Category: OHSMS Documentation
Many of the recent high-profile instances of organizational failures – such as the BP Deepwater Horizon explosion, Penn State Sandusky scandal and the Barclays Bank Libor manipulation – have resulted in independent investigations. The point of these investigations is to identify what went wrong in order to prevent similar failures in the future. Often these investigations result in reports with recommendations for management system changes.
Recently, one commentator characterized one of these reports as follows:
These recommendations are simply the imposition of unnecessary bureaucracy on the hapless many in the organization because of the misconduct of a very few. In the end, the changes recommended will not work anyway. What this failure shows is a lack of leadership that management systems can’t solve.
Implicit in this comment are the following assumptions –
- Management systems are simply bureaucratic burdens that get in the way of doing “real work.”
- Management systems don’t work; what is important is leadership.
Taking each of these assumptions in turn –
I have to admit it – I like paper.
This can be a scary admission since today everything digital is considered better. At times, there seems to be almost a mass hysteria that our paper pads must be replaced by iPads.
There are, of course, advantages to electronic data management. At the very least, there is the physical space you save when you eliminate the storage of paper records. Then, there is the immediate availability of even very arcane information with a simple web search.
But there are downsides to electronic data management as well. These downsides include catastrophic data loss when your computer crashes and the limitations associated with difficult-to-read screens, lack of reliable power supplies and web access failure.
Today, what is needed is a life cycle assessment approach to information management – with both paper and electronic devices playing their part.
In my view, paper is still the hands-down best choice for many of the data collection activities associated with occupational health and safety management system processes in industrial environments.
Reason #1 – Paper doesn’t require training or specialized knowledge to use.
We all know how to write.
The same is not true for using electronic devices. Although manufacturers have attempted to make their products more intuitive, there is still a learning curve associated with every different device.
Filling in paper forms is something most of us have been doing all of our lives.
Reason #2 – Paper is more robust and unlikely to blow the place up.
Most electronic devices are fragile and, unless specially designed, capable of initiating a fire or explosion. Dropping an electronic device into a puddle or pond likely means it is destroyed.
Particularly for field use, paper works.
One of the best products for wet environments (such as Florida where I live) is Rite in the Rain all-weather writing paper. As long as you use a pencil or waterproof pen, your form or log book will not be destroyed even if you drop it in standing water. Neat!
Reason #3 – Paper can be “smart.”
Paper can have “metadata” associated with it. It can have digital watermarking, bar codes and RFID tags. It can “talk to” electronic devices such as bar code readers and cell phones. The most ubiquitous example of smart paper is the identification badges that can open doors and keep track of your location.
Paper forms can be intelligently designed so that when they are scanned, information is uploaded directly into a database. You can have the benefit of paper for data collection and the benefit of computerization for data management.
Paper is increasing a transient medium used to display and transport information that is developed and maintained electronically.
Reason #4 – Paper can be secure.
When information is collected and maintained on a piece of paper there is only one copy and it can be physically secured. A piece of paper cannot be hacked and sent offshore to information pirates.
Reason #5 – Paper helps you think.
There is a reason for whiteboards and flipcharts in conference rooms. Putting ideas “down on paper” helps us collaborate, form ideas and identify connections.
So before you exchange your paper pad for an electronic tablet, think about what you want to accomplish. Consider whether paper may still be the better choice for at least some part of the data management process – at least where you need a human interface.
© ENLAR Compliance Services, Inc. (2012)
It is common for the clauses of the management system standards – including OHSAS 18001 – to be known by “shorthand” names.
Clause 4.4.5 of OHSAS 18001 is known as “document control”; clause 4.5.2 is known as “CAPA” (corrective action and preventive action).
Similarly, clause 4.4.1 is often referred to as roles & responsibilities or “R2A2” – roles, responsibilities, authorities, and accountabilities.
OHSAS 18001 requires that the organization [a.k.a. “top management”] “ensure the availability of resources essential to establish, implement, maintain and improve the OH&S management system.” These resources include human resources and specialized skills, organizational infrastructure, technology and financial resources.
Although there is a great deal of focus these days on reducing cost, the truth is management systems cost money. An organization can strive to achieve the best value for the money spent; however, spending money is not optional.
One of the mistakes I often see organizations make is attempting to implement an OHSMS “on the cheap” – often by piling additional work onto already overworked staff and by attempting to “repurpose” existing infrastructure, such as data management software. Although I am all about being cost effective, there is more to an OHSMS then creating documentation using a global search on someone else’s procedures to replace your organization’s name for theirs. Similarly, the human resources needs of an occupational health and safety management system include individuals with a certain level of competence, specialized skills, and AVAILABLE TIME. Attempting to save money by using jerry-rigged databases often causes user frustration and results in incomplete and/or meaningless data being collected for analysis.
Nor is an OHSMS a one time purchase. The resource needs of an OHSMS continue and change over time.
As OHSAS 18002 points out (in section 4.4.1) – “Resources and their allocation should be reviewed periodically, via management review, to ensure they are sufficient to carry out OH&S programmes and activities ….the adequacy of resources can be at least partially evaluated by comparing the planned achievement of OH&S objectives with actual results.”
Have you evaluated your OHSMS resource needs?
© ENLAR Compliance Services, Inc. (2012)
Every year we do a Christmas dinner party – a three-course English Feast with Roast Beef and Yorkshire Pudding and a dessert we call “The Amy” (Butter Tarts with Stilton Cheese). The menu is set and draws its inspiration from my husband’s heritage (England and Canada) and my Midwest upbringing (Iowa). We have been doing the same meal for the last 15 years.
Once I started developing and implementing management systems, I could not resist applying management system theory to this event. I developed a Christmas Party Checklist. This checklist sets out the various tasks that need to be done and has blanks for assigning responsibilities and checking off each task when it is done.
Why do I use a checklist?
One year, I found the strawberries for the appetizer course still in the refrigerator when I put the leftovers away. Another year, I had to scramble to find the meat platter while the guests watched from the table.
This checklist helps the party go smoothly and, more importantly, it helps me relax and actually enjoy the party because I know I am not going to forget anything important.
The morning after the party I make notes and additions to the checklist and file it away for the following year.
So what does this have to do with OHSAS 18001?
Checklists are an important part of a management system. As with our Christmas party, they prevent you from missing important tasks. They also help make your job more manageable and enjoyable – that is, if they are done right.
Want to learn more about creating effective checklists?
Click here to check out my previous blog and sign up for my mini-course (starting January 16, 2012) focused on checklist creation.
p.s. It was a great webinar Tuesday on ISO 19011:2011 – The Impact on Management System Auditing. Thank you to those of you who participated and submitted questions for the Q&A. Come back here next week for a link you can use to view this presentation.
© ENLAR Compliance Services, Inc. (2011)
In my last blog, I discussed the importance of checklists in saving lives.
Checklists are everywhere.
They are an integral part of many personal activities – from completing your tax return to communicating symptoms to your doctor. Checklists also play an important role in managing many business processes.
Checklists will be an important part of your OHSMS documentation.
In order to be effective, checklists need to be intelligently designed and routinely used. They also need to be controlled.
So how do you go about creating a great checklist?
Checklists are essential to successful business operations. Checklists are an integral part of an occupational health and safety management system. More importantly, checklists save lives.
This result is most obvious in medicine where the use of surgical checklists has saved thousands of lives and untold suffering. The importance of checklists in medicine was highlighted in a 2007 article in the New Yorker Magazine, The Checklist. The most dramatic of these incentives is the international adoption of a one-page Surgical Safety Checklist developed, promoted and disseminated by the World Health Organization.
There are numerous uses of checklists in OH&S management systems. In fact, checklists are one of the most effective way of creating management system procedures and work instructions to meet the OHSAS 18001 requirements.
Some of the OH&S uses of checklists include –
- Inspection checklists – for forklift trucks, fire extinguishers and other safety-critical devices, equipment and supplies.
- Plans and permits – for confined space entry, hot work and equipment lockout where the sequence of tasks and adequacy of precautions are critical.
- Emergency preparedness – for making sure equipment, materials and personnel will be ready and available when an incident occurs.
- Risk assessments – for evaluating the hazards and risks associated with materials, equipment and tasks.
- Internal audit protocols – for making sure that OHSMS audits are complete, inclusive and cost-effective.
As regulations, activities and organizations become more complex, checklists become increasingly important for ensuring that nothing is missed. This is why pilot checklists were developed in aviation in the 1930s. This is why surgical checklists are being aggressively promoted in medicine today. This is why most OH&S management systems would benefit from the use of appropriately-designed checklists.
In my next blog, I will cover the 5 steps you should follow in order to develop good OHSMS checklists.
In the meantime, click here to request a copy of my EHSMS Implementation Checklist.
© ENLAR® Compliance Services, Inc. (2011)
In a previous blog, I discussed the new High Level Structure and identical text requirements that has been proposed for all ISO management system standards. One of the proposed changes is to eliminate the document control and record control elements and replace them with a new provision requiring control of “documented information”. Documented information is somewhat vaguely defined in this new scheme as “the information required to be controlled and maintained by an organization”.
Although this may be seen as progressive by those who developed this new management system structure, it is likely to create confusion on the part of users of the standards who are not information management experts.
There are important reasons for distinguishing between the documents that need to be controlled in a management system and record retention requirements. Even though both document control and record control are control of documented information, their purpose and use is very different.
One of the difficult questions that OH&S managers face is – “Do we need a written procedure for [some process]?” The dilemma is that although written procedures are a necessary part of an occupational safety and health management system – if you create too many formal procedures your OHSMS becomes complex, cumbersome and unwieldy.
I just got done reading an article in the October 2009 Quality Progress Magazine that sets out a nifty tool for making this decision – a 2 x 2 matrix for deciding whether or not to standardize a process. Although the example given in this article – Building a Consensus – is for a quality system process, it can be easily adapted to making standardization decisions in an OH&S management system.
Try it out for your OH&S management system and let me know – “Did it work?” – by posting your comments below.
© ENLAR® Compliance Services, Inc. (2009)
One of the signfiicant tasks associated with implementing any management system is managing information – typically lots of information. Usually, way too much information. As I discussed in a previous post – Data Sprawl – Not Just an IT Problem, the fact that we are now managing “virtual information” leads us to believe that the more information we have the better.
As this video points out, at some point more information simply makes us stupid.
This is an important point to remember as you are establishing, implementing and maintaining your OH&S management system. As you are developing your procedures, programs, forms, inspection sheets, training programs, meeting minutes, e-mail updates…… remember that the human brain only has so much capacity.
Use it wisely.
© ENLAR® Compliance Services, Inc. (2009)
A reader recently asked –
Why is that OH&S management system manuals so often repeat the language of the OHSAS 18001 standard – isn’t that redundant?
Yes and No.