Recent Posts

Metrics Manipulation

The current news articles about the concerns raised about metrics manipulation associated with the VA Electronic Wait List reminded me of the similar concerns that have been raised about metrics manipulation related to the reporting of workplace injuries and illnesses.

One of the recurring problems with metrics is attempts to “game the system.”

Interested in finding out more?

Check out the latest issue of my Ethics in Focus newsletter – Metrics Manipulation.

This newsletter is a part of a new web-based course that ENLAR is offering in partnership with AIHA – Ethics for the OH&S Professional.  This interactive course meets the CEU training requirements set by ABIH for CIH’s to maintain their certification.

(NOTE – This edition of the newsletter also contains links to the GAO reports on the disincentives for reporting workplace injuries and the OSHA guidance on the use of safety incentive programs.  As set out in the OSHA guidance, “Reporting a work-related injury or illness is a core employee right, and retaliating against a worker for reporting an injury or illness is illegal….”)

© ENLAR Compliance Services, Inc. (2014)
July 1, 2014 | 0 Comments More

Risk vs Risks

In the April 2014 issue of the Synergist, AIHA published an article I wrote entitled Risk vs. Risks – Risk Assessment Lessons from Weather Forecasting. This article discusses the three different but related concepts that individuals associate with the term risk:

  1. Probability – What is the risk?
  2. Relevance – Is the risk important to me?
  3. Significance – How much do I care about the risk?

It is difficult to draft requirements related to risk –  as we are attempting to do in ISO 45001 – when there is a lack of clarity and consensus about what the word “risk” means.

Click here if you would like to read this article.

Have thoughts about this topic?  You can comment below.

May 12, 2014 | 0 Comments More

ISO OHSMS Standard – Update

The administrative aspects associated with the development of an ISO OHSMS standard are proceeding:

  • ISO has added PC 283 to its list of Technical Committees and there is a website page set up for its activities.  So far, no number for the standard has been announced.
  • ANSI has approved the American Society of Safety Engineers (ASSE) as the administrator of the U.S. Technical Advisory Group (TAG to PC 283) and issued a press release on July 24, 2013 announcing that ASSE is seeking TAG participants.
  • The initial meeting of TC 283 has been set for October 21-25, 2013 in London UK.

Discussion about the content of the standard – the actual specification of what needs to be included in an OHSMS – will begin in earnest later this year.

As I reported in a prior blog, the development of the ISO OHSMS standard will need to conform with Annex SL of the ISO/IEC Directives, Part 1.  This means the high-level structure of the standard and the core requirements, those elements that are common to all ISO management system standards, have already been pre-established for this standard.

Modification of these core requirements is possible, but the intent behind Annex SL is to maintain alignment between all of the ISO management system standard requirements in order to help organizations establish integrated management systems covering multiple disciplines.

© ENLAR Compliance Services, Inc. (2013)
August 26, 2013 | 0 Comments More

ISO OHSMS Standard – What Now?

Last week, I did a blog post announcing that ISO had approved moving forward with the development of an occupational health and safety management system standard.

In response, I have gotten the following question – “What now?”

Let me try to answer this question.

ISO has established a Project Committee, ISO PC 283.   This PC is charged with developing this standard.  The standard will be entitled – Occupational Health and Safety Management Systems – Requirements.  The number designation has not yet been announced.

Based on information in the New Work Item Proposal (NWIP), this standard development effort will start later this year with a meeting in the U.K. and conclude with the publishing of an ISO Final Standard – likely in 2016. 

Once published, this ISO standard will replace other country-specific OHSMS standards such as ANSI Z10.  It will also replace OHSAS 18001.

The standard will be a specification standard intended to be used for third-party certification.  This means it will have auditable “shall” clauses.  The development of the standard will be governed by the requirements set out in the ISO directives, including the requirements for management system standards set out in Annex SL.   This means it will have the same top-level structure, use the same terminology and have many of the same core requirements as the other ISO management system standards.

Each ISO member body will have an opportunity to participate and to designate individual experts to represent it in this international standard development process.  These experts will be the ones who draft the language for the OHSMS standard.   Consensus among the experts will be reached in a series of international meetings where the content of the standard is discussed and agreed upon.   Opportunity will also be provided for others to review one or more committee drafts (i.e. CDs) of the standard and to provide comments to the designated experts for their consideration. 

In the United States, the American Society of Safety Engineers (ASSE) has applied to ANSI to become the TAG Administrator.  The activities of this committee will be governed by the ANSI rules for U.S. Technical Advisory Groups.  The members of this TAG will determine the U.S. position for the international standard development meetings held by PC 283 and designate the members of the TAG who will be the U.S. Experts.

Although the ISO OHSMS standard will be developed as a voluntary consensus standard, it is very likely that it will be incorporated into or referenced in other documents.  This may include supply-chain contracts, sustainability frameworks and governmental regulations.  It is this use of the standard that may make conformance with the ISO OHSMS standard mandatory.

What to know more?

For more information about the likely impacts of an ISO OHSMS standard, click on the link below to download your copy of the ENLAR Executive Briefing Paper  -
Impacts of an ISO OH&S Management System Standard.

Have a question about the development of this standard?

Ask it in the comment box below or send me an e-mail at TDunmire@enlar.com.

June 25, 2013 | 0 Comments More

ISO OHSMS Standard Going Forward

The New Work Item Proposal (NWIP) for development of an ISO Occupational Health and Safety Management System standard has been approved.  A new ISO Project Committee, PC 283, has been established to develop the standard.  BSI has been appointed as secretariat.

The intent is that this new ISO standard will replace OHSAS 18001:2007.

As I outlined in a prior blog post, there are several issues associated with this standard development activity.  The most important of these is that the development of ISO standards must conform with the ISO directives, including the requirements for management system standards set out in Annex SL.

© ENLAR Compliance Services, Inc. (2013)
June 19, 2013 | 0 Comments More

“Risky” Risk Matrices

I don’t like risk matrices. 

I have written blog posts, given speeches, and written comments on several draft consensus standards pointing out the flaws in using risk matrices in EHS decision-making.  I continue to be frustrated by the insistence some registration auditors place on having them – even though there is no requirement in either ISO 14001 or OHSAS 18001 mandating their use.

Just last month, a registration auditor expressed his disapproval of a client’s aspect evaluation procedure because, as he put it,

“Where are the ranking numbers?”

So I was quite pleased when I stumbled upon the following YouTube video that set out in an explicit and graphic way why the majority of risk matrices are flawed.

 

 There are three common problems associated with using a risk matrix –

1.  As set out in this video, most numeric-based risk ranking tables are not based on a valid statistical approach and result in a biased analysis of the potential risks associated with the items being analyzed.  Many times, the results do not even pass a “common sense” test when they are reviewed after the number-crunching is complete (i.e. “Does this result make sense based on what we know about our operation?”).

2.  There is the temptation to use a risk matrix simply because there is insufficient information to do “a real analysis.”  Rather that developing real data, numbers are simply assigned to educated guesses.  The inevitable result is GIGO (Garbage In = Garbage Out).

3.  Risk ranking tables are used to compare items that can’t be directly compared.

So, can a risk matrix ever be used?

Sometimes, if certain conditions are met.

Want to find out more, click here to read what they are in the latest EHS Management System Update Newsletter – Apples or  Oranges – Which is Better?

Want to subscribe to this newsletter – use the sign-up box below.

© ENLAR Compliance Services, Inc. (2013)
June 5, 2013 | 0 Comments More

Implementing an OHSMS – 7 Steps to Take First

steps1Are you thinking about implementing an occupational health and safety management system?

There are 7 Steps you should take FIRST. 

Want to know what they are?

Sign-up below for my mini-course (delivered to you in 7 e-mail installments) – The 7 Steps to Take Before You Implement an OHSMS.

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May 23, 2013 | 0 Comments More

“Just an Industrial Accident”

There have been two deadly workplace accidents in two weeks. 

  • A horrific explosion in West Texas that killed 14 and destroyed at least 40 homes. 
  • A building collapse in Bangladesh that killed at least 275 and injured hundreds more.

In both cases, a workplace incident quickly became a community tragedy.

  • In West Texas – What may have been a small fire triggered a massive explosion – an explosion several times greater than the explosion in the Oklahoma City bombing.
  • In Bangladesh – An unsafe building has become a mass grave where family members are digging through the rubble searching for loved ones.

Unfortunately, worker safety is often viewed by the press as unimportant when compared to events that are labeled as terrorist attacks.  This was clearly evident last week.  One report, when comparing the West Texas Explosion to the Boston Marathon Bombing, characterized the explosion in West Texas as “just an industrial accident.”  No readily available villain so, therefore, the event is less important. 

deathYet, statistics show that workplace incidents are often much more deadly.  In addition, the effects don’t stop at the facility boundary.  Industrial accidents also impact families and our communities.

Workplace deaths are even more worthy of our attention because they are often preventable – if there is the public will to insist that they become so.

We will not be able to stop every terrorist attack without both a massive outlay of resources and even greater intrusions into areas that were previously considered private and “off limits” in a free society.  Yet, the causes of most significant workplace incidents can be identified and addressed.  What is often missing is a societal insistence that those who can prevent workplace accidents be required to do so rather than profiting from ignoring unsafe workplace conditions.

Both a change in perspective and improved enforcement of workplace standards are needed.

Society needs to stop viewing workplace accidents as simply an acceptable risk that workers are expected to take in order to get paid for their labors.  As John Howard put it – “Earning a day’s pay should not place anyone at risk of losing life or livelihood.”

In addition, international consensus standards are needed that establish clear, transparent and enforceable requirements that organizations must meet if they want to claim recognition for providing “safe workplaces.” 

ISO is proposing such a standard be developed in its New Work Item Proposal for an Occupational Health and Safety Management System standard (click here to read more about it).  Of course more will be needed to ensure worker safety but at least the development of an ISO standard can be an initial first step – if this initiative is approved.

 © ENLAR Compliance Services, Inc. (2013)
April 26, 2013 | 0 Comments More

Validity of Certification

I recently got the following question about a blog post I did back in 2009 – OHSAS 18001 “Governing Body”.

The question was -

My company is an Environmental Laboratory in India.  It holds an unaccredited certificate issued by an Indian company.  Can you clarify how far this certificate is valid.

My response -

I can’t answer your question since the answer is specific to your organization, the clients you conduct work for and the laws of your jurisdiction.  For example, in the United States, there are laws that require testing laboratories to be accredited – including those doing certain environmental tests.

As I mentioned in the blog post you referenced, management system standards are used for a variety of different purposes.

One of those purposes is to set out the requirements upon which certification programs are based.  Some of these certifications are reputable and legitimate, whether they are accredited or not.  Others are only sham certifications.  They are issued primarily to deceive or encourage reliance on the part of third parties that is not justified based on the level of investigation actually being performed by the individual or organization providing the certification.

The issue is not so much accreditation or not.  The issue is the credibility of the certification based on the level of due diligence that supports the determination being made.

I posted this question and response because of the increased interest and reliance on OHSMS certification that is being driven by an increase in public sustainability reporting.  It is important to understand that certification alone does not represent due diligence unless it is clear exactly what assessment activities were done to support the certification.

© ENLAR Compliance Services, Inc. (2013)
March 20, 2013 | 0 Comments More

Proposal for an ISO OHSMS Standard

Yesterday, I received a copy of the ISO New Work Item Proposal (NWIP) for a new requirements standard for occupational health and safety management systems.  ANSI has requested that comments on this NWIP be sent to ANSI by April 26, 2013, so ANSI can decide how it will vote on this proposal. 

There are several interesting aspects to this NWIP –

1.  This is a proposal for a Project Committee (PC), not a Technical Committee (TC). 

The distinction is that a Project Committee is authorized to develop a single standard.  This is the approach that was used for the development of ISO 50001:2011 – the ISO Energy Management System standard.  An ISO PC can be converted into a TC in the future but, at least initially, the standard development authority of this ISO committee will be limited solely to the development of the one standard being proposed – an OHSMS requirements document.

2.  Given the past controversy that has surrounded the development of an ISO OHSMS standard, this NWIP includes two additional letters. 

The first is a letter from the Rob Steele, the ISO Secretary General, addressing the right and ability of ISO to deal with the subject area.  The second is a letter from the International Labour Organization (ILO) expressing its concerns with ISO’s decision to proceed with this standard development effort.

3.  Any ISO OHSMS standard will be required to meet the requirements for management system standards that are set out in Annex SL of the ISO Directives. 

What this means is that an ISO OHSMS will not be based on any of the existing OHSMS standards – including OHSAS 18001 or ANSI Z10.  These standards can serve as reference documents but many of the important requirements of an ISO OHSMS will be determined solely by the high-level structure and core common text that are set out in Annex SL. 

ANSI is in the process of circulating this proposal to stakeholder groups in the United States.  I am confident there will be a great deal of discussion of this NWIP.  It is likely that there will be continued disagreement concerning the appropriate venue for developing OH&S standards. 

As set out in BSI’s justication document, the world is markedly different today from what it was when an ISO OHSMS standard was last proposed. 

Today, protection of workers is as much driven by a complex web of supply chain relationships and sustainability initiatives as it is by governmental decrees and enforcement actions.  As show by the success of the certification initiatives that have developed around the handling of electronics waste, publicity and supply chain initiatives can have a greater impact in protecting worker health than governmental rulemaking. 

In addition, given the increased use of outsourcing arrangements, many individuals performing work on an organization’s behalf are no longer employees in the traditional labor law sense.  By extension, worker safety is no longer solely an employment issue.  As explicitly set out in OHSAS 18001, and recognized in several OSHA standards, an organization’s obligation to protect workers extends beyond employees to individuals who are performing work on an organization’s behalf.  This can include a range of parties – including contract workers, employees of contractors, volunteers, visitors to the workplace and employees. 

Worker safety is no longer simply a labor issue to be addressed through governmental action.

Want to know more?

If you want to know more about Annex SL and the revision of ISO 14001, check out my previous blog post – New Year – New Standards.

If you want to review the ISO NWIP for an OHSMS standard click here (note – this document does not include the Justification Study and other attachments to the NWIP but does include copies of the letters discussed above).

© ENLAR Compliance Services, Inc. (2013)
March 13, 2013 | 0 Comments More