CMP for Special Regs and Safety Issues. 1. INTRODUCTION Purpose Scope Submissions to Australian Sailing:...
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1 CMP Policy - AS i Australian Sailing CMP for Special Regs and Safety Issues 1. INTRODUCTION Purpose Scope Submissions to Australian Sailing: CHANGE MANAGEMENT PROCEDURE (CMP) CMP Initiator (Members, Clubs, and Owners) Stakeholder Safety Bodies AS National Safety Committee RESPONSIBILITIES CMP Initiator (Members, Clubs, Owners): MYA or Class Association AS Safety Representative APPENDIX A CHANGE MANAGEMENT PROCEDURE (CMP)... 1 APPENDIX B AUSTRALIAN SAILING GUIDELINES FOR RISK ASSESSMENTS... 1 DOCUMENT CONTROL RECORD REVISION HISTORY... ERROR! BOOKMARK NOT DEFINED.
2 CMP Policy - AS i Australian Sailing Terms and Definitions CMP Change Management Procedure for Special Regulations and Safety Issues (refer Appendix A) Final Risk Rating Initial Risk Rating The final risk after implementing additional treatment, control or change The existing risk without additional treatment, control or change Risk Effect of uncertainty on objectives. An effect is a deviation from the expected positive or negative. Risk is often expressed in terms of a combination of the consequences of an event and the likelihood of occurrence. Uncertainty is the state (even partial), of deficiency of information related to understanding the likelihood and consequences of an event. Risk Management Coordinated activities to direct and control an organisation, with regard to risk. Risk Assessment Overall process of risk identification, risk analysis and risk evaluation. Risk Identification Process of finding, recognising and describing risks Risk Analysis Process undertaken to comprehend the nature of risks and to determine the level of risk. This process provides the basis for risk evaluation. Risk Evaluation Process of comparing the results of risk analysis with risk criteria and to determine whether the risk and its magnitude are acceptable or tolerable. Risk Assessment Overall process of risk identification, risk analysis and risk evaluation Risk Level A Unacceptable. Additional control measures must be sought and evaluated to assess their reasonable practicability as a priority. Risk Level B Undesirable. Additional control measures must be sought and evaluated to assess their reasonable practicability, however priority should be given to risks with a high risk rating. Additional or enhanced control measures should only be discounted if their cost of implementation is demonstrated to be grossly disproportionate to the potential benefit.
3 CMP Policy - AS ii Australian Sailing The level B risks are further categorised as B+ and B- to enable a further degree of prioritisation and relative importance. B+ risks are considered to be on the verge of being unacceptable and must be given immediate priority Risk Level C Tolerable. Additional control measures should be sought and evaluated to assess their reasonable practicability, however priority should be given to risks with a higher risk rating. Additional or enhanced control measures should only be discounted if their cost of implementation is demonstrated to be disproportionate to the potential benefit. The level C risks are further categorised as C+ and C- to enable a further degree of prioritisation and relative importance. Risk Level D Broadly acceptable. Additional control measures should be sought and evaluated to assess their reasonable practicability, however priority should be given to risks with a high risk rating. Risk Treatment Process to modify an identified risk.
4 CMP Policy - AS Page 1 Australian Sailing 1. INTRODUCTION 1.1. Purpose The purpose of this procedure is to describe the Change Management Procedure used to change the Special Regulations and influence other safety issues. This procedure ensures that whenever a change is proposed or a safety hazard is identified, the associated risks are assessed and reduced to a level As Low As Reasonably Practicable (ALARP) Scope Application of this process is required for all proposed changes to Australian Sailing (AS) Special Regulations that could potentially impact safety. These include, but are not limited to changes to Special Regulations that: introduce systems and/or equipment; require physical modifications of existing systems and/or equipment; specify maintenance, inspection and certification requirements where these may impact safety. specify organisation, management and operational requirements where these may impact safety. The following changes are excluded from the scope: requests for Clarification of Existing Special Regulations (refer CESR procedure); those of an administrative or routine nature that do not impact on safety; emergency measures introduced for a limited period of time; and like for like changes with no potential for an adverse safety impact Submissions to Australian Sailing: Submissions to Australian Sailing for changes to the Special Regulations or actions dealing with safety issues must follow the CMP process for identifying and managing risks. Details of the CMP and its findings must be included in the submission to Australian Sailing. This process is described in sections 2 and 3 (refer Appendix A for CMP form). MYAs and affiliated National Class Associations should consider the following when making submissions to AS seeking changes to the Special Regulations.
5 CMP Policy - AS Page 2 Australian Sailing Has there been adequate communication and consultation with all interested parties or stakeholders? Is the risk or any related change proposed or considered within the context of yachting in Australia? Has the risk been comprehensively identified and detailed? Has the likelihood of occurrence and potential consequence been analysed? Does the assessment fairly represent the real level of risk? If the risk requires treatment, what options are recommended? Are the recommended treatments cost effective in consideration of its initial risk rating? Have the above details been included in the submission to Australian Sailing?
6 CMP Policy - AS Page 3 Australian Sailing 2. CHANGE MANAGEMENT PROCEDURE (CMP) An overview of the CMP process is show in figure 2.1. The process is described in the following sections 2.1 to 2.3.
7 CMP Policy - AS Page 4 Australian Sailing Figure 2.1 Overview of Change Management Procedure (CMP) process When making submissions stakeholders should provide as much information as possible. This should include risk assessment details, summaries of meetings and correspondence from the consultative process and reports from the monitoring/review processes being used. Submissions will be considered by the National Safety Committee in accordance with Australian Sailing s National committees Policy BUS CMP Initiator (Members, Clubs, and Owners) A change can be initiated by any interested party including: Affiliated clubs or classes; Boat owners and crews; Accredited officials; and Relevant marine industries or businesses. Step 1 Establish the context of the CMP The initiator should establish the context of the proposed change. This may be triggered by at least one of the following: A hazard that is required to be removed; Recurring safety issues or incidents; A significant safety incident of severe consequence to lives and/or property; Identification of potential hazards; and The initiator must complete the CMP form (refer Appendix A). These forms can be obtained from the Australian Sailing web site. The initiator should complete the first page of the CMP which includes: title; description of the problem/issue/hazard; scope of the problem/issue/hazard (e.g. Australia-wide, a particular geographical location, a specific class of yacht);
8 CMP Policy - AS Page 5 Australian Sailing context of the proposed change; and proposed description of a new Special Regulation or a change to an existing Special Regulation. If the proposed change is a Change of an Existing Special Regulation that has no bearing on safety, the initiator should defer to the Change of Existing Special regulation (CESR) form. When completing the CMP, a formal Risk Assessment must be undertaken before the CMP is submitted to Australian Sailing. The Initiator should seek assistance from the relevant MYA or Class Association to complete the Risk Assessment Stakeholder Safety Bodies Step 2 Identify the Risks of the proposed change The relevant MYA or Class Association shall appoint a Safety Officer to co-ordinate the development of the CMP. On receiving the CMP, the nominated Safety Officer will confer with the initiator and organise a risk assessment workshop. The participants of the risk assessment workshop will included the initiator and other interested stakeholders and/or subject matter experts. The workshop will identify and document all the Safety Risks associated with the hazard/issue/problem identified in the CMP. Step 3 Analyse and Evaluate Identified Risks For each identified risk, the workshop will conduct a risk assessment using the Risk Assessment Guidelines (Appendix B). The outcome of the risk assessment is an Initial Risk Rating for each identified risk. Only identified risks with an Initial Assessed Risk Rating of greater than C+ are deemed a priority. All other identified risks should be initially locally at the discretion of the MYA or Class Association, and forwarded to Australian Sailing as capability permits. The rating of a risk previously considered tolerable may change to significant as circumstances in the Sailing community change. Such triggers might include, one or more local or international incidents increased risk and safety awareness.
9 CMP Policy - AS Page 6 Australian Sailing Increasing demand for safety performance and associated tightening of risk criteria by Australian Sailing or the wider community Identification of weaknesses of existing controls, such as through near misses, reports or audits Emergence of new risk controls in the Australian or international yachting communities which represent good practice The Risk Assessment Workshop will rank all risks (from highest to lowest). Step 4 Treat the Risks For each such identified risk one or more possible risk controls are to be considered. A risk control is a proposed change to a Special Regulation or a proposed new Special Regulation that reduces the risk. When the list of possible risk controls for each such risk has been identified, each control must be further evaluated. This is achieved by conducting a new risk assessment based on the assumption that the proposed risk control was implemented ( what-if scenario risk modelling). The difference between the initial risk rating (without risk control) and the final risk rating (after introduction of proposed risk control) is a measure of the effectiveness of the proposed control. Risk controls will then be ranked by the workshop participants in order of cost effectiveness. For each ranked risk control, the workshop participants should conduct an Impact Assessment in order of effectiveness of the control. The Impact Assessment will consider the impact of each potential change on: safety risk profile (assessed change in risk); scope (fleet, class, region or country); cost; interfacing rules and regulations (does this potential change have an adverse effect on any other rule or regulation?); introduction of new risks (does this potential change introduce any other risks to the sport such as safety, participation levels, or reputational)
10 CMP Policy - AS Page 7 Australian Sailing performance and participation; implementation (is this risk control feasible?); and compliance (is this risk control enforceable?). When all solutions have been considered and treated, a summary matrix can be drawn up that compares the various potential changes. The summary matrix will identify the preferred risk controls. When considering risk treatment options, the preference should be to find reasonable and practicable ways to eliminate the risk. If the risk cannot be eliminated, find reasonable and practicable ways to reduce the risk. Once reasonable and practicable control options have been implemented with respect to any residual risk, determine if the final (residual) risk is tolerable. Specialists may need to be appointed to verify various estimates and assumptions that may not have been available at the time of the workshop. The purpose of such verification is to confirm the feasibility of each proposed risk control. The verification process may include (but is not limited to): detailed Cost/Benefit analysis; review/interpretation of some Rules and Regulations; legal and medical advice; engineering and naval architect advice; and safety practitioners opinion; The workshop participants should decide on what additional subject matter expertise is required. The Safety Officer must co-ordinate any additional information and if necessary, convenes another workshop. The Safety Officer will assist the initiator to complete the CMP for presentation to the local MYA or Class Association. Step 5 Review and Endorsement of CMP On completion of the CMP, the Safety Officer will review the submission and ensure that sufficient information is provided. The Safety Officer will sign off that the CMP has been adequately reviewed.
11 CMP Policy - AS Page 8 Australian Sailing The CMP is subject to MYA or Class Association endorsement and its submission to AS. If the CMP is rejected at any stage, the Safety Officer will notify the initiator of the reasons for the rejection AS National Safety Committee Step 6 Communicate/Consult CMP Nationally CMPs received by AS will be registered and the National Safety Committee will appoint a working group, sub-committee or safety officer to manage the review process. The National Safety Committee or its appointed nominee must collate all comments and either accept or reject the CMP. If the CMP is recommended for acceptance, it will be referred for NSC approval. The National Safety Committee or its appointed nominee may at its discretion seek comment from other MYAs, Class Associations and selected clubs. If there is insufficient information in the CMP, the AS Safety representative may reject the CMP and return it to the MYA or Class Association with a request for more information. Step 7 Review Submitted CMP Subject matter experts may also be appointed to assist with reviews and advise the NSC and its working groups or sub-committees. It is not the intention of AS to repeat workshops and risk assessments that may have been conducted by MYAs and Class Associations. AS will use a verification process to confirm that submitted CMPSs do not introduce any additional risks. Following all such independent reviews, the AS Safety representative will either approve or reject the CMP. The National Safety Committee or its appointed nominee may at its discretion seek comment from other MYAs, Class Associations and selected clubs. If the CMP is rejected at any stage, the NSC will notify the MYA or Class Association of the reasons for the rejection. CMPs with insufficient support documentation will be returned to the initiating MYA or Class Association with a request for more information. In accordance with AS policies governing its committees, all changes to the Special Regulations recommended by the NSC will be referred to the AS Board for approval. Step 8 Communicate Approved Change Nationally
12 CMP Policy - AS Page 9 Australian Sailing All approved changes to the Special Regulations will be communicated nationally to all affected stakeholders and posted on the AS web site.
13 CMP Policy - AS Page 10 Australian Sailing 3. RESPONSIBILITIES 3.1. CMP Initiator (Members, Clubs, Owners): To raise a CMP when the need for a potential change which affects the Safety of yachtsmen on the water and also on shore is identified To complete an Impact Analysis that indicates the significance of the proposed change. For details of what is required by an Impact Analysis go to Appendix A and refer to the Impact Analysis section of that form MYA or Class Association To record all proposed changes To co-ordinate Risk Assessment workshops to review all CMPs Other than those simply requesting Rule Clarification To review all proposed changes for significance and for content To assist with appropriate levels of Impact Assessment, To assist with acquiring Subject matter experts as required To forward endorsed CMPS to the Australian Sailing National Safety Committee AS Safety Representative To register all proposed changes escalated to the AS National Safety Committee To review all proposed changes for significance and for content To communicate these proposed changes nationally to all relevant MYA Safety Committees To collate all responses To organise a final review by appropriate Subject Matter Experts of proposed changes as required To prepare final recommendation to AS National Safety Committee and subsequently to the AS Board To communicate AS s decision on the proposed changes nationally to all relevant MYA Safety Committees
14 CMP Policy - AS Page A1 Australian Sailing APPENDIX A CHANGE MANAGEMENT PROCEDURE (CMP) Title Initiator Date Step 1. Establish the context (What is the hazard/issue/problem/incident) Describe the circumstances that are a Safety Risk or potential Safety Risk to life and/or property within the Sailing community. Describe the scope of these circumstances. Is the risk related to Fleet, Class, Region or Australia wide? NOTE: If this request is for a Clarification of an existing Special Regulation, complete this section and go to Step 6. Step 2. Identify the risks if we do nothing. Risk 1. Risk 2. Risk 3. Risk 4. Risk 5. Risk 6.
15 CMP Policy - AS Page A2 Australian Sailing Step 3. Analyse and Evaluate the Identified Risks Use the Guide in Appendix B. Risk Assessed Risk >C+ Risks (Highest to lowest Assessed Risk
16 CMP Policy - AS Page A3 Australian Sailing Step 4. Treat the Identified Risks For each of the risks in the previous section list possible treatment alternatives. Please identify the preferred treatment option based on the impact analysis below. Risk1 Risk 2 Risk Provide an impact analysis for each of the treatment alternative above. Also attach supporting data, reports, subject matter expert opinion etc. Risk1 Alternative 1 Current Situation New Situation Part A. Initial impact Analysis (compulsory) What are the current and proposed Safety Risk Ratings (refer workshop)? Does the proposed change impact a Fleet, Class, Region or all yachts? What is the cost of not implementing (loss of property, lives etc.? What is the estimated cost of implementation? Are any other Special Regulations impacted? What is the impact of the change on yachting performance? Is this solution feasible? E.g. Can the equipment be sourced? Does it work somewhere else in the world? Is the solution relevant to Australian conditions? Is this solution enforceable? Part B. Detailed Impact Statements (specify which additional Subject Matter Experts might be required and Why) Detailed Cost/Benefit analysis Review/Interpretation of some Rules and Regulations Legal advice Engineering/Technical advice Safety Practitioners opinion Occupational Hygienists opinion Other (Please specify)
17 CMP Policy - AS Page A4 Australian Sailing Risk1 Alternative 2 Current Situation New Situation Part A. Initial Impact Analysis (compulsory) What are the current and proposed Safety Risk Ratings (refer workshop)? Does the proposed change impact a Fleet, Class, Region or all yachts? What is the cost of not implementing (loss of property, lives etc.? What is the estimated cost of implementation? Are any other Special Regulations impacted? What is the impact of the change on yachting performance? Is this solution feasible? E.g. Can the equipment be sourced? Does it work somewhere else in the world? Is the solution relevant to Australian conditions? Is this solution enforceable? Part B. Detailed Impact Statements (specify which additional Subject Matter Experts might be required and Why) Detailed Cost/Benefit analysis Review/Interpretation of some Rules and Regulations Legal advice Engineering/Technical advice Safety Practitioners opinion Occupational Hygienists opinion Other (Please specify) NOTE: Repeat this page for all alternative Risk Controls considered where the original Risk was considered significant (>C+). Step 5. MYA or Class Association Review and Endorsement Reviewed by (MYA CEO) Name: Date: Endorsed by (MYA President) Name; Date:
18 CMP Policy - AS Page B1 Australian Sailing APPENDIX B AUSTRALIAN SAILING GUIDELINES FOR RISK ASSESSMENTS NOTES: Only risks identified with a Final Assessed Risk Rating as being greater than C+ will be considered for a Rule Change or New Rule introduction. These risks MUST have a Risk Treatment attached to the submission. Event Frequency Historical (Likelihood) Predictive (Likelihood) Less than once every 1000 years Unheard of in the Yachting industry Not expected to occur Once every 100 to 1000 years Has occurred once or twice in the Yachting industry, but not in Australia. May occur only in exceptional circumstances Once every 10 to 100 years Has occurred many times in the Yachting industry, but not in Australia. Could occur at sometime but not likely Once every 1 to10 years Has occurred once or twice in Australia. Expected to occur at least once in the next 10 years if performing similar activities More than once per year up to and including 10 times per year Has occurred frequently in Australia. Expected to occur at least once this year if performing similar activities More than 10 times per year Has occurred frequently at specific locations Expected to occur at least once this month if performing similar activities F1 F2 F3 F4 F5 F6 Consequence Incredible Improbable Remote Occasional Probable Frequent >10 Fatalities C6 Disastrous B- B+ A A A A 2-10 Fatalities 1 Fatality (2-10 Major injuries) 1 Major injury 1 or more minor injuries First aid treatment or illness/injury not requiring treatment C5 Catastrophic C+ B- B+ A A A C4 Critical C- C+ B- B+ A A C3 Major D C- C+ B- B+ A C2 Minor D D C- C+ B- B+ C1 Negligible D D D C- C+ B- Definition for Use-at MYA Level This matrix can be used for the assessment of all risks identified. When there is insufficient data or considerable difference of opinion at the Risk assessment Workshop, this matrix needs to be supported by additional expert opinion and/or credible industry statistics. There are 3 options for descriptors which can be used to determine the frequency category. One set of descriptors which can be used to determine the frequency category. One set of descriptors is provided for frequency, one for historical likelihood, and one for predictive likelihood. Choose the most appropriate. To score the risk, follow the steps: 1.Identify the magnitude of the credible consequences if the risk were to occur. If applicable, risks should be considered in terms of the safety (this matrix), commercial and environmental impact (using other matrices). 2.Identify the likelihood of this level of consequence occurring. (This is done after considering the effectiveness of the current controls in place) 3. Score the risk using the combination of likelihood and consequence ranking. Note: Where there are a range of credible consequences which may lead to a different level or risks and/or where the controls may be different. It may be useful to score the risk more than once.
19 AUSTRALIAN SAILING
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