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MOM Tightens Factory Registration Scheme For Higher-Risk Factories From 1 March

04 February 2010

  1. With effect from 1 March 2010, the Ministry of Manpower (MOM) will tighten the factory registration scheme for some 8,000 higher risk factories1. The new Scheme strengthens the requirements for implementation of risk management (RM) and safety and health management system (SHMS) in these factories at the point of registration. These factories include construction worksites, shipyards, metal working factories and petrochemical plants.

  2. Announcing the enhanced scheme at the bizSAFE Convention 2010 on 4 February 2010, Manpower Minister Gan Kim Yong said, "These workplaces account for more than two-thirds of workplace fatalities every year. Over the years, MOM has put in place many measures to monitor the WSH performance of such workplaces but we can do more. Going forward, we will tighten the control at the point of registration before these workplaces can commence work."

  3. Under the Scheme, registration requirements will be tightened in accordance with the level of risks in the operations of these factories. There will be two groups of factories which will have different registration requirements based on their risks levels.

    Group A – One-time registration

  4. The first group of factories (Group A) under the enhanced scheme are listed in Annex A1. These are factories including construction worksites, shipyards, wafer fabrication plants, pharmaceutical plants and metal working factories. The key enhancements made in the registration requirements are summarised below.

    a. Declaration of RM implementation – Qualifying factories will have to make an online declaration that they have implemented RM in their factories prior to commencement of business operations;

    b. Completion of SHMS audit or internal review – Qualifying factories will have to conduct an audit or internal review of the SHMS implemented in their factories and to submit the audit/review documentation to MOM within 2 months of commencement of business operations ; and

    c. One-time Factory Registration – Qualifying factories will now only need to register once with MOM and that the Certificate of Registration (CR) will be valid for the lifetime of their factory operations, unless revoked. No further renewal is required. With one-time registration, these factories will save more than $1.7 million in registration fees annually. 

  5. For details on the current and new requirements for factories in this group, please see Annex A2. For existing factories in this group, MOM will automatically convert their current CR to the new Scheme. Similarly, their CR will be valid for the lifetime of their factories, unless revoked. These factories will continue to submit their SHMS audit/internal review documents periodically, as required under the law.

    Group B – Renewable registration

  6. The second group of factories (Group B) under the enhanced scheme are listed in Annex B1. These factories work with highly flammable and hazardous materials and chemicals or handle large quantities of hazardous substances. Such work is inherently dangerous and can potentially lead to severe accidents with multiple injuries. Hence, it is crucial that their work is properly managed. Possible work risks must be identified prior to carrying out of work tasks and that comprehensive control measures must be taken to manage or mitigate the risks. The key enhancements made in the registration requirements are summarised below.

    a. Declaration of RM implementation – Qualifying factories will have to make an online declaration that they have implemented RM in their factories prior to commencement of business operations;

    b. Completion of SHMS audit or internal review – Qualifying factories will have to conduct an audit or internal review of the SHMS implemented in their factories and to submit the audit/review documentation to MOM within 2 months of commencement of business operations ;

    c. Completion of MOM Site Inspection – After a factory has submitted its application for registration, it will be inspected by MOM within 1 month. This is done before the issuance of the CR; and

    d. Extension of Renewal period for Factory Registration – Qualifying factories will have the renewal period of their factory registration extended to once every 5 years. The Ministry will conduct checks on the Process Hazard Analysis2 (PHA) for such factories upon renewal of the CR.

  7. Please see Annex A2 for details on the current and new requirements for new factories in this group. For existing factories in this group, their Factory CR will remain in force until the expiry date or unless revoked. They will be required to renew their CR based on the new requirements.

    More checks required for factories with higher risks

  8. MOM's Commissioner for Workplace Safety and Health Mr Ho Siong Hin elaborates on the need to enhance the Ministry’s former factory registration process, "At the point of registration before companies even begin operations, MOM wants to alert them to the need to manage risks properly and to put strong WSH management systems in place. Differing management approach based on the level of risks reminds companies to be mindful of the unique challenges in their operations and to tailor their risk management accordingly. By ensuring strong WSH management from the start and catering it to the needs of the workplace, MOM hopes that companies will carry through this approach throughout their operations in order to keep their workers safe at work."

  9. Elaborating on this is WSH Council Deputy Chairman Mr Heng Chiang Gnee, "The enhanced Scheme is a logical and effective approach to get companies to take all WSH considerations seriously when they are setting up their businesses. As we move towards world class safety standards, this is closely linked to building the right culture. Hence our companies must plan their WSH management right from the start, build appropriate systems and processes with due safety considerations, and align closely with the national agenda as each and every company has a part to play to help achieve and sustain the national safety goals."

    Enhanced scheme supported by industry and union

  10. MOM worked with the Workplace Safety and Health (WSH) Council to consult more than 10 industry and professional associations as well as the unions on this enhanced Scheme. The Association of Singapore Marine Industries (ASMI), National Trades Union Congress (NTUC), Singapore Chemical Industry Council (SCIC), Singapore Contractors Association Limited (SCAL), Singapore Manufacturers' Federation (SMa) and the Singapore National Employers' Federation have expressed support for the scheme.

  11. Expressing support for the Scheme is Mr Koh Juan Kiat, Executive Director of SNEF, "MOM efforts to simplify and streamline the registration and administrative process, with the fulfillment of the relevant mandated requirements, will further help ensure workers have a safe working environment in these industries."

  12. Echoing this sentiment is Mr Simon Lee, Executive Director of SCAL, "This enhanced Factory Registration Scheme is more business friendly and also sets a higher standard of safety practices. SCAL supports it."

  13. More information on the Enhanced Factory Registration Scheme is available at our website.


Annex A1

Listing of Factories under the One-time Registration Scheme (Group A)

1. Construction worksites

Any premises where any building operation or works of engineering construction is or are being carried out by way of trade or for purposes of gain, whether or not by or on behalf of the Government or a statutory board, and includes any line or siding (not forming part of a railway) which is used in connection with the building operation or works of engineering construction.


2. Shipyards

Any yard (including any dock, wharf, jetty, quay and the precincts thereof) where the construction, reconstruction, repair, refitting, finishing or breaking up of ships is carried out, including the waters adjacent to any such yard where the construction, reconstruction, repair, refitting, finishing or breaking up of ships is carried out by or on behalf of the occupier of that yard.


3. Metalworking factories with 100 or more persons employed

Any factory engaged in the manufacturing of fabricated metal products, machinery or equipment and in which 100 or more persons are employed.


4. Pharmaceutical factories

Any factory engaged in the manufacturing of pharmaceutical products or their intermediates.


5. Wafer fabrication factories

Any factory engaged in the manufacturing of semiconductor wafers.




Annex A2

Table1: Comparison of current and new requirements for registration of factories under the One-time registration scheme (Group A)

Current Registration Requirements

New Registration Requirements

No declaration of Risk Management (RM)

Declaration of Risk Management (RM) required

Since Sept 2006, RM is a statutory requirement for all factories under the WSH (RM) Regulations.
Factories are expected to implement RM but they are not required to declare that they have implemented RM at the point of factory registration.

To strengthen RM implementation, new factories have to make an online declaration that they have implemented RM in their workplaces. The declaration ensures that factories are reminded of their statutory responsibilities. Factories will now have to implement RM before making the declaration prior to commencement of operations.

SHMS audit or internal review to be conducted periodically

SHMS audit or internal review to be completed within first 2 months of operations

The submission of a SHMS audit / internal review is currently not a part of the factory registration process. However, factories are currently required under the various WSH Regulations to conduct their SHMS audits or internal review periodically.

Factories must complete their first SHMS audit / internal review within two months after the commencement of business operations. The audit / internal review documents must be submitted to MOM, otherwise, the factory certificate of registration (CR) may be revoked. Subsequent audits or internal review documents would also be required to be submitted periodically.

Registration renewed every year or every two years

One-time registration

Currently factories are required to submit an online application for a CR upon payment of the registration fee and to have the CR renewed every year or every two years upon payment of the renewal fee.

The new scheme does away with renewal of factory registration. Factories will only need to submit a one-time online registration for the CR that is applicable for the lifetime of the factory operations, unless revoked.

Registration fees to be paid for every renewal

One-time registration fees for first application only

Currently, factories need to pay a registration fee for each renewal of the CR.

Factories will only need to pay a one-time registration fee. As there is no renewal registration and fees incurred, the factories collectively will save up to about $1.7million every year in licencing fees.


 
Annex B1

 

Listing of Factories under the Renewable Registration Scheme (Group B)


1
. Oil Refineries and Petrochemical plants

Any factory engaged in the processing or manufacturing of petroleum, petroleum products, petrochemicals or petrochemical products.


2. Bulk storage terminals of toxic or flammable liquid

Any premises where the bulk storage of toxic or flammable liquid is carried on by way of trade or for the purpose of gain and which has a storage capacity of 5,000 or more cubic metres for such toxic or flammable liquid.


3. Chemical plants

Any factory engaged in the manufacturing of —

(a) fluorine, chlorine, hydrogen fluoride or carbon monoxide; and

(b) synthetic polymers.




Annex B2

Table 2: Comparison of current and new requirements for registration for factories under the Renewable Registration scheme (Group B)

Current Requirements

New Requirements for new factories

No declaration of Risk Management (RM)

Declaration of Risk Management (RM) required

Since Sept 2006, RM is a statutory requirement for all factories under the WSH (RM) Regulations. Factories are expected to implement RM but they are not required to declare that they have implemented RM at the point of factory registration.

To strengthen RM implementation, new factories have to make an online declaration that they have implemented RM in their workplaces. The declaration ensures that factories are reminded of their statutory responsibilities. Factories will now have to implement RM before making the declaration prior to commencement of operations.

SHMS audit or internal review to be conducted periodically

SHMS audit or internal review to be completed within first 2 months of operations

The submission of a SHMS audit / internal review is currently not a part of the factory registration process. However, factories are currently required under the various WSH Regulations to conduct their SHMS audits or internal review periodically.

Factories must complete their first SHMS audit / internal review within two months after the commencement of business operations. The audit / internal review documents must be submitted to MOM, otherwise, the factory certificate of registration (CR) may be revoked. Subsequent audits or internal review documents would also be required to be submitted periodically.

MOM site inspections for factory registration

MOM site inspections within one month of factory registration

Currently MOM conducts site inspections at these factories as part of the factory registration.

Under the new scheme, the factories will be subjected to a MOM site inspection within one month of the factory registration. The factories will have to clear the site inspection to verify the implementation of control measures that were specified in the RM.

Registration renewed every year or every two years

Renewal of Registration extended to once every five years

Currently factories are required to submit an online application for a CR upon payment of the registration fee and to have the CR renewed every year or every two years upon payment of the renewal fee.

Qualifying factories will have the renewal period of their factory registration extended to once every 5 years. The Ministry will conduct checks on the Process Hazard Analysis3 (PHA) for such factories upon renewal of the CR


 

1This follows the Factory Notification Scheme which was launched for 14,000 lower risk factories on 1 November 2008. Under the Factory Notification Scheme, employers need to notify to the Commissioner for WSH of their factory operations and declare that they have implemented RM at their workplaces before work can commence. With the removal of registration fees, the 14,000 factories that benefited from the Scheme saw annual savings of about $3.5 million.

2The established PHA includes Hazard and Operability Analysis (HAZOP), Failure Modes and Effects Analysis (FMEA) and any equivalent methods. It is commonly used in the petrochemical industry to ensure that all work-related risks and hazards have been properly identified and measures have been implemented to manage them.

3The established PHA includes Hazard and Operability Analysis (HAZOP) studies, Failure Modes and Effects Analysis (FMEA) and any equivalent methods. It is commonly used in the petrochemical industry to ensure that all work-related risks and hazards have been properly identified and measures have been implemented to manage them.