July 1, 2009
I was recently asked to review the safety issues related to a particular task that necessitated the handling of a flammable liquid. This is not the first such operation I have reviewed. In fact, the proper handling of flammable liquids is a topic that has come up over and over again during my career as a occupational health and safety professional. In conjunction with this evaluation, I reviewed the safety training currently being used for training the operators who perform this task.
In this case, like many, many others, the training being provided was an on-line generic training video developed by an outside safety training company that had been turned into “web-based” training. What struck me in reviewing this training was the complete and total disconnect between the operation being performed at the facility and the safety training being provided to the employees performing the work.
They had almost nothing in common.
For example -
- The facility using the flammable liquid was a clean room / laboratory operation; the training film was set in a “heavy industry” machine shop.
- The task involved handling of relatively small quantities of flammable liquids in glass beakers; the training video showed the handling of large quantities of flammable liquids in 55-gallon drums.
- No bonding and grounding is used during dispensing operations; the training video emphasized the importance of bonding and grounding.
- Employees used little PPE; the training video showed employees using respirators and face shields for protection.
Because I am currently in the process of developing several e-learning programs, I have been reviewing information on instructional design as it relates to creating web-based training programs. One of the experts in this area is M. David Merrill, a professor of instructional technology at Utah State University. One of the points he emphasizes is - simply providing information is NOT instruction. Instead, when developing training, he suggests that you start by developing a task-centered instructional design strategy.
Start with one of the tasks being performed and build training that is appropriate to performing that task. Eliminate information that is irrelevant or misleading. Focus on what is important and useful to the specific task. Apply the information to case study situations that are consistent with the content being taught. Ask students to apply the knowledge being taught to a scenario that is similar to their real-world experience. Build your training by repeating each of these steps for any other relevant tasks.
Want more information?
Go to M. David Merrill’s web site and download his paper that discusses using the use of these principles in developing an on-line first aid course in Australia. It is really cool.
© ENLAR® Compliance Services, Inc. (2009)
Posted in Training & Communication 
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June 23, 2009
The effectiveness of occupational health and safety programs is in the news.
On June 18, 2009, OSHA issued a press release announcing that it will conduct a comprehensive evaluation of its Voluntary Protection Programs (VPP) and Alliance programs to determine their effectiveness. This is OSHA’s response to a new GAO report that identified problems with OSHA’s VPP program and recommended improved oversight and additional controls.
So, how does one go about determining the effectiveness of an OHS program – or a management system?
This is not just a philosophical question.
An important requirement of OHSAS 18001:2007 is that top management review the “continuing suitability, adequacy and effectiveness” of the organization’s OH&S management system (Section 4.6 Management Review).
The meaning of this phrase was the topic of an extended discussion during the drafting meetings for OHSAS 18002:2008 (the guidance document for OHSAS 18001). The following conclusion was reached and added to Section 4.6 of OHSAS 18002:
Management Review should focus on the overall performance of the OH&S management system with regard to:
- suitability - ”Is the system appropriate to the organization, dependent on its size, the nature of its risks, etc.?”
- adequacy - “Does the system fully address the organization’s OH&S policy and objectives?”
- effectiveness- “Is it accomplishing the desired results?”
The OHSAS 18002 guidance is consistent with the dictionary definition of “effective” – “adequate to accomplish a purpose; producing the intended or expected result.”
Therefore, if one wants to determine whether a program is effective (as opposed to whether it is suitable or adequate) one needs to evaluate whether the desired results are being accomplished. It is not sufficient to focus simply on whether there are programs (i.e. “paperwork”) in place. Unfortunately, the focus of many management system reviews is on adequacy - have all the checklist boxes been checked - rather than effectiveness.
Effectiveness review is more difficult than adequacy review. In order to conduct an effectiveness review, you must answer the following questions –
- “What exactly are the specific results we are trying to achieve?”
- “How will we know whether or not we have achieved them (i.e. are the desired results measurable)?”
- “If the desired results are not easily or reliably measured, are there other metrics that need to be routinely monitored instead?”
An important caveat – for purposes of OH&S programs, the determination of effectiveness should not be limited to “counting dead bodies.” Particularly when it comes to occupational diseases, it is inappropriate to count the number of sick and/or dying employees to measure the effectiveness of our OH&S program.
© ENLAR® Compliance Services, Inc. (2009)
Posted in OHSMS Implementation 0 Comments » Trackback This Post
April 2, 2009
Apparently the Automotive Industry Action Group (AIAG) issued a position statement in March 2009 stating that although they support the integration of health and safety programs into existing management systems, they will not “specifically mandate OHSAS 18001 certification.” A recent blog post asked “Is it politics once again?”
According to the AIAG statement they firmly believe that “the use of formal management systems are necessary for effective management of health safety and environmental programs.”
AIAG’s concern appears to be that the OHSAS 18001 standard was developed by an independent group - the OHSAS Project Group chaired by BSI - rather than ISO.
This is where the “politics” comes in. Despite intensive lobbying by the OHSAS Project Group, ISO appears unwilling to develop an OHS management system standard.
Why?
The International Labor Organization (ILO) has raised objections and several member countries - including the U.S. - have consistently voted against it. An OHSMS standard seems to be the exception to the rule that any proposed ISO standard-setting activity is guaranteed to be approved.
© ENLAR® Compliance Services, Inc. (2009)
Posted in OHSAS 18001:2007 Revisions, Standards & Certification 0 Comments » Trackback This Post
March 23, 2009
I recently had the following question e-mailed to me – “What is the “Hierarchy of Controls” [referenced in section 4.3.1 of OHSAS 18001:2007] and how do I address it in the hazard control & risk assessment procedure?”
The “hierarchy of controls” is a protocol that you use when deciding what kind of control measures you are going to use to address a particular OH&S hazard. The rationale underlying the “hierarchy of controls” is that an organization should use more reliable control measures rather than measures that are more likely to fail.
Read the rest of this entry »
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March 11, 2009
I am pleased to announce that ENLAR has launched a new blog - www.managementsystemexpert.com.
The purpose of this blog is to provide real-world practical advice to assist you in establishing, documenting, implementing and maintaining an integrated management system.
This website provides information and resources to help you understand the requirements of the various management system standards - ISO 9001, ISO 14001, OHSAS 18001, etc. In addition, it provides an opportunity for you to post your questions and comments on a variety of management system topics.
An integral part of this blog is the monthly FREE teleseminar that ENLAR will be hosting. These monthly ”conversations with experts” will provide a unique opportunity for you to BOTH listen to experts on a variety of management system topics AND ask questions for them to answer in their calls.
Click here to check out this new blog. While you are there, check out the upcoming teleseminars on -
- Revision of ISO 19011 - The Challenge of Drafting a Generic Auditing Standard
- Five Steps for Achieving Employee Engagement
Thanks! I hope you like this new site.
© ENLAR® Compliance Services, Inc. (2009)
Posted in OHSMS Auditing, Standards & Certification 0 Comments » Trackback This Post
March 5, 2009
One of the requirements of OHSAS 18001 is to identify all of your workplace hazards, including those that may cause “ill health”. This includes illnesses that are made worse by a work activity. This analysis also needs to be extended to individuals beyond the borders of the traditional workplace.
ABC News reported on just such a situation last night. It included a segment on the health implications of driving a school bus and the steps Broward County, Florida has taken to address them.
What did the Broward County School Board do? Read the rest of this entry »
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February 25, 2009
Many OHS management systems and programs have a major problem – they are bloated with paperwork, inefficient in their operation and filled with busywork. These programs are often focused on the achievement of arbitrary metrics rather than improved OH&S performance. As a result, the managers of these programs are often fed-up, burned out and overwhelmed. They are also increasingly being told – “Given the current economy, you need to do more with less.”
That is the wrong message and the wrong goal.
To quote Peter Drucker – “There is nothing so useless as doing efficiently what should not be done at all.”
The goal should not be to do more with less – it should be to do less.
Read the rest of this entry »
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November 6, 2008
In a previous post, I discussed that there is no single, fill-in-the-blank, process for conducting an OHS hazard identification and risk assessment. Instead, what is needed is an assembly of individual processes that, when taken together, result in a comprehensive OHSMS risk management strategy.
It is equivalent to assembling a meal from an a la carte menu.
So what are your a la carte choices?
They are numerous and varied and include –
- Checklists and questionnaires
- Consequence / likelihood matrices
- Failure modes and effects analysis (FMEA)
- Hazard and operability studies (HAZOP)
- Exposure assessment strategies
- Bayesian analysis
- Ergonomic evaluations
- Computer modeling programs
Just as the key to healthy eating is making wise menu choices, the key to a sound OH&S risk management strategy is choosing the hazard identification and risk assessment tools that are appropriate for your organization.
© ENLAR® Compliance Services, Inc. (2008)
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October 8, 2008
What does the current meltdown of the global financial markets teach us?
To paraphrase a line from the last presidential election - “It’s the System, Stupid.”
Right now, there is a lot of finger-pointing and plenty of blame to spread around. This mess is not, however, the fault of a single individual, a single institution or, even, a single political party. Instead, it is the system that is flawed.
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August 29, 2008
The ANSI-ASQ National Accreditation Board (ANAB) is seeking public comment on its Draft Accreditation Rule A on OHSMS Program. ANAB is the U.S. accreditation body for a number of different management system standards, including ISO 9001, ISO 14001 and ANSI/AIHA Z10. ANAB has posted a link on its web site (under Public Ballots) that provides access to this draft rule.
This draft accreditation rule sets out the requirements for certification bodies to obtain accreditation to their choice of -
- ANSI/AIHA Z10, Occupational Health and Safety Management Systems (the US standard)
- CSA Z1000, Occupational health and safety management (the Canadian standard)
- BS OHSAS 18001, Occupational health and safety management systems – Requirements (the British standard, which is identical to the international OHSAS 18001:2007 standard)
Read the rest of this entry »
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