important, the competency is also very important – play a very high role part of that to make sure that this tool is really perfected and being used as what it is designed for. So that will answer on the OSHMS for Shell. So I would say more towards PDCA cycle. The challenge is to make sure that is being done. Q.2 Is it an asset or liability? Please elaborate. Cik Zul, do you think this management system is more of an asset or liability to Shell? Management system should be an asset. A liability means you do not well manage on your management system. It should be a very good asset that you use this to protect yourself and to use this to gain the objective of what you want, especially your policies. So we want to make sure that we have a direction and that will be our guide to make sure that management system is really well structured and constructively we use for our day to day activity. Q.3 How do you relate it towards the company’s Vision and Mission? Third question skip (because answered in second question). Q.4 What is your involvement in the arrangement of it? Fourth question skip (because it is obvious the role of the SHO in OSHMS). Q.5 How do you contribute towards the implementation? Fourth question skip (because it is obvious the role of the SHO in OSHMS). Q.6 How is the arrangement and implementation conducted from your point of view? Is it just sekadar fulfill OHSAS or there is another way you derive? Arrangement and implementation is conducted in a very well mannered and if you want to make something happen to make materialize, the arrangement on the planning must be in very good manner. So, what we did hear actually, we have not only by HSE driven, we want all departments and all side all other discipline own the responsibility. So, we talking about ownership is belong to individuals. So, we in HSE department some sort of support to them. We don’t want to anymore for example like a kind of policeman but we are more coaching and make things happen. So the planning and arrangement is very important. Without the arrangement and planning, we do not have a complete how we want to achieve from the management system. So, is talking about the teamwork, responsibility and accountability. So, once we decided who will be accountable for that, we have a process of system we have about almost 23….. I couldn’t get the correct number. But the processes all they have owners. So, these processes we call it like for example “permit to work” is like a critical processes that we want to make sure that what our objective and our mission can be fulfilled. So, these processes they have owners and they have to fulfill all they’re responsibility and they have to be reported every month. I give you

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simple example like myself, I have main process where “permit to work” is under me and the sponsor is my boss, and my boss definitely will make sure that I done my duty to make sure that my processes work well to contribute to the critical activities. That is one of the route to all the processes. Another process could be MOC, Management of Change. Another process could be inspection. So all this have owners to drive this to make things happen. So in a nutshell we talking about ownership and accountability to make sure that this is happening. Ada some sort of, mungkin Encik Zul keep a record of the initial review of the arrangement of the OSHMS/HSEMS ? The review, of course we have the management review that you can get here. Musa is the owner. We review this every year and to get the effectiveness of that program, of that tool to make sure that we really review where our status and where our improvement that we need to cover all the gap that we identified. So one of the content of the management review is the HSEMS? Yes. Q.7 Are there any further considerations for the arrangement and implementation besides compliance to regulations and standards? Ada additional considerations tak? Ya, of course. The first priority is to make sure that whatever we need to comply with all our Shell regulation and Shell procedure need to be complied and on other parameter that we monitor are incidents. What are the incidents that happened and what are the threats and what are the statistics and what are the precursors. Precursor means what are the signal that could for us to improve to make sure that this doesn’t happen again. So for example actually we discuss our statistic in the management review and we see what is the trend, the pattern of the incident and we also study what are the precaution and what are the steps that we need to take to make sure that doesn’t happen again. So that is on the incident. Beside incident also we take some of the feedback from the floor, from the user : what will be the best way to improve our norm. Sometime we feel that our norm could be the best solution but with the feedback from the floor from the user, that also will take into account. So I would say it is many many parameters of many many input that we use during it. Q.8 Are there any financial considerations towards the arrangement and implementation? Eighth question skip (because answered in ninth question). Q.9 What financial elements can be considered (or additional considerations) for the current Occupational Safety and Health Management Systems? Any financial considerations towards the arrangement and implementation of OSHMS? We really allocate our budget. We feel that is really is a need and in Shell that is really a top priority. We will accommodate for that and especially we in the oil and gas company we do not have much problem on costing and every time when we do a budget we see that that must be done and especially not compromise on any implication on the asset, the people, the environment… we take as very high priority. What are the financial elements that are considered during the consideration for the HSEMS?

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Example could be resources, could be equipment, could be enhancing what are the safeguarding system that to make sure it protect the whatever equipment that is protectable and we probably we need to put more financial resources to upgrade our equipment, our gadget to make sure that is safe to be used then we will consider on that. Not only on that, that is probably on equipment but on resources could be competency level, could be the training to bring any external resources that could have to improve that process. We will do that. What is the platform that Shell use to bring about this financial consideration? It’s simple… first of all it’s about legislation, if we think that will bring up to ALARP, then we have our measurement we call it ALARP : As Low As Reasonably Practicable. So as long we have to meet this ALARP condition, then that will be most justified parameters that we have to have here. What is the platform? We have one is management review, we will table out in the management review. Annual? Yes annual, another one is our yearly budget. Our yearly budget is ahead looking, where we really budget to what we really going to spend next year. So have allocate budget and this will be challenged by our top management and especially our account manager and when we justified that this should be allocated, then will table up in the budget meeting for every year. So these two I would say is the two platform we use to get our finance. In terms of the HSE, is there a specific process to calculate HSE matter, when the moment comes management review atau annual budget, during that time baru put forward. But that specific channel, procedure or process takde la? Process for what? Budget? Yes, finance. Process, procedure, I do not know how to relate that, but our review – mid year review and end year review will definitely will definitely will cover this to make sure that we allocate some budget for our we call it LE – Latest estimation where we know what sort of budget that we need to consume and if that will burst beyond the plan, we roughly know what our plan for next year. So, the best platform is more talking about the mid year review to see what is our cost status right now. Q.10 What are your suggestions to improve the current Occupational Safety and Health Management System? Last but not least, your suggestion to improve the current HSEMS. If anything, your opinion. My suggestion is, everything we do………..I would say that I was very lucky I work for a company is that safety is not only a priority but safety is a value. I have a colleague outside there where they have struggled they have challenge talking about budget talking about commitment. But for me, wherever you go, whether you are in oil and gas, whether you are in construction whether you are small company whether you are big company, important thing is the commitment and whether you have an objective, how you want to make sure that the management system been done well. The challenge here actually is what I say is first of all is commitment the sincerity whether you want to make sure that you treat the safety is really a value. If you treat safety is something that you have to do, must do then you will come out more better. Anyhow in any organization, whether in oil and gas or construction, the top management who drive this management are the one who really I would say most crucial part of it. So if you challenge, it is more to commitment on how we commit.

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APPENDIX G: Interview Transcript with Head of HSSEM S

Q.1 From your perspective, describe the Occupational Safety and Health Management System for Shell Refining Company in Port Dickson? You can answer briefly to save your time. If I need any clarification, I will ask. (He gave me a copy of the HSEMS for SRC) Q.2 Is it an asset or liability? Please elaborate. You can answer briefly. I think any management system is an asset. I would it’s an enabler. But in the end, people who execute it. I would say it’s both, because we are still binded by the legislation. Ok lah. Q.3 How do you relate it towards the company’s Vision and Mission? Third question skipped (time constraint) Q.4 What is your involvement in the arrangement of it? Your involvement? Memang you directly HSEMS but you apa? I memang the focal point. When you say focal point, meaning updating the HSEMS. Besides managing/updating the HSEMS, what else do you do? What else do I do? I’m also the so called focal point for incident investigation system. So kat sini we call it as causal learning. That’s the method that we use. Q.5 How do you contribute towards the implementation? Fifth question skipped (HSEMS guy is obviously directly involved) Q.6 How is the arrangement and implementation conducted from your point of view? Usually HSEMS atau any management system dia ada so called Initial Review. Ada any document atau file lama that I can study how it was created. Saya dah Tanya Hj, dia kata takde. Dia kata after 7 years records dia buang. Atau you have a checklist atau some sort of guideline or paperwork for the first arrangement? This is because I want to see the thought process of creating the management system, the inception of it.

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I have not seen the initial review. That’s another thing, I punya predecessor he left in March. For 3 months, this position kosong. So there is no handover for this position when I started. Kita punya HSEMS ni started before year 2000. Q.7 Are there any further considerations for the arrangement and implementation besides compliance to regulations and standards? Besides complying to legislation and standards of OHSAS atau Shell punya global HSE policy…… besides that ada any other considerations dalam reviewing arrangement of the HSEMS. I don’t think so, those 3 (legislation, OHSAS and global HSE policy) are the main governance. Actually the control framework is very encompassing. Any additional considerations? Takde. Q.8 Are there any financial considerations towards the arrangement and implementation? ……Towards HSEMS. Financial consideration……normally HSE items ni, it’s a do item… maksudnya you don’t argue whether you need to do or not. In terms of financial perpective, you just budget and spend. What about mechanism, atau specific steps when involve financial implication for anything that you want to implement. Atau you just come out with a quotation ataupun recommendation of whatever to implement. Example? Examples ranging from substitution of something sampailah ke PPE. Aaah…. hierarchy of control. Could be hierarchy of control ataupun others……training ke……itu dah admin control. I mean apa considerations that contoh lain departments, adakah training ada some sort of quota. Contohnya. I think to answer that question, conceptually ada Hazards and Effect Management Process. So this one ni macam equivalent to HIRARC. So we use this term quite common ALARP. So what it means by reasonably practicable in ALARP maksudnya you reduce the risk until towards an acceptable risk…. comparable so called resource planner. I give you one example, one scenario macam you ada this one hazard…. let’s say fire explosion, you put in some engineering control and definitely you need to put some investment so that is cost associated. So you assess what is the residual risk, so you put this one (explains the HEMP). Let’s say this one hazard/scenario the current rate is RED (further exlplain HEMP ala severity times likelihood). So we need to do something la. So definitely we will go for engineering control first and there is a cost to it and then for example you reduce the risk to yellow. Yellow meaning medium risk. So as a business we will evaluate whether this is acceptable or not. Can we continue the operation with yellow risk. How do you evaluate? Risk assessment la. In terms of finance? We try as best as possible to spend less to get maximum results. So that is financial consideration la. But at the same time, we don’t want to be so relaxed, so lenient, that we want to save so much cost in the expense of safety. We reduce until the risk is acceptable and the acceptable resource cost.

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Acceptable and reasonable is very subjective. Dia takde so called calculation….because what could be acceptable and reasonable to Shell might not be for others. People can say, no Shell is a big multinational corporation, international – global. They can afford more than this, they should take the maximum, not as low but as most practicable. Some people might say that, it is verfy grey area jugak la. (Chuckle laugh)….Concept of ALARP is that we don’t want to spend unnecessarily if the risk is already ok or acceptable towards us. Contohnya, the cheapest will achieve yellow (moderate safe), but more expensive will achieve blue (maximum safe). So how will Shell decide? Basically the risk assessment team, dia akan do the risk assessment and present to the decision makers who are accountable. Q.9 What financial elements can be considered (or additional considerations) for the current Occupational Safety and Health Management Systems? If you were to put across to finance department regarding HSEMS. What would it be? Actually, I don’t remember seeing the word finance in the HSEMS (flipping through the HSEMS). Memang takde, saya rasa itulah pengikat dia…. at the end of the day, nak tak nak you have to consider jugak finance because if its not mentioned in management system, finance will be something blurry/subjective. Good, Shell mesti buat, but what about others yang small companies, because my research ni case study at Shell, tapi kalau boleh applicable to all industries itself. Small companies kalau boleh nak elak, taknak keluar duit sikit pun. But when in the management system dah ada clause to make consideration, nak taknak dia kena buat. Betul la you kata finance… I mean integrating the business plan in the HSEMS (Browsing HSE documents on computer on showing Shell business plan) Actually, business planning in short is budgeting. Actually we are in the midst of business planning for next year by department. Q.10 What are your suggestions to improve the current Occupational Safety and Health Management System? Tenth question skipped (due to time constraint)

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APPENDIX H: Interview Transcript with HR Representa tive

Q.1 From your perspective, describe the Occupational Safety and Health Management System for Shell Refining Company in Port Dickson? Explain the OSHMS in SRC. We have local requirement and Shell global requirement. One is HSE framework where the SRC globally have to follow. Second is the Safety Management System that we have to follow and procedures. Q.2 Is it an asset or liability? Please elaborate. For this question, from your opinion, there is no right or wrong. Of course it is an asset. We don’t want to damage our environment, our machines, our people so we can do sustainable business. It is an asset that is closely related. Q.3 How do you relate it towards the company’s Vision and Mission? So indirectly that would also the relation of the HSEMS to SRC VMO. Yes. Q.4 What is your involvement in the arrangement of it? For, the HR department, what is the arrangement involvement of the Safety Health Management System? Arrangement in what sense? Arrangement, from, start – implementation – continual improvement. How the HR’s role in the management system itself. Ok, this not only HR. Everybody participate. If you ask me about HR relationship with safety there is not much link that can be made. HR per se handling union issue, all this kind of thing it is not so much on the safety. However, training yes. We train our workers to be competent in terms of HSSE and in term of day to day work. For example, there’s a machine out there, so everybody who want to put their hands on the machine must be competent. We also come out with their operational procedure. We also have safety procedure, they must be assessed competent in doing HSSE critical procedure. What does it mean by critical procedure? Any procedure that involve life saving rules. We have 12 life saving rules is critical, must be followed. Any activity that involve in life saving rules, the people must be competent. What is competent? It’s defined in HSE framework. Some weakly defined in ISO. In the

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framework you must have assessor. Independent assessor, internal assessor, external assessor on those who are assessed. So we don’t want them to get injured. So when they use this machine, what are the risks? So to fulfill that, the competence, we have a system in place, we call it HSE Level 1 assurance program for front line people. Front line people meaning those who put their hands on the machine. It can be process technician, maintenance technician, supervisor. We have 36 competent assessor. I’m the one lead assessor who train the assessor as part of resource training. So we have to show competence by going to exam. We then are given the title assessor so we can assess the people is based on normally collecting evidence. We got 1,360 assesment to be done. Massive kind of assurance program. (Shows assessments on computer and assessor related documents). I will give feedback and motivate them after the assessment. The things that we can measure, we can control better. So statistics help us to control better (shows statistic on computer). You measure things you can manage things. (proceeds to show and explain compliance report on computer). This not play play kind of thing because we take serious in safety. (shows and explain other reports for example). Q.5 How do you contribute towards the implementation? Fifth question skipped (answered in fourth question). Q.6 How is the arrangement and implementation conducted from your point of view? Sixth question skipped (seventh answer implies HR is not directly involved). Q.7 Are there any further considerations for the arrangement and implementation besides compliance to regulations and standards? In terms of legislation, regulation, are there anything that you have to comply to? On legal requirement, DOSH says for example we have to be certified on confined space entry…. so we have to the managers there, we talk to DOSH make arrangements, we talk to safety department and then run course for them, manage course. We do, yes. We are working for it. Besides complying to legislation and regulation, anything additional to strengthen, enhance more than the minimum requirements? On behalf of HR. In the plant they have the KPI, permit to work, etc. We….aah…(laugh). we….. aah (pause). We are very difficult to marry the HR with HSE. The only thing we employ people, we ask them to go for induction. Of course, when new guys come in, we train them, we manage them, we send them to induction course. Per se HR to put the blood and sweat in HSE is very difficult to explain. HR is dotted line to HSE. Q.8 Are there any financial considerations towards the arrangement and implementation? What about the financial consideration towards for the training, must it be presented and endorsed? (shows and explains training plan calendar) We pay money for only legal requirement and Shell requirement. Other than that ada juga external requirements when the needs is there. So, basically no budget constraints la. Basically no financial issues? No financial issues.

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Q.9 What financial elements can be considered (or additional considerations) for the current Occupational Safety and Health Management Systems? Fifth question skipped. Q.10 What are your suggestions to improve the current Occupational Safety and Health Management System? As a holistic, any suggestions to improve as a whole or from the aspect of HR. Auditor recognition. What do you mean recognition? Some auditors, even the manager don’t know that and no incentive. No incentive tapi you get extra burden. Auditor must me from HR? Not necessarily, it can be from anyone. On what basis hantar auditor hantar course? The boss recommends. (Mumbling) Our last audit, 3 out of 5 auditor tak datang. Only me and my friend datang. Kerja lebih. Asalkan buat je lah internal audit. (Grumbling). I assume if they are not coming because there is no recognition. Nobody wants extra work. So how to motivate? Kalau ikutkan kalau tak cukup auditor tak boleh audit, postpone. … and are there any other challenges? There are shift workers. So sometimes we call them for assessment, training. They have to be called outside their shift and make arrangements of time, working overtime, off day….. on this kind of training. This is our constraints and limitation because we have to respect their off day.

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APPENDIX I: Interview Transcript with Occupational Health Nurse

Q.1 From your perspective, describe the Occupational Safety and Health Management System for Shell Refining Company in Port Dickson? Can you tell me a bit of the OSH Management System? Basically, my role here lebih kepada Emergency Preparedness and fitness to work. Tapi yang lain tu, sub-sub to ada banyak la. Ok dari segi emergency preparedness, I need to ensure that kita align based on the Shell Framework. Yang dia ada tiers apa semua tu. So, beside that I mention pasal fitness to work, medical surveillance, programs. Itu part of the OSHMS la. Ok, my role here banyak focus on that 2 lah. First aider, itu I yang coordinate. Q.2 Is it an asset or liability? Please elaborate. From your opinion, do you think the OSHMS is an asset or liability that you comply. It’s an asset. Q.3 How do you relate it towards the company’s Vision and Mission? How do you think it relates? Yes of course it relates in terms of whoever yang comes under specification or framework need to comply for it. Once you dah fulfill nanti, I believe you akan support the VMO. Q.4 What is your involvement in the arrangement of it? In terms of your appointment. My role here lebih banyak pada coordinating dari segi coordinate with the process owner, the asset manager. For example macam medical surveillance, I rasa the most effective way is to get the key person to communicate and get the staff engagement. I go to the key person rather than I pergi to each one. Q.5 How do you contribute towards the implementation? I guess this question is also answered by your previous question. Ok, I buat coordination tadi and endure whatever the result is, I take the further action. For example, he went on mercury test ke, benzene test ke based on the result tu, then I will discuss with the OHD ke the process owner ke. From that, if things need to be investigated further…it’s a teamwork punya thing. Tapi on medical surveillance I take the big role there.

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Q.6 How is the arrangement and implementation conducted from your point of view? From your point of view, how is it conducted. It needs support from all departments. It is teamwork punya contribution yang penting. Otherwise you cannot work alone. You need to get the engagement because I believe banyak issues from the site, from the operation. Not only daripada office site. So, macam I cakap tadi, banyak kepada discussion, brainstorm. Ada apa challenges from this. When comes to the staff attitude, which they suppose to go to medical surveillance but they are reluctant banyak reason tak turn up. Have to go for the training, tak turn up training. Itu banyak lebih pada the attitude of the staff la, which is I banyak push to the manager to handle. Kalau tak memang payah. Q.7 Are there any further considerations for the arrangement and implementation besides compliance to regulations and standards? Is there anything besides, register, standards, regulations. So far I kat sini, I banyak rely on standards. Q.8 Are there any financial considerations towards the arrangement and implementation? Any financial considerations towards OH in SRC? Takde. Kalau kita nak beyond daripada standard, kita nak ‘up’kan lagi the medical surveillance or other HSE matters. Unless you ada concrete reason. Of course, I think dia nak jugak supporting document. We have to prove it. The management ok. Q.9 What financial elements can be considered (or additional considerations) for the current Occupational Safety and Health Management Systems? Dari aspect OH from your opinion? Takde, in terms of financial dah cukup. Maksud saya any additional yang memerlukan financial yang boleh ditambahbaik? Takde masalah kot. As long as you can justify, whatever you can prove to the management, they can really whatever figure. Tapi kalau dia nampak benda tu macam wasting, for example you already a trainer. Why do you go to another course because you already certified. It is not necessary to assign another person to be a trainer, which happens in one of the scenario which I see the management disagree sebab nampak macam membazir. It seems as though Shell, is unlimited funding, therefore tak perlulah cost benefit analysis? MMM (agrees). Q.10 What are your suggestions to improve the current Occupational Safety and Health Management System? Any suggestions? I takde, have no idea.

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APPENDIX J: Interview Transcript with OHD

Q.1 From your perspective, describe the Occupational Safety and Health Management System for Shell Refining Company in Port Dickson? Skip question (because of time constraints). Q.2 Is it an asset or liability? Please elaborate. Skip question (because of time constraints). Q.3 How do you relate it towards the company’s Vision and Mission? Skip question (because of time constraints). Q.4 What is your involvement in the arrangement of it? Whether directly or indirectly, adakah dipanggil? In terms of the management system, I’m not directly involved. My role is more on providing advice, in relation to health services on site. I’m covering downstream businesses throughout Malaysia including the refinery. So I get involved and influence how the OH services are being provided here. That’s how I get involved in the process and the implementation. Q.5 How do you contribute towards the implementation? Skip question (indirectly answered in question four). Q.6 How’s the arrangement and implementation conducted from your point of view? Skip question (because of time constraints). Q.7 Are there any further considerations for the arrangement and implementation besides compliance to regulations and standards? From your opinion? I think what we have done differently here in SRC and Shell in general, we have gone beyond compliance to regulation. So of course for OH, it remain as what we call, run and maintain program. Meaning to say, we maintain program so much so that we can keep in compliance with the law. Not only for the local legislation but Shell procedures. Point number two, we have gone beyond that throughout the

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activities that we implement especially what we call the wellness activities which has been introduced in the past 3 years. Which have been more and more aggressive looking at personal wellness that we like to achieve what we call the culture if health. So, we have moved from compliance towards culture of health and wellness has been our priority. Wellness is our personal health. What is the status right now? Have we achieved the culture? Yes of course. How do you measure hat you have achieved? There are a few key programs that we have. Those programs are basically as much as possible try to manage what we call disease related risk. For example the common ones would be smoking, physical activities and diets. So these are the 3 common risk factor to any chronic illnesses in the world. So all the activities are focused on these three items. For here in SRC PD I think we have incorporated a lot of things, one is what we call the wellness. We have programs one week once a year. I think that’s not all, I think there are many other programs that are related to this, we have stop smoking cessation programs throughout the year. We have competitions amongst the staff throughout the year. We have physical activities throughout the year. So, you are looking at the more comprehensive wellness activities amongst the staff meaning the organization. So, to say that is an ongoing process. Takde exact measurement? There’s a short measurement that we have conducted two years ago, what we have observed in SRC PD, we have previously issues on fitness to work, unable to perform their job for example they were obese and obesity also related to spinal problem, back pain and a quite a number of unfit. 3 years ago the number is something like 20 to 30 people who have been certified unfit so they cannot do specific tasks. So, it’s a loss to the company. So what we have achieved today, I think we have reduced the number to something like 5. Now we have reduced the number down to at least to 5 in 3 years. Some of the things which is not incidental or accidental. When you talk about obesity, when you talk about muscle stretching, it’s all interrelated. We see that the number of people who are unfit at the moment have been reduced to 5. There are many other factors that may contribute. At least, those are the simple things that we do, it might not be accurate statistically, but at least that is something that we have achieved to date moving towards that direction. Q.8 Are there any financial considerations towards the arrangement and implementation? Skip question (because of time constraints). Q.9 What financial elements can be considered (or additional considerations) for the current Occupational Safety and Health Management Systems? Skip question (because of time constraints). Q.10 What are your suggestions to improve the current Occupational Safety and Health Management System? Any suggestions in terms of OH or OSHMS at SRC PD. We should improve on the competent person especially the SHO and also the OHN. There is no requirement. What we do here in Shell is more of Shell requirement but so far there is none for local requirement. Local requirement does not require OHN on site, so health has not been put as important as safety. The health part punya component banyak kurang lagi. The health part I tengok banyak lagi. Health

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component is generally speaking not as good as safety. We are looking at that from our perspective. SHO competencies, I’m not sure how it is being assessed their competency from time to time but I know that questionable. They might have the certification but moving forward, what are the assessment that they need to go through to make sure that they’ve.

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APPENDIX K: Observation Notes for Safety Induction

Research Topic


AT SHELL OIL REFINERY PORT DICKSON Date: 2 Sep 13 Activity: Safety Induction Location: SRC HSSE Induction Centre Respondent Groups: New Employees OBSERVATION ITEMS YES NO N/A

Refers to company mission, vision and policy directly or indirectly. √

Notes: Only mentions about company Vision, Mission and Objective. No review or explanation given on company Vision, Mission and Objective. Clear objective or goal driven activity. √

Notes: Covers all the important scope of the safety induction which includes: visitors, permit-to-work, road safety, marine, environment, safety walks, PPE, working at height, H2S, Shell 3 Golden Rules and Shell 12 Life Saving Rules. Routine complacency. √

Notes: Safety induction is not executed complacently and conducted well. Promotes improvisation for OSH and/or improvement for OSHMS. √

Notes: There is room for improvement. Rather than teaching to comply to safety rules, it will be better if the mindset goes beyond complying by indoctrinating a thought process culture to keep safe. Room for flexibility in arrangement or implementation. √

Notes: Not applicable because safety induction is not the appropriate channel to affect or influence the OSHMS. Includes consideration towards financial implication √

Notes: Irrelevant to safety induction. Participant’s room for input in activity:

Low 1 2 3 4 5 High



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APPENDIX L: Observation Notes for HSSE Meeting

Research Topic


AT SHELL OIL REFINERY PORT DICKSON Date: 26 Sep 13 Activity: HSSE Meeting Location: SRC Meeting Room Respondent Groups: HSSE Committee OBSERVATION ITEMS YES NO N/A

Refers to company mission, vision and policy directly or indirectly. √

Notes: Reflects and guided on company policy. (Eg. Permit To Work – Chairman looks serious upon an incident of forgery on Permit To Work and further explains that employees don’t understand the significance of Permit To Work and its relation with JSA). Clear objective or goal driven activity. √

Notes: Definitely yes in this activity. Apart from LTI achieved, it was announced in the meeting that the company received the Hibiscus Award in Exceptional Achievement for 2013. The chairman did not want these awards to cause complacency and the level of standard achieved must be sustained. Routine complacency. √

Notes: The incident of forgery of Permit To Work was suspected due to complacency or the hassle of many red tapes to go through. The investigation done was not to the point of the root cause of the incident. This could be an isolated case that rarely happens. Promotes improvisation for OSH and/or improvement for OSHMS. √

Notes: Can be seen in the meeting through: (1) incident investigation, (2) bicycle management programs and bicycle safety event (after incident of an employee injured using a bicycle), (3) decrease max noise level acceptance to 115 db. Room for flexibility in arrangement or implementation. √

Notes: Reassess: (1) medical surveillance, (2) shift time work, (3) management of change for noise monitoring after discussing the noise level. Includes consideration towards financial implication √

Notes: No financial considerations were discussed (possibly due to Shell’s “big” budget or financial resources to implement any safety related issues discussed in the meeting). Participant’s room for input in activity:

Low 1 2 3 4 5 High



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APPENDIX M: Selective Coding in Nvivo 8

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APPENDIX N: Validation E-mail from HSE Manager MISC Berhad

Siti Elina Bt Abdul Rahman <[email protected]> Wed, Dec 4, 2013 at 8:29 AM To: Salehuddin [email protected]

Dear Capt,

I agree theoretically and recommend for the improvised OSH Management System to be tested in real life/industries.

Best regards,

Siti Elina Abdul Rahman

Manager, Research, Planning & Policies | Corporate Health, Safety & Environment (CHSE) | MISC BERHAD tel : +6 03 2275 3757 | fax : +6 03 2275 3931 | mob : +6 013 3884335

email : [email protected] | [email protected] | website : www.misc.com.my

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APPENDIX O: Validation E-mail from Engingeering Safety Officer Sime

Darby Energy & Utilities

zamree amin <[email protected]> Thu, Dec 5, 2013 at 4:07 PM Reply-To: zamree amin <[email protected]> To: Salehuddin <[email protected]> Dear Capt, My comment:

In improving OSHMS, generally or at a company level is not an easy task. This is due to several limitation of the company might face in order to accommodate this changes. Furthermore the company like SRC is a well established organization and has been operated since years ago. However the intention towards improving the SRC HSSEMS is consider a good approach and might be a good reference in future.

Theoretically it is possible to be done by improving the sub-elements related to the HSSEMS which might be directly involved in enhancing their daily operation. But in practical wise, it might to have a proper plan and time to adapt and absorb the changes. In other words the existing HSSEMS concept has already embedded in their culture and by changing or amend the system might affect multi level decision.

As a conclusion, the improvise HSSEMS being suggested is a cool plan and decision in upgrading the existing SRC HSSEMS.

Thank you