Category: OHS Metrics & Measurements
One of the ongoing discussions about OH&S management systems revolves around what it is exactly that the organization should be accomplishing. In “standards speak” this is referred to as the “intended outcomes” of the OH&S management system.
In my conversations with professionals in the field, there seems to be a consensus that the overall goal – “intended outcome” – of an OH&S management system is either protecting the health of workers or worker safety. How this goal is phrased, in terms of health or safety, seems to depend primarily on whether one views oneself as an “occupational health professional” (i.e. industrial hygienist) or a “safety professional”.
Interestingly, the goal of an OH&S management system is often articulated in the negative, rather than the positive, as “prevention of worker injury and illness.”
Why is this important?
It is important because how the goal is phrased often drives what outcomes are measured and tracked by the organization.
If the goal is prevention of worker injury and illness, then the outcome metrics selected focus almost exclusively on injury and illness rates.
For more about the use of management system metrics, check out my article in the November 2014 issue of the Synergist – Selecting Management System Metrics.
Many companies are increasing including some type of “injury and illness data” in their sustainability reports. It is one of the metrics included in the GRI reporting scheme. It is used both internally and externally to determine financial bonuses. It is also used by a number of companies and governmental agencies to select qualified contractors. There is a great deal of pressure to report low numbers.
The question is – “How accurate is this data?”
There are many who believe it isn’t very accurate at all.
As I discussed in a previous blog, there are strong incentives for under-reporting and, very often, little or no independent verification of the numbers. This is even the case for many of the processes and web-based tools used by major companies to select contractors.
Safety professionals may want to re-assess the risks associated with the creation and external reporting of injury and illness data.
Companies may want to re-assess their reliance on data that has no independent verification.
Because, given the results of a recent court case, inaccurate reporting can be considered fraud and those involved can go to jail.
In early November 2012, a jury convicted a safety manager for The Shaw Group of eight counts of major fraud against the United States. They found that he had provided false and misleading information about injuries associated with work at TVA (Tennessee Valley Authority) facilities. This false injury data was used by his company to collect safety bonuses worth over $2.5 million. (Note – According to the DOJ press release, The Shaw Group entered into a civil agreement in 2008 with the United States and paid back twice the amount of the safety bonus they collected.)
What to know more about verifying injury and illness data?
© ENLAR Compliance Services, Inc. (2012)
This week, in addition to attending the AIHCE in Portland, I will be participating in a meeting of the ANSI Z10 Committee. We will be discussing the revision of Z10 that was undertaken last year and is scheduled to be completed later this year (Fall 2011).
ANSI Z10:2005 is the American National Standard for Occupational Health and Safety Management Systems. As such, it is part of a large family of standards addressing this topic. The dominate sibling in this family is, of course, OHSAS 18001:2007. According to the 2009 Standards and Certificates Survey conducted by the OSHAS Project Group, over 50,000 organizations have obtained certification to OHSAS 18001.
The goal of this revision of Z10 is to continue to provide guidance helpful to organizations in the United States that want to implement an OH&S management system. Another use of Z10 is as a reference document for OSHA’s initiative for development of a standard requiring that employers establish an Injury and Illness Prevention Program (I2P2 Initiative). Finally, there is a desire to ensure that Z10 continues to have relevance to OH&S in the future.
One of the interesting inputs impacting this revision of Z10 is the increasing focus on sustainability initiatives and corporate sustainability reporting. Many OH&S professionals have expressed concern about the lack of attention given to worker safety within the sustainability movement. One of the initiatives ASSE and AIHA are working on together is the development of appropriate metrics for measuring OH&S performance for the next revision of the GRI sustainability reporting guidelines.
© ENLAR® Compliance Services, Inc. (2011)
Standards are based on principles.
ISO 9001 is based on quality principles. ISO 19011 is based on auditing principles. Last week, I participated in a conference call for ISO 14046 in which we discussed what principles are important to the development of a water footprint. For this discussion we started with the sustainability principles set out in a publication entitled, Guide to Corporate Ecosystem Valuation, which was recently developed by the World Business Council for Sustainable Development.
Just as principles are important for many of the ISO standards, OHSAS 18001 is also based on several principles.
A blog on the website The Hill caught my eye this morning. It is entitled “More than 70 percent of Congressional offices violate OSHA worker safety standards.” This is an alarming finding.
What was even more disturbing is that the blog went on to say that this result – 70% of office areas in violation of OSHA standards – was seen as an improvement because the number of violations found during previous inspections was even higher.
Having piqued my interest, I headed over to the website for the Office of Compliance to take a look at the report myself.
What I found was the Biennial Report on Occupational Safety and Health Inspections dated June 2009.
There are some interesting things in this report –
There seems to be a “disconnect” between current economic realities and the metrics often suggested for evaluating OH&S programs and management systems.
Many organizations are facing a level of financial hardship not seen since the Great Depression. As a result, cutbacks, downsizing and belt-tightening are the new normal. “Do more with less” has become the mantra of business. This translates – for many EHS professionals – into being asked to get by with fewer people and no new resources.
On the other hand, many organizations seem unwilling to match their OH&S goals and expectations to the reality of fewer resources. Managers still insist on setting “continual improvement” metrics based on achieving “best-in-class” management system performance. This is often expressed in the form of a performance rating scheme based on some sort of numeric scoring of the “performance” achieved by particular S&H programs or management system elements (typically on a 1 to 4 or 1 to 5 scale). Examples of this abound. There is one set out in an article I just finished on SH&E Strategic Planning in the October 2009 Professional Safety Magazine.
Implicit in many of these of rating schemes is the assumption that there is “unused capacity” that can be utilized to achieve the performance improvement desired.
There seems to be a renewed interest in metrics, measuring and monitoring within OH&S management systems. Given the advances in continuous monitoring technology, this interest often translates into the installation of a host of different monitoring devices with alarms – fire detection alarms, security alarms, gas detection alarms, motion sensor alarms, electrical current alarms, high level alarms, low level alarms, entry alarms, exit alarms, etc.
One of the challenges associated with all of these alarms – “What are you supposed to do when the alarm goes off?”
Since my husband is at the top of the call list when an alarm goes off at his facility, I am only too familiar with this question – particularly since the “alarm alert” often occurs in the wee hours of the morning (as it did this morning). I can tell you attempting to answer the “now what?” question at 4 am is no fun.
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 an OH&S program.
© ENLAR® Compliance Services, Inc. (2009)