Libryo’s Roll Out Plan for Self Assessment Item

How does Libryo determine the Roll Out Plan for Assessment Items?

The purpose of Libryo’s Roll Out Plan for Assessment Items is to provide the user with a suggested methodology by which to address all of their Assessment Items over a period of 12 months. In the Roll Out Plan, the Assessment Items are broken down into manageable monthly chunks such that if, on a monthly basis, the Assessment Items scheduled for that month are addressed, by the end of 12 months, the user should have covered all of their Assessment Items. To spread the Assessment Items over the 12 month period, each Assessment Item is assigned a Default Due Date.

1. Default Due Dates

The assigned Default Due Date is determined based on a categorisation system developed by Libryo. This categorisation system uses two criteria:

(i) Controls

(ii) Default Risk Rating, to group similar Assessment Items together.

Upon its creation, each assessment item is given a Control and a Default Risk Rating.

2. Controls

The Controls assigned relate to what control, if any, the Assessment Item is dealing with. Examples of Controls include:

Agreements
Appointments
Assessments
Audits and Training
Authorisations
Calibration
Communication
Financial Provisioning
Insurance
Maintenance
Monitoring
Plans, Policies and Procedures
Records Management
Reporting
Verification

The Controls are applied in order to group similar assessment items together. So for example, all Assessment Items which deal with Authorisations will appear together in month 1, all those relating to Appointments will appear together in month 2, all those relating to Reporting appear together in month 3 and so on. Rather than as a means of prioritizing the Assessment Items, the Controls serve as a means of logically grouping the Assessment Items together and therefore assisting the user in being able to address similar Assessment Items at one time.

3. Default Risk Ratings

It is difficult to apply ratings to Assessment Items, which are applicable based on different legal requirements, in different locations and different types of industry. An obligation in one instance may have a different significance to another instance and this will vary from location to location and industry to industry. It is for this reason that Libryo has not used a ‘quantitative’ methodology to apply the risk rating based on consequence, but rather used an ‘Environmental or Health and Safety Impact’ approach.

The risk rating is applied to provide guidance on conducting compliance evaluations or self assessments and compliance thereof, rather than a priority on actioning or implementing the requirements of the law, even though, where non-compliance occurs an action item or task is required.

The methodology and criteria used is the following:

High Risk

All authorisations (permits, licenses, approvals, registration, certificates)
High risk activity risk assessments
Controls to prevent or correct a significant impact on the environment
Controls to prevent or correct a significant risk to the health and safety of personnel

Medium Risk

Reporting relating to significant environmental impact (emission results, effluent results)
Reporting relating to significant health and safety risk (Incidents, emergencies)
Record keeping relating to significant environmental impact (emission results, effluent results)
Record keeping relating to significant health and safety risk (Incidents, employee exposure, medical)
General baseline risk assessments
Controls to monitor environmental performance (monitoring, measuring)
Controls to monitor health and safety performance (inspection, testing, maintenance)

Low Risk

Reporting relating to activities and processes (waste management activities, stormwater activities)
Record keeping relating to processes (waste management activities, maintenance records)
General policy or information communication (display health and safety policy)

During the assigning of risk ratings, if there is uncertainty between two ratings, the precautionary principle is applied and the higher rating is assigned.

The Resulting Roll-Out Plan

The outcome of this categorisation system is a suggested Roll Out Plan for systematically addressing the Assessment Items applicable to a Libryo Stream. The Assessment Items with similar controls are grouped together per month and ranked from High Default Risk to Low Default Risk.

This Roll Out Plan is Libryo's suggested approach. In order to ensure flexibility for subscribers to Libryo's Assess Module, there are also other subject categories (e.g. Waste Management, Air Quality Management, Hazardous Substances Management etc) by which users can group their Assessment Items should they so wish.