DOI: 10.3303/CET2290128 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Paper Received: 1 January 2022; Revised: 3 March 2022; Accepted: 27 April 2022 
Please cite this article as: Gajek A., 2022, Organizational solutions for employee training to be included in the safety management system, 
Chemical Engineering Transactions, 90, 763-768  DOI:10.3303/CET2290128 
  

 CHEMICAL ENGINEERING TRANSACTIONS  
 

VOL. 90, 2022 

A publication of 

 
The Italian Association 

of Chemical Engineering 
Online at www.cetjournal.it 

Guest Editors: Aleš Bernatík, Bruno Fabiano 
Copyright © 2022, AIDIC Servizi S.r.l. 
ISBN 978-88-95608-88-4; ISSN 2283-9216 

Organizational Solutions for Employee Training to be 
Included in the Safety Management System 

Agnieszka Gajek 
Central Institute for Labour Protection – National Research Institute, Czerniakowska 16, Warsaw, Poland 
aggaj@ciop.pl 

The Seveso III Directive has been implemented in each of the EU Member States. This means that the safety 
management systems (SMS) implementing the Major-Accident Prevention policy (MAPP) function in every 
establishment with upper and lower tier in the EU. Unlike Notification, MAPP, Safety Reports or Emergency 
plans, a SMS does not need to be a separate written document. The only guideline is Annex III of the Seveso 
III Directive. The SMS may be the part of the general management system which includes the organizational 
structure, responsibilities, practices, procedures, process and resources for determining and implementing the 
major-accident prevention policy.  
In upper tier SMS often is a part of standardized, normalized systems, but in lower tier not necessary. For this 
reason, guidelines for Small and Medium Enterprises (SME) have been developed to allow fulfil the law 
requirements and to check - audit whether these requirements are met. For prevention of the major industrial 
accidents, it is extremely important to analyse the training demand, including assigning the training level to the 
hierarchy of employees. From the other hand the analysing the available training in terms of its content and 
methods of conducting is also very important. The analysis of the available training should take into account the 
way of conducting classes - in the sequential mode for beginners, and in the simulation mode for the advanced, 
because each style is aimed at teaching and developing different attitudes. Presentation-only training is very 
common and the cheapest, but it is also the least effective. Missing and ineffective training frustrates both the 
employee and the employer. The more so because employee training is a serious burden for the employer, 
especially the SME one, because it is associated with considerable costs of the training itself, as well as with 
the absence of employee at the workplace. The level of training of employees translates directly into the level 
of safety in the establishment.  

1. Introduction 
According to the provisions of Directive 2012/18 / EU of the European Parliament and of the Council, known as 
the Seveso III Directive (Seveso III Directive, 2012), establishment operators should be subject to a general 
obligation to take all necessary measures to prevent major accidents, to mitigate their consequences and to 
take recovery measures. In art. 8 Member States were obliged to require the operators to draw up a written 
document setting out the Major-Accident Prevention Policy MAPP and to ensure its proper implementation.  
The policy must define the overall objectives and principles of the operator's actions, the role and responsibilities 
of management, as well as the commitment to continuous improvement of the major-accident hazards control 
and ensuring a high level of protection. The policy is to be implemented through appropriate measures, 
structures or through the Safety Management System SMS defined in Annex III to the Directive.  
System implementing MAPP should include such issues as organisation and personnel, identification and 
evaluation of major hazards, operational control, management of change, planning for emergencies, monitoring 
performance and audit and review. The policy and system should be commensurate with the level of major 
accident hazards and the complexity of the organization or operation profile of the establishment.  
Operators of upper-tier establishments must report to appropriate authorities by filing a safety report. The first 
point of the safety report is to demonstrate that, according to the information set out in Annex III, an accident 
prevention policy has been implemented by means of a safety management system. The obligation to file the 

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report applies only to upper-tier establishments. Lower-tier establishments are required to develop a policy and 
implement it through the system without the need to prepare a safety report. The simple diagram of relations 
between the policy, the system and the report is presented in Figure1. 

 

Figure 1. The diagram of relations between the policy, the system and the report in accordance with the 
Seveso III Directive (own drawing) 

2. Training requirements included in the Safety Management System 
In Annex III to the Seveso III Directive, the learning and training requirements are stipulated in the organisation 
and personnel sub-section. Accordingly, the safety management system should take into account: 
• the roles and responsibilities of personnel involved in the management of major hazards at all levels in the 

organisation, together with the measures taken to raise awareness of the need for continuous improvement; 
• the identification of training needs of such personnel and the provision of the training so identified; 
• the involvement of employees and of subcontracted personnel working in the establishment which are 

important from the point of view of safety. 

3. Solutions used in upper-tier establishments 
The safety management system connected with the prevention of major industrial accidents and limitation of 
their consequences may be integrated with another system or other systems, e.g. with the occupational health 
and safety management system in accordance with the PN-ISO 45001 standard. Currently, the establishments 
often have an integrated management system that includes an environmental management system, an 
occupational health and safety management system and a quality management system, compliant with the 
requirements of ISO 45001 for occupational health and safety, ISO 14001 for the environment and ISO 9001 
regarding the quality. Nowadays, the information security management system according to ISO / IEC 27001 is 
becoming important. 
Taking into account the occupational health and safety management system, in accordance with point 7 of the 
standard (ISO 45001 standard), an organization should:  

b) ensure that workers are competent (including the ability to identify hazards) on the basis of appropriate 
education, training or experience;  

c) where applicable, take measures to acquire and maintain the necessary competencies and evaluate the 
effectiveness of the actions taken. 

One of the hazard elimination and health and safety risk mitigation processes that the organization should 
establish, implement and maintain is the application of administrative risk mitigation measures, including training 
(8.1.2. Letter d). 
In the management system standards, incl. ISO 45001 or EN ISO 9001 the approach to the management system 
is based on the concept of Plan - Do - Check - Act (PCDA), the so-called Deming’s loop or cycle. 
In general, it consists of 4 consecutive steps that can be illustrated by the example of an occupational health 
and safety management system (ISO 45001: 2018): 
• Plan: identify and assess OH&S risks, identify OH&S and other risks and opportunities, and establish OH&S 

goals and processes necessary to achieve results consistent with the organization's OH&S policy; 
• Do: implement processes as planned; 
• Check: monitor and measure activities and processes against OSH policy and objectives, and report the 

results; 
• Act: take action to continuously improve the health and safety performance to achieve the intended results. 

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In ISO standards, the PCDA concept is presented graphically - below is an example from PN-ISO 45001: 2018 
(Figure 2).  

 

Fig. 2. Graphic concept of PCDA from the ISO 45001:2018(en) standard  

4. Solutions for lower-tier establishments 
In upper-tier establishments, training on major-accident prevention and emergency response shall normally be 
provided in accordance with a specific procedure developed in the establishment. This procedure indicates the 
types of mandatory training for each work station and outline the training programs. According to this framework, 
all training ensures that employees are provided with appropriate knowledge and skills in the following areas: 
• all hazards, general safety principles and basic principles of accident prevention and response, for an entire 

establishment - as part of the introductory training, basic training in occupational health and safety; 
• hazards and safety rules for individual processes - workplace instruction; 
• emergency procedures - as part of introductory, basic and periodic training. 

In addition, each employee involved in packing, loading and unloading of hazardous materials (hazardous 
substances in accordance with the nomenclature of the CLP Regulation) as well as in the inspection of vehicles 
and issuing of documents related to the transport of such materials, should be trained in accordance with the 
requirements of the European Agreement concerning the International Carriage of Dangerous Goods by Road 
(ADR).  

4.1 The measures taken to raise awareness of the need for continuous improvement 

The first of the proposed organisational solutions could be the establishment of a training and personal 
development team in the establishment. However, the aim is not to employ teachers, educators or trainers, but 
to select a group of employees. In small establishment it would be enough to select two members of staff who 
would receive professional training on techniques and methods allowing for effective training of other 
employees. It is crucial to select such people who would have a predisposition to conduct training and teach 
others. It should be remembered that the final goal is the acquisition of knowledge and development of skills by 
all employees, rather than creating a coaching personality. People from the training and development team 
would be involved in the work related to the training of employees in various areas related to the operation of 
the establishment. 
The most common organisational solution used in establishments is the use of external experts to train 
employees on site or directing employees to external training. However, in this case, the knowledge is provided 
by a person from outside the establishment, who often presents general solutions without expertise referring to 
the specifics of the establishment. After such training, it is often difficult to use the given general knowledge to 
solve specific problems occurring in the establishment.  
 

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In this case, the key is to apply the Employee 4.0 approach. The training of representatives of each generation 
should be approached in a different way, as their goals and priorities are completely different. What works for 
training for young people will not work for training for people 40+, 50+. The ability to adopt appropriate training 
methods is in this case an indicator of training effectiveness.  
The second potential organisational solution could be to make the training information public in the 
establishment, taking into account the entire hierarchy of the establishment. Due to the regulation on the 
protection of personal data, it might be sufficient to assign positions to the proposed training. This should show 
how much importance the establishment management places on safety. 
Another possible organisational solution is anticipation in the form of different development programs. For 
example, a program in which former employees could maintain contact with the establishment as mentors, 
trainers and tutors. Another option is a mentoring program where experienced managers become guides for 
those just starting out in managerial roles. The next one is the "creation of a 50+ club", i.e. an organisation for 
employees over 50. The club's goals include building motivation for continuous development among members, 
inspiring them not to give themselves a "discount ticket" due to their age, eliminating the feeling of pressure 
from younger employees, supporting professional activity and encouraging a lifestyle which will sustain this 
activity in the long-term perspective. This allows knowledge and experience to be shared (Pęciłło M. & Galwas-
Grzeszkiewicz M., 2019).  

4.2 The identification of training needs of such personnel and the provision of the training so 
identified 

The one of the common disadvantages of mandatory training programs is high level of generality and the 
excessive amount of content inadequate to the needs of the trainees. An organisational solution that can be 
used to more effectively adapt training programs to the needs of employees is to instruct the future internal 
trainers as to a scope of the necessary knowledge. 
Example to use (Clark, 2020): Each of us learned the names of twelve months in primary school and everyone 
could easily list them in the order of their occurrence during the year - this is basic knowledge. The next level of 
knowledge may be the ability to list the names of months in alphabetical order - in this case it is no longer so 
simple and not so obvious. The next level of knowledge would be to e.g. name them in order from the lowest to 
the highest number of letters.  
Similarly, in an establishment, a completely different knowledge is needed by a regular or subordinate employee 
(knowledge of the order in which months of the year occur), a middle-level manager or a manager (knowledge 
of the sequence of months in the year and alphabetical order), or a director or manager (knowledge of the order 
of occurrence of months in the year and alphabetical order and the order from the lowest to the highest number 
of letters in each name). 
It is a definitely infantile example, but it clearly shows the relation between the required knowledge and skills 
and the hierarchy in the institution. One may wonder what the purpose of explaining such an obvious issue is, 
but choosing the right training program is not at all simple or common. In this case, if a training team were 
created, it would take over the obligation to prepare a training program adequate to the positions held and the 
activities carried out. 

4.3 The involvement of employees and subcontracted personnel working in the establishment which is 
important from the point of view of safety 

In upper-tier establishments, internal emergency plans are prepared and systematically exercised. However, for 
lower-tier establishments there is no obligation to prepare such plans. Absence of legal requirement may  result 
in the failure on the part of establishment management to recognise the significance of this element of the major 
industrial accidents prevention system. 
Similarly, in many cases the systematic analysis of the response in the event of an accident is not carried out.  
Consequently, establishments may fail to ensure that the appropriate number of people undergo systematic 
theoretical and practical training as well as medical examinations to be able to participate in and to manage the 
company's rescue operations 
There have been situations in which such analyses were not updated while people assigned to the activities left 
the establishment, e.g. retired and were not replaced, which caused an evident safety gap. 
A good organizational solution is the method developed by Chistian Kunz at al. to supports systematic cultivation 
of collective tacit knowledge (Kunz Ch at al., 2017, Pęciłło M. & Galwas-Grzeszkiewicz M., 2019), which fits to 
the concept of resilience engineering. This method covers three stages:  
• workshops before starting work (pre-job workshop),  
• systematic exchange of cooperation relevant information during job execution;  
• post-work workshops. 

 

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Stage 1. The first part of the workshop is about a realistic scenario in which an experienced team member has 
to be replaced for some time by an inexperienced colleague. Each of the workshop participants takes turns 
playing the role of an absent experienced colleague. The scenario is the basis for individual reflection and for 
discussing the disturbances that may be caused by an inexperienced employee working solely on the basis of 
standards. At the same time, team members involved in the discussion identify what is missing from the official 
documentation and what they consider necessary for proper operation. 
The second part of the workshop is devoted to revealing the tacit knowledge of the team as a result of 
dysfunction, including mutual expectations and doubts. The discussion covers areas such as existing forms of 
cooperation, expectations of team members regarding this cooperation, limitations resulting from a lack of 
knowledge about team members, possible disruptions resulting from different or incompatible expectations and 
from different experiences of team members, and uncertainty about future cooperation. 
Stage 2. The systematic exchange of tacit knowledge and mutual expectations during the work builds on the 
results of the pre-workshop. A short interview is conducted with each team member three times: before, during 
and after the work. The interviews cover past cooperation in the team (successful and unsuccessful), doubts 
and knowledge from the workshops, new doubts and uncertainties about the work and the cooperation. 
Stage 3. The final workshop is devoted to discussing the work done, analysing those elements that have been 
done correctly and identifying areas for improvement. 
In the case of training for employees responsible for actions in the event of an industrial accident, the entire 
workshop/training would concern actions in the event of such an event. Practising various scenarios, especially 
representative ones, first theoretically and then practically,  can have a significant impact on making the right 
decisions and taking appropriate actions in the event of a major accident. 

5. A proposal of a solution for small and medium-sized enterprises categorised as lower-tier 
establishments 
For upper-tier establishments and for lower-tier establishments operating under integrated management 
systems, compliance with the legal requirements is not as much of a problem as it is for small and medium-
sized enterprises, which are mostly lower-tier establishments and often do not have ISO systems in place.   
The preliminary procedure has been proposed to help establishments meet legal requirements. 

Procedure 

1. Selection of at least two members of staff to be responsible for training in the field of major-accident 
prevention. In the event of one person leaving (e.ig. dismissal, retirement), the knowledge shall remain in the 
establishment. 

The following steps concern employees responsible for training.  

2. Assigning employees to groups based on:  
Option 1. being a member of the accident response team - active participation (action, reaction) in the activities 
when an accident occurs,  
Option 2. the same hazards to which they are exposed in the event of an accident (e.ig. the same type of 
hazardous substance) 
Option 3. the same hazards to which they are exposed on a daily basis during work (e.ig. the same type of 
hazardous substance).  

3. Identification of the area of knowledge required for the employees under each option separately, including  
the identification of dedicated knowledge. 

4. Verification of employees' knowledge before training.   

5. Selection of people to be trained; in option 1 - internal training of all employees.  

5. Identification of available training and analysis of the available training programs, including their division into 
theoretical and practical parts. 

7. Verification of employees' knowledge after training.  

8. Preparation of a report for the employer. 

9. Analysis according to concept of Plan - Do - Check - Act (PCDA), the so-called Deming’s loop or cycle – 
repeating points 2 to 8. 

 

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Conclusions 
For the purposes of major industrial accidents prevention, it is important to adopt a systematic approach which 
will allow the acquired knowledge to be used in the event of a major accident, when people operate under great 
pressure and stress. Requirements concerning continuous improvement and training are one of the key 
elements of the safety management system. A proper analysis of training needs in the establishment, including 
correct allocation of the training level (basic, advanced) and its programme to the level of seniority in the 
organisational structure is one of the most important factors. The methodology of adult education and training 
is paramount as it translates directly into the effectiveness of training, which in turn translates into the ability to 
successfully apply the relevant knowledge and skills in a failure situation.  

Acknowledgments 

This paper has been based on the results of a research task carried out within the fifth stage of the National 
Programme “Improvement of safety and working conditions” partly supported in 2021–2022 — within the scope 
of state services — by the Minister responsible for labour (task no. 2.SP.20 entitled “Training methods dedicated 
to the system of major industrial accident prevention (organizational solutions and management concepts)”).  
The Central Institute for Labour Protection – National Research Institute is the Programme’s main co-ordinator. 

References 

Clark R.C, 2020 Evidence-Based Training Methods: A Guide for Training Professionals, ASTD DBA Association 
for Talent Development (ATD), USA 

ISO 45001:2018(en) Occupational health and safety management systems www.iso.org (accessed 30 
November 2021) 

Kunz Ch, Wafler T., Saric N., Fischer K., 2017 Improving team resilience by supporting mindful cooperation 
awareness, 7th Resilience Engineering International Symposium, Liège (Luik) (Belgium), 26-29 June 2017, 
https://resilience-engineering-association.org (accessed 30 November 2021) 

Pęciłło M., Galwas-Grzeszkiewicz M., 2019 Assessment of the potential of organizational solutions with regard 
to the application of resilience engineering principles in upper-tier and lower-tier enterprises. Part III. Good 
practices (Ocena potencjału rozwiązań organizacyjnych w zakresie zastosowania zasad resilience 
engineering w przedsiębiorstwach o dużym lub zwiększonym ryzyku wystąpienia poważnej awarii 
przemysłowej. Część III. Dobre praktyki), CIOP-PIB in Polish only 

Seveso III Directive, 2012, Directive 2012/18/EU of the European Parliament and of the Council of 4 July 2012 
on the control of major-accident hazards involving dangerous substances, amending and subsequently 
repealing council directive 96/82/EC 

 
 
 
 
 
 

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http://www.iso.org/
https://resilience-engineering-association.org/

	lp-2022-abstract-230.pdf
	Organizational Solutions for Employee Training to be Included in the Safety Management System