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)

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. 

Although they are not explicitly listed within the OHSAS 18001 standard, these include –

• Leadership Involvement – The top management of the organization must be actively engaged in the management system;
• Risk Management – Implementation of an OH&S management system is driven by the risk management needs of the organization – the hazards and risks identified and the controls that are determined to be necessary to prevent injuries and ill health;
• Commitment to Compliance – Societal interests, as reflected in the laws and regulations promulgated, must be addressed;
• Worker Participation – Workers, as the primary stakeholders of an occupational health and safety management system, have the right to be involved in management system processes; and
• Performance Monitoring & Improvement – Continual improvement, a management system mantra, cannot be achieved unless processes are in place to measure performance. 

© ENLAR® Compliance Services, Inc. (2011)

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. 

Wow!

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 –

• Although details about the inspection criteria and protocols used for the Office of Compliance inspections was not provided, the inspections seemed to be heavily focused on the OSHA electrical and fire regulations.  As a result, the primary types of hazards identified appeared to be electrical and fire hazards.
• Clearly missing from the report was any discussion of ergonomic hazards associated with office work.  It is difficult to accept that simply because there is no OSHA ergonomics standard, no ergonomics hazards exist in these offices.  The irony being that the reason there is no OSHA ergonomics standard is that Congress blocked OSHA from developing one.
• The inspections conducted did NOT include assessment of written safety and health programs – even though this report acknowledges that “agencies can reduce considerably the incident and severity of on-the-job injuries by implementing effective safety programs.” 

This is a significant omission given that the most frequently issued OSHA citations are associated with the lack of safety programs such as hazard communication programs. 

The reason given for this omission? 

The employing offices (i.e. Congressional members) were concerned about the time required to develop safety programs, their lack of readiness for inspection as well as “legal issues.” (see page 19 of the report).

Given the results reported and, more importantly, the omissions from the inspections actually conducted, it makes one wonder about the wisdom of giving awards to members of Congress for “office safety”.  The results to date do not appear to demonstrate a commitment to safety that should be commended.

© ENLAR® Compliance Services, Inc. (2010)

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.

Get real. 

First, the assumption of “unused capacity” is probably an illusion.  When I talk with in-house EHS Staff, many of them admit that they are stressed out and burned up.  There is no more time available and they are sick and tired of being asked to “do more with less”.  It never fails to amaze me that business managers will readily accept that every piece of equipment has some kind of capacity limitation (e.g. piece rate, load rate, utilization rate) yet expect that the capacity of individuals to complete work is infinite.  As the recent aviation incidents show, people have limits too.

Second, as business books such as The Goal clearly point out – local optimization is a poor business strategy. Unless there is some real business value (ROI) associated with the expenditure of the funds needed to achieve the improved local result, the resources used for local optimization are wasted. 

To order a copy of The Goal from Amazon, click here The Goal: A Process of Ongoing Improvement

“Improvement” just for the sake of being able to claim improvement is a waste of valuable time and resources.  So before you set any improvement metrics for your OH&S management system for 2010, ask yourself – “Why Improve?”  It could be the programs you have in place are already good enough. 

© ENLAR® Compliance Services, Inc. (2009)

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.

One of the important tasks associated with implementing an OH&S management system is making sure there are thought out, agreed upon, documented and acceptable answers to all the “now what” questions.  In determining the “acceptability” of the answers agreed upon, it is important to consider of the views and needs of multiple stakeholders –

• The views and needs of the individual(s) who are required to answer the calls in the middle of the night (as well as the other members of their households whose sleep is disrupted).
• The views and needs of the individual(s) who are required to physically respond to alarms – including the need for specialized training and PPE.
• The views and needs of those who will have to deal with the public relations issues if an alarm triggers a “911” call for emergency services.
• The views and requirements of insurers if alarms are ignored because of frequent false alarms.
• The views and needs of individuals who are relying on alarms to protect their safety or property.
• The views and needs of the individuals who have the responsibility of keeping the alarms working right.

Putting in alarms is fine…just make sure there are plans in place for when they go off.

© ENLAR® Compliance Services, Inc. (2009)

 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)