Category: OHSMS Implementation
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)
What is an effective OH&S program?
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)
What is Hierarchy of Controls?
I recently had the following question e-mailed to me – “What is the “Hierarchy of Controls” [referenced in section 4.3.1 of OHSAS 18001:2007] and how do I address it in the hazard control & risk assessment procedure?”
The “hierarchy of controls” is a protocol that you use when deciding what kind of control measures you are going to use to address a particular OH&S hazard. The rationale underlying the “hierarchy of controls” is that an organization should use more reliable control measures rather than measures that are more likely to fail.
What are you going to STOP doing?
Many OHS management systems and programs have a major problem – they are bloated with paperwork, inefficient in their operation and filled with busywork. These programs are often focused on the achievement of arbitrary metrics rather than improved OH&S performance. As a result, the managers of these programs are often fed-up, burned out and overwhelmed. They are also increasingly being told – “Given the current economy, you need to do more with less.”
That is the wrong message and the wrong goal.
To quote Peter Drucker – “There is nothing so useless as doing efficiently what should not be done at all.”
The goal should not be to do more with less – it should be to do less.
“It’s The System, Stupid.”
What does the current meltdown of the global financial markets teach us?
To paraphrase a line from the last presidential election – “It’s the System, Stupid.”
Right now, there is a lot of finger-pointing and plenty of blame to spread around. This mess is not, however, the fault of a single individual, a single institution or, even, a single political party. Instead, it is the system that is flawed.
“Data Sprawl” – Not Just an IT Problem
An article in the 6/30/2008 issue of CRN Magazine reported on the problem of “sprawl proliferation” associated with the use of virtualization in IT datacenters. Because virtual machines are easy to deploy, they don’t get the same scrutiny as the purchase of physical machines. The result – virtual machines that are not doing any meaningful work and thousands of dollars of assets locked away in computer redundancy.
“Data sprawl” is also a significant concern for OH&S management systems.
“You Will Be Assimilated.”
One of the interesting, and challenging, issues in developing an OH&S management system is the tension between developing detailed work instructions versus relying on competent individuals to perform critical OH&S tasks.
On one hand, there is the view that all tasks, especially important ones, need to be reduced to written work instructions. After all, the person performing these tasks might “win the lottery” and never return to work. On the other hand, there is the view that it is more important to have competent people performing critical tasks. The example — “If you were going to have brain surgery, would you want a surgeon who is competent or an individual who is simply following a set of written work instructions?”
This conflict of views was recently brought into focus for me. A senior manager in a company suggested that the work being done by the OH&S staff should be reduced to “work instructions that anyone can follow” for entry into the company’s preventive maintenance program.
Let’s Not Kill Our Responders
June 1 marked the beginning of the 2008 Hurricane Season. Both individuals and organizations in Florida are being urged to review and update their emergency plans to ensure we are ready in case a serious storm comes our way this year. There are articles in the paper on ensuring that our pets are save, putting together our “Grap-and-Go Kits” and hurricane-proofing our landscaping.
So what does that have to do with an occupational safety and health management system?
A great deal, as it turns out.
As I mentioned in my last post, I attended the annual AIHce two weeks ago. The keynote speaker on Wednesday morning was Dr. Robin Herbert. She is the director of the World Trade Center Medical Monitoring Program Data and Coordination Center with the Mount Sinai Medical Center in New York, New York.
Her presentation covered, in sometimes graphic detail, the on-going health impacts to those who responded to the World Trade Center (WTC) attack on 9/11. This includes both physical and psychological health effects – including respiratory disease, stomach problems and post-traumatic stress disorder (PTSD). Some of these effects are the result of the fact that individuals worked long hours, ate their meals and slept outdoors at the site – in effect having 24/7 exposure to a toxic environment.
Dr. Herbert ended her presentation with a list of recommendations that every organization should consider in their annual review of their emergency plan to prevent future impacts to the health of their emergency workers and first responders:
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Ensure that each person has, and is trained to use, appropriate personal protective equipment
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Include the steps (and supplies) necessary to define a “boundary” around areas that are not safe and limit access to those areas
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Limit the time individuals spend in emergency response and in areas with unsafe exposures
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Record the name of each individual who participates in the emergency response in case future follow-up is needed
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Take action to prevent and address psychological as well as physical trauma
Just as we have learned for confined space entry, we need to be aware that emergency response to disaster events can kill or maim responders. We need to have plans in place to prevent this from happening – before the disaster occurs. In other works – we need to include emergency response as part of an OH&S management system.
© ENLAR® Compliance Services, Inc. (2008)
Three HSE Strategies
I attended the annual American Industrial Hygiene Association conference (AIHce) last week in Minneapolis, Minnesota.
There were many excellent sessions covering a wide range of topics important to the practice of industrial hygiene. In particular, the Tuesday morning general session focused on demonstrating the value of the industrial hygiene profession and included a presentation by Jeffrey P. Pino, President of Sikorsky Aircraft Corporation.
In his presentation, Mr. Pino stated that there are three strategies important to a successful HSE (health, safety and environmental) program:
- Leadership Commitment
- Employee Engagement
- Risk Management
These three strategies are also critical to the implementation of an occupational safety and health management system based on OHSAS 18001:2007.
