Housing Authority Safety Auditing System

February 1996: a consultancy agreement was entered into between the then Works Branch of the Government and the OSHC for the latter to manage the Independent Safety Audit Scheme (ISAS), establish a scheme for the accreditation of independent safety auditors, and develop a safety auditing system suitable for the Hong Kong construction industry.

December 1996: the Hong Kong Housing Authority (HA) joined the Scheme and the Occupational Safety and Health Council (OSHC) was invited to develop and manage a safety auditing system for the Scheme—the Housing Authority Safety Audit Scheme. The aim of HASAS was to evaluate the occupational safety and health performance of Housing Authority projects through independent safety audits undertaken by competent safety auditors accredited by the OSHC. The Scheme was also aimed at promoting safety management and enhancing safety standards in the construction industry.

November 1999: the Government introduced a set of safety management regulations under the Factories and Industrial Undertakings Ordinance to further enhance industrial safety standards.

April 2002: the Factories and Industrial Undertakings (Safety Management) Regulation came into effect, making it mandatory for contractors and proprietors of certain industrial undertakings to establish safety management system comprising 8 - 14 key elements.

The system is divided into two parts:

Part A—covers the Safety and Health Management System that is evaluated through Elements 1 to 13.

Part B— concerns the implementation of the Safety and Health Management System (Process Control), that is evaluated by Element 14.

Under the system, key elements and high-risk sections are categorized as critical pass items, carrying critical weighting. Safety audit scores are linked to the Pay for Safety, Environment and Hygiene Scheme. Checklists are then devised for high-risk items and heavier weighting for physical implementation aspects/items are introduced to enhance the effectiveness of the auditing system.

Random Selection Mechanism

1. HA contracts are categorized into Project Table A and Table B:
   
   • Table A : Building Contracts, District Term Contracts, Lift Maintenance Contracts, and other types of contracts such as Foundation Contracts, Civil Engineering Contracts and Ground Investigation Term Contracts with contract period of more than 2 years.
   • Table B : Demolition Contracts, Redecoration Contracts, Lift Addition Contracts, Lift Modernization Contracts, Lift and / or Escalator Installation Nominated Subcontracts (in case of reselection of ASA) and other types of contracts such as Foundation Contracts, Civil Engineering Contracts and Ground Investigation Term Contracts with contract period of not more than 2 years.
2. The ASAs in the list maintained by OSHC is categorized into Grade A to D depending on their performance in the immediate past 4 quarters. HA would feedback to OSHC on the ASAs’ auditing performance quarterly.
   

   ASA performance Grading	ASA Performance Score
   Grade A	>=90%
   Grade B	>=80% and < 90%
   Grade C	>=70% and < 80%
   Grade D	< 70%

3. When a new contract is included in the Project Table A, HA will conduct random selection of an ASA from the list of ASAs using computer programme after OSHC has finished checking on (a) workload for HA’s works contract, (b) any conflict of interest, (c) availability of ASAs, and (d) whether they have been selected and appointed for a contract in the Project Table A in the current selection cycle.
   
   • The ASA who has been selected and appointed as an auditor of a contract in the Project Table A in the current selection cycle will be excluded from random selection for all other new contracts in the Project Table A in the same selection cycle.
   • An ASA who is selected and appointed as an auditor of a contract in the Project Table B can still be included in the list of ASAs for selection of an auditor for a new contract in the Project Table A.
   • When all the interested ASAs have been selected and appointed for a contract in the Project Table A in a current selection cycle, then the list of ASAs will be reset for selection in the next selection cycle.
   • A confirmation email will be issued to those ASAs not being selected and appointed in the current selection cycle before starting a new selection cycle.
4. When a new contract is included in the Project Table B, HA will conduct a random selection of an ASA from the list of ASAs using computer programme after OSHC has finished checking on (a) workload for HA’s works contract, (b) conflict of interest, (c) availability of ASAs, and (d) whether they have been selected and appointed for a contract in the Project Table B in the current selection cycle.
   
   • The ASA who has been selected and appointed as an auditor of a contract in the Project Table B in the current selection cycle will be excluded from random selection for all other new contracts in the Project Table B in the same selection cycle.
   • An ASA who is selected and appointed as an auditor of a contract included in the Project Table A can still be included in the list of ASAs for selection of an auditor for a new contract in the Project Table B.
   • When all the interested ASAs have been selected and appointed for a contract in the Project Table B in the current selection cycle, then the list of ASAs will be reset for selection in the next selection cycle.
   • A confirmation email will be issued to those ASAs not being selected and appointed in the current selection cycle before starting a new selection cycle.
5. If a new ASA joins the list of ASAs in a selection cycle, he/she will be included in the current selection cycle for random selection after checking on the workload, conflict of interest and availability (Please refer to the random selection mechanism in paragraph 3 and 4 above).
6. The maximum number of HA contracts to be handled by each ASA are 5 nos., 4 nos. and 3 nos. for ASAs with Grade A, B and C performance gradings respectively. The allocation ceiling of HA contracts to be handled by ASAs with different performance gradings shall be as follows:
   

   	Maximum number of HA works contracts
   Latest Performance Grading	Project Table A	Project Table B
   Grade A	3	2
   Grade B	2	2
   Grade C	1	2

  The existing total number of HA works contracts handled by an ASA will be counted as workload. An ASA with total existing workload reaching or over the ceiling would not be included in random selection.

7. The balloting chance will take into account the overall “latest” performance of ASA based on his or her performance in all contracts in hand for the past four quarters, i.e. on a rolling basis.
8. After the assessment, the performance grading would affect the balloting “chance” (or number of ballot ball(s)) for each ASA in the random selection exercise in the following quarter (The number of balloting chances would be 3, 2 and 1 for ASA with Grade A, B and C performance respectively).
9. The balloting chance is reduced by 1 for any ASA who has 3 or more audit projects (Table A or B projects) in hand.
10. For ASAs without contract in hand, their latest performance will apply until they get a new contract in which their performance will be assessed again.
11. A new ASA is given a Grade B “performance” for the purpose of the random selection exercise.
12. An ASA who is given a grading of “marginally acceptable” in the quality of two audit reports in any contract(s) or a grading of ‘unacceptable’ in the quality of an audit report in any contract being undertaken by the ASA in the past 4 quarters on a rolling basis will be deprived of being included in random selection in (a) the current selection cycle if he / she has not been appointed under any contract in that selection cycle, or (b) the subsequent selection cycle in case he / she has been appointed under a contract in that selection cycle. For avoidance of doubt, those audit report(s) with “marginally acceptable / unacceptable” grading already counted for the abovementioned deprivation action in the past 4 quarters on a rolling basis will not be counted again to avoid double penalty. The relationship of quality of audit report and the deprivation of being selected for audit is as follows:
    

    	Grading in Audit Report attained by an ASA in the past 4 quarters (on rolling basis) [Report with “marginally acceptable / unacceptable” will not be counted more than once to avoid double penalty]	The ASA will be deprived of being included in a selection cycle of the following Project Table
    (i)	Either “marginally acceptable” in two audit reports in any contract(s) or “unacceptable” in an audit report in any contract in Table A.	Table A
    (ii)	Either “marginally acceptable” in two audit reports in any contract(s) or “unacceptable” in an audit report in any contract in Table B.	Table B
    (iii)	“marginally acceptable” in an audit report of a contract in Table A and a contract in Table B.	Table A

13. For an ASA who is given a grading of ‘marginally acceptable’ / ‘unacceptable’ in the quality of audit reports in three consecutive audits for a particular contract or given a grading of ‘unacceptable’ in the quality of audit reports in two consecutive audits for a particular contract, the performance of the subject ASA for the particular contract will be regarded as repetitively poor and the subject ASA will be replaced. The re‐appointment of ASA will be conducted through a random selection exercise and the subject ASA will not be included in the ASA invitation list for that particular contract.
14. Unless otherwise specified, ASAs whose performance are rated at Grade D will be suspended from participating in further audit of his / her contract and any audit selection cycle for 1 year. If the ASA concerned has other ongoing contract(s) in hand, re‐appointment of ASA will be conducted which would entail a random selection exercise. Yet, if the ASA concerned has already started audit preparation work for a particular contract and the audit plan has been approved in that quarter, he or she would be allowed to complete the relevant work for that quarter. After suspension and before uplifting of performance rating to Grade C, the ASA need to re‐apply to OSHC and pass the interview assessment conducted by the office of Hong Kong Safety and Health Certification Scheme.
15. The above mechanism helps to avoid the chance of ASAs not being selected despite repeated participation in selection and can help to split the long audit and short audit consultancy services for more even distribution of workload and more direct involvement of all ASAs in the auditing system. The random selection of an ASA from the list of ASAs using computer programme may be witnessed by OSHC or contractors but all background information of workload and performance rating of the ASAs will be kept confidential and not be disclosed to the contractors. The random selection procedure by S&H Unit comprises:
    • Preparation of an excel table of balloting chances of ASAs by a technical staff of S&H Unit based on the input of OSHC;
    • Checking of the excel table by a professional of S&H Unit;
    • Counterchecking of the excel table and executing the selection button in the excel table by the senior professional of S&H Unit in the witness of the professional and the technical staff of S&H Unit;
    • Signing the print out of the excel table by the senior professional, professional and the technical staff of S&H Unit for issue to OSHC and filing purpose.
16. HA will feedback to OSHC on the ASAs’ performance.