OHSAS 18001 EXPERT » OHSMS Documentation

Should I Write a Procedure?

Thea — Fri, 06 Nov 2009 22:14:55 +0000

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)

Information Overload

Thea — Tue, 27 Oct 2009 20:43:59 +0000

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.

Not true.

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)

Creating OHSMS Documentation

Thea — Wed, 30 Sep 2009 15:16:49 +0000

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.

During management system implementation, the constant repetition of the OHSAS 18001 language feels redundant. You are referring to OHSAS 18001 constantly – in drafting procedures, discussing processes, creating forms and developing training programs. You probably feel – “enough already with the arcane standards speak.” Since you are so close to the initial drafting of the manual and other procedures, it is clear in your mind what the OHSAS 18001 requirements are and how you are planning to meet them.

As with most things, memories and associations fade with time.

One of my favorite Christmas stories is that each year when we got together with my mother and my husband’s parents for Christmas, my Mother would start a question with “What year was it when we ….” A lively discussion would ensue as we tried to remember exactly what year it was that we did some particular activity – “Was it 1997 or was it 2000?” My mother has since passed away but we still discuss “What year was it when we …” at Christmas – and I am reminded of her presence.

A similar thing happens with your management system manuals and procedures. Over time, people will forget both WHAT they need to do and WHY if you don’t actually include the requirements in your Manual. The “shall clauses” in the OHSAS 18001 standard are unlikely to be remembered and may not actually be met if you don’t explicitly include them in your own OHSMS documentation.

One of the tests of the completeness of a management system manual is whether you can file the standard away (never refer to it again), and still have a management system that continues to be in conformance with the requirements of OHSAS 18001.

In fact, the hallmark of a good internal audit program is that audits are performed against the organization’s own OHSMS documentation – its manual and procedures – NOT against the OHSAS 18001 standard. Conformance with the OHSMS manual IS conformance with OHSAS 18001.