Category: Emergency Preparedness

Accidents, Incidents and OH&S Management Systems

Inadequate emergency planning has claimed more victims at the World Trade Center site in New York City.

According to reports in The New York Times and Forbes, two firefighters were killed in a fire and two were injured in a separate construction accident last week at the Deutsche Bank building near Ground Zero.  This building has been empty, and undergoing demolition, since it was damaged during the 9/11 terrorist attack six years ago.

These incidents highlight the importance of having a functioning OH&S management system – even for construction and demolition projects.

What were the obvious management system failures?

  • Lack of appropriate risk assessment / inspection processes.  Apparently, the fire department was not inspecting the building because of concerns about exposure to toxic materials.
  • Lack of emergency preparedness procedures.  No plans were in place for fighting a fire in the building.
  • Failure to take effective corrective and preventive actions.  This demolition project had apparently been plagued by accidents and the primary contractor has been cited for dozens of safety violations.

According to The New York Times article, Scott Stinger, the Manhattan Borough president, summed up the situation as follows:

“[W]e sent 100 firefighters in with little water, not enough oxygen and no plan….They have got to shut this down pending a safety review.  I don’t understand why that is so difficult.”

It’s too bad a “safety review” wasn’t done before more people died.  Even better – make sure an effective OH&S management system is put in place.

© ENLAR® Compliance Services, Inc. (2007)

August 28, 2007 | 1 Comment More

What is “Management of Change?”

Although it is often used as a term of art in the safety field, “management of change” is not a defined term in OHSAS 18001:2007.  It is, however; vital to an effective OH&S management system. 

Explicit requirements for management of change were added into section 4.3.1 of OHSAS 18001 in the 2007 revision of the standard.  This addition was an explicit request of the American Industrial Hygiene Association for purposes of aligning OHSAS 18001 with the U.S. Occupational Health and Safety Management System standard — ANSI/AIHA Z10-2005.  In addition, management of change is also an explicit requirement for safety management systems implemented to comply with the Seveso II Directive (see Annex III of EU Council Directive 96/82/EC).

 The following requirements related to management of change were added in section 4.3.1:

 The procedures for hazard identification and risk assessment shall take into account:

g) changes or proposed changes in the organization, its activities or materials; h) modifications to the OH&S management system, including temporary changes, and their impacts on operations, processes and activities;…. For the management of change, the organization shall identify the OH&S hazards and risks associated with changes in the organization, the OH&S management system or its activities, prior to the introduction of such changes. 

In addition, reference to Management of Change was also included in section 4.4.6: 
The organization shall determine those operations and activities that are associated with the identified hazard(s) where the implementation of controls is necessary to manage the OH&S risk(s). This shall include the management of change (see 4.3.1).

These new requirements cover four important concepts:

  • Identification of the hazards associated with “change”
  • Assessment of the risks associated with “change”
  • Consideration of OH&S hazards and risks prior to the introduction of the “change”
  • Implementation of the controls needed to address the hazards and risks associated with the “change”

For purposes of management of change within an OH&S management system, the changes that need to be addressed include:

  • Organizational changes (e.g. personnel or staffing changes)
  • Activity changes (e.g. changes to processes, equipment, infrastructure, software)
  • Material changes (e.g. new chemicals, packaging)
  • Changes to the OH&S management system (e.g. procedures)

Why is management of change so important?

Ineffective management of change is one of the leading causes of serious incidents.  To quote the U.S. Chemical Safety and Hazard Investigation Board (CSB), “In industry, as elsewhere, change often brings progress.  But it can also increase risks that, if not properly managed, create conditions that may lead to injuries, property damage or even death.” (from CSB press release announcing its 8/28/2001 Safety Bulletin concerning “Management of Change”)  Ineffective management of change is one of the major contributing factors in many of the incident investigations conducted by the CSB.  To check it out, go to the CSB web site at  and enter “management of change” as your search term at the link “Search this Site.”

© ENLAR® Compliance Services, Inc. (2007)

July 18, 2007 More