Category: OHSMS Implementation
Ban the Blame
One of the key requirements of the OHSAS 18001 standard is establishing a procedure for taking corrective and preventive action (section 4.5.3.2). Both corrective and preventive action need to include identifying the underlying causes – often called root causes – of whatever it is that is or went wrong.
This is not easy. Often, the root cause investigation ends with a determination along the lines of “Joe screwed up.” We play the blame game.
Why?
“Timely” Incident Investigation
Section 4.5.3.1 of OHSAS 18001 requires that OH&S incident investigations “be performed in a timely manner”.
So – What is Timely?
Neither OHSAS 18002 nor the dictionary (my primary sources for interpreting the OHSAS 18001 requirements) provides much help.
OHSAS 18002 does not explicitly discuss this particular requirement of the OHSAS 18001 standard.
The dictionary isn’t particularly helpful either. It defines timely as – “well-timed, in time, occurring at a suitable time, opportunely“. The legal dictionary definition is “falling within a prescribed or reasonable time.”
Information Overload
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
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.
Challenges & Opportunities in Developing OHSMS Standards
This week I had the opportunity to attend and give a presentation at the NIOSH NORA Health Care and Social Assistance Sector Council Meeting in Washington DC. It was the first NIOSH NORA meeting I have attended and I found the discussion both very enlightening and somewhat scary.
At this meeting I gave a presentation – Challenges & Opportunities in Developing OHSMS Standards – that outlined five common barriers to implementing Occupational Health and Safety Management Systems. Also giving presentations on this topic were Mike Seymour from OSHA and Barbara Braun from The Joint Commission. Mike Seymour discussed the OHSMS guidance document that OSHA is currently in the process of developing and Barbara Braun discussed how the Joint Commission standards also include worker safety requirements. As several of the attendees pointed out, there is a clear and obvious link between patient safety and worker safety.
The purpose of these presentations was to assist the HCSA Sector Council in developing implementation plans for the new National Occupational Research Agenda for this sector (currently out for public comment until the end of October 2009). A key strategic goal in this agenda is promoting the use of OH&S management systems and improving safety culture in healthcare organizations.
The scary part of the meeting…
The critical issues that need to be addressed to protect health care workers – particularly as it relates to the H1N1 pandemic. There was a great deal of discussion concerning the precautions that need to be taken related to providing proper respiratory protection - NOT JUST SURGICAL MASKS – and the current lack of hospital preparedness. The importance of this topic was emphasized by the advisory issued by the Institute of Medicine yesterday that urges health care workers to use N95 respirators instead of surgical masks for protection.
© ENLAR® Compliance Services, Inc. (2009)
The Role of Trust
In last week’s post, I discussed the relative importance of management system standards versus company culture, particularly the presence of trust or distrust, on OH&S performance. This discussion was based on the paper entitled The Limits of Management Based Regulation by Neil Gunningham and Darren Sinclair.
In this paper, the authors conclude – “A lack of organizational trust was certainly one of the most important problems, for without trust, our evidence shows the effectiveness of management based regulation may be severely and sometimes fatally compromised.”
There are a lot of books – and consultants – offering advice on improving safety culture. “Safety culture” even has its own Wikipedia entry. Many of these resources do not; however, spend much time discussing trust.
If trust is critical to OH&S performance, what is it and how do you get it?
Although I usually refer to www.dictionary.com for my definitions, in this case I prefer the definition Steven Covey gives in his book - The Speed of Trust. He defines trust as confidence and he defines distrust as suspicion. He then goes on to discuss why trust is important – to individuals and society – and how to develop personal trustworthiness as well as trust in relationships and organizations.
To order this book from Amazon – click here The SPEED of Trust: The One Thing That Changes Everything
In his chapter on organizational trust, Steven Covey sets out four questions to ask to determine whether your organization has a high-trust environment.
- Does your organization have integrity – a culture of honesty and ethical behavior?
- Does your organization have good intent – a culture of caring?
- Does your organization have the right people to deliver value?
- Does your organization deliver on its promises?
Want to improve your OH&S performance?
Consider how you can use your OH&S management system to build or support trust rather than tear it down.
© ENLAR® Compliance Services, Inc. (2009)
Effectiveness of Management System Standards
I recently read with great interest a paper entitled The Limits of Management Based Regulation by Neil Gunningham and Darren Sinclair.
In this paper, the authors sought to answer the following question –
Do management-based OH&S initiatives work?
This is an excellent article. It is well-researched, well-written and, most importantly, actually supported by independent research.
It also challenged my beliefs about the effectiveness of management system standards. That was uncomfortable, to say the least.
This paper concludes with the following paragraph:
These findings have important implications for regulatory theory, and suggest that the claim that management based regulation – or meta-regulation more broadly – can overcome many of the traditional challenges of regulating complex organizations is overstated….in [the mining] industry at least, management based regulation is substantially constrained by low organizational trust, minimal mine site commitment and divided loyalties.
The Need for PM
What do the National Mall, my homeowner’s association and your OH&S management system have in common?
The need to pay for preventive maintenance.
When we moved to Florida, we purposely choose to live in a neighborhood that did NOT have a golf course, community center or jointly owned “common areas.” Instead, we choose a neighborhood that had a voluntary homeowners association – not a mandatory one. A couple of years ago, a few neighbors wanted to “beautify” the neighborhood by putting up signs and installing landscaping. They did so. Then, because the plantings they put in were dying and you could not see the new signs at night, they wanted to add irrigation and lighting. They did so. Needless to say, once they realized that these things were costing money, there was an attempt to impose mandatory fees to pay for the on-going expense. It didn’t happen. These neighbors became upset when the rest of the neighborhood was not interested in paying for their neighborhood beautification efforts.
According to last Friday’s paper, the National Mall is slipping into a state of neglect. Apparently, ducks died last year of avian botulism because the water in a mall pool was so foul, the Jefferson Memorial is sinking into the mud and the soil is so compacted in places that grass can’t grow. Yet, Congress has refused to provide funding to pay for the necessary upkeep.
What do these stories have in common?
The failure to recognize that – “If you build it, you’ve got to maintain it.”
This is an important warning to keep in mind as you develop your OH&S management system.
Whatever systems you put in place must be maintained –
- Documents need to be reviewed and revised
- Software needs to be maintained and updated
- Controls need to be inspected and maintained
All of this costs money.
Make sure you consider the long-term preventive maintenance costs before you put systems, software and controls in place. If you can’t maintain them, you may only make things worse.
© ENLAR® Compliance Services, Inc. (2009)
Safety is NOT Free
Bottom line – an effective occupational health and safety management system costs money.
There are those that argue that safety – like quality – is free (in line with the classic book by Philip Crosby – Quality is Free). The premise being that, in the long run, effective safety programs save money and add business value. Unfortunately, this premise is difficult to prove. This argument strikes me as similar to the “free market” argument that financial markets don’t need to be regulated because they will regulate themselves. Perhaps that is true in textbooks, but rarely – if ever – in practice.
To order Crosby’s book from Amazon – click here Quality Is Free: The Art of Making Quality Certain
OHSAS 18001 specifically requires that top management determine the need for and ensure the availability of the resources essential to maintain the established OH&S management system and prevent workplace injuries and ill health (Section 4.4.1 of OHSAS 18002).
Presidents, Process and Supreme Court Nominees
I have been following with interest the nomination hearings of Sonia Sotomayor. I find the focus on substance (i.e. what she believes) as opposed to process (i.e. how decisions are reached) fascinating.
When we were at Disney earlier this month, we visited the re-opening of the Hall of Presidents featuring Obama as the newest President of the United States. As I sat through the presentation, I contemplated which of the Presidents has had, or will have, the greatest impact on American life.
Interestingly, one of Presidents with a direct and on-going impact is William Howard Taft. Not because of what he accomplished as President but because of what he did after serving as President. Taft is the only President to go on to serve as Chief Justice of the Supreme Court. He considered this the highest point of his career. While at the Supreme Court, he was instrumental in establishing the processes for how legal cases are handled – processes that are still in place today.
In many legal cases, process determines outcome. This can occur in a variety of ways. Process can determine whether a matter is heard in the first place. Process may make a case too expensive to litigate – or continue litigating. Process may prevent any further appeal of an unfavorable lower court decision. In all of these circumstances, process can be more important than substance.
The same thing can occur in occupational health and safety management systems. The processes you put in place will have a direct impact on your ability to prevent injury and ill health. If your work instructions do not include safety precautions, safe work practices will not be used. If your safety SOPs are complex and unwieldy, they will be ignored. If employees are criticized for using safe work practices because it impacts production, employees will be less likely to work safely next time. In all of these cases, “processes” can have direct health and safety consequences.
Remember, to have good outcomes you need good processes.
© ENLAR® Compliance Services, Inc. (2009)
