This interest seems to be driven by two organizational concerns – transparency and risk.  In particular, it appears to be driven by the risks associated with transparency.

I attended the ISO 9000 Conference earlier this week. 

One of the keynote speakers – Bennie Fowler from Ford Motor Company – discussed how Ford has refocused on its core principles in order to achieve a financial turn-around.  This includes a re-emphasis on the principle – “Quality is Job #1.”  At Ford, quality is now an integral part of executive strategy discussions.

One of the main drivers for this renewed emphasis on quality is transparency. 

Due to the “open communication” nature of the intranet, companies can no longer hide their quality problems. 

Today, delivering a quality product every time is key to survival.  If a company does not, its quality issues are likely to be reported on the intranet for all to see.

Other speakers discussed the on-going shift in focus from product quality to organizational quality.  According to surveys, consumers often buy products because of their perception of the company rather than because of any objective evaluation of the quality of a particular product. 

This means that organizational risks become marketing risks. 

This customer focus on organizational quality is one of the drivers in the increase in corporate sustainability reporting.  Customers are interested in whether a company is a good corporate citizen.  They want to make sure their brand loyalty is justified.

These sustainability reports often include an occupational safety and health component.  This usually consists of “some numbers” associated with injury rates. 

But are these numbers true?

If the studies that have been conducted on the accuracy of injury reporting are to be believed, maybe not. (Click here to go to a previous blog post about injury and illness reporting issues.)

Why?

There is no global standardization, no accountability (as in a third-party review of the data or processes used to develop the data) and definitely no transparency for injury and illness metrics.   There is no easy way to check the numbers being reported, nor is the information available to do so.  Right now, we simply have to take the company’s word for it that these “metrics” are accurate.

Quality is being driven by the risks of transparency; safety is not.

© ENLAR Compliance Services, Inc. (2012)

At the end of the year, our attention often focuses on planning – the setting of goals and objectives for the coming year.  This can be exciting - plans for launching new projects or products – or it can be depressing - setting aside time to organize old files.

Planning is a key component of an OH&S management system.  The planning section of OHSAS 18001 consists of 3 elements –

• Identifying hazards and risks (4.3.1)
• Identifying legal and other requirements (4.3.2)
• Establishing objectives and programs (4.3.3)

Many organizations put a great deal of time and attention into identifying both their hazards and risks and their legal and other requirements. Often, less attention is paid to establishing objectives and programs.

This lack of attention to objectives and programs may be due, in part, to a lack of clarity about how “objectives” actually fit into a management system.  This lack of clarity about objectives, and their interrelationship with risk management, has been an issue of much heated discussion.  It has lead to a lack of consensus in ISO’s attempt to develop consistent definitions across all of its management system standards (see discussion of ISO’s MSS initiative).

One of the areas of confusion relates to the ownership of OH&S objectives.  Although individuals need to be assigned responsibility and authority for achieving OH&S objectives, OH&S objectives are organizational – not personal.  This is clear from the definition of OH&S objective in section 3.14 of OHSAS 18001.  An objective is a goal that an organization sets itself to achieve.   Therefore, OH&S objectives need to be set from an organizational perspective – not as individual performance targets.  This is a critical distinction.  It is the organization itself that is ultimately responsible for setting and achieving its objectives.  This responsibility cannot be shifted onto the backs of individual employees – such as the facility Safety Manager.

A second area of confusion relates to the use of the words “objective” and “risk” in two different contexts within the ISO management system standards and OHSAS 18001. 

The “top-level” meaning – used in defining both what a “management system” is and the meaning of the word “risk.” 

A management system is defined as a “set of interrelated or interacting elements to establish policy and objectives and to achieve those objectives” (ISO 9000, Section 3.2.1 & 3.2.2).  Risk is defined as “the effect of uncertainty on objectives” (ISO 31000, Section 2.1). Both of these definitions are focused on the strategic, organization-wide level of objectives.

This means that the overall “strategic level” objective of an OHSAS 18001 management system must be controlling (managing) OH&S risks in order to prevent injury and ill health to persons working under the control of the organization.  All other OH&S objectives flow from, and must be consistent with, this strategic-level objective.

The “functional level” meaning – used at a project, process or departmental level of an organization. 

This is the level at which most organizational objectives are set and managed.  Financial profitability and sales targets.  Product quality metrics.  Safety performance targets.  Waste reduction goals. 

The functional-level definition of an “OH&S objective”, as set out in section 3.14 of OHSAS 18001, is an “OH&S goal, in terms of OH&S performance, that an organization sets itself to achieve” (OHSAS 18001, Section 3.14).

Functional-level objectives are important.  They are where “the rubber hits the road” so to speak.  However, when evaluating OH&S performance and assessing overall risk management, the objective that must be kept foremost in mind is the strategic, top-level one.

At the end of the day, the question that must be answered is “Are we, as an organization, controlling our OH&S risks in a manner that prevents injury and ill health to those working for our organization?”

© ENLAR Compliance Services, Inc.(2011)

This debate impacts occupational health and safety management systems as well.  We just don’t call it nature vs. nurture.  Instead we discuss safe workplaces (the inherent nature of the workplace) vs. behavior-based safety (the safe or unsafe activities of workers).

Although it is not yet clear how much of who we are is determined by heredity and how much by upbringing, it seems clear that both play a part.  As with the “nature vs. nurture” debate, occupational health and safety hazards are created by BOTH unsafe situations AND by unsafe acts.  You cannot focus solely on just one or the other in an OHSMS.

OHSAS 18001 makes this clear. 

By definition (see OHSAS 18001:2007 3.6), hazards include sources, situations AND acts with the potential for harm.  This includes unsafe conditions in the workplace.  This ALSO includes unsafe activities on the part of people.

Some organizations seem to forget this distinction when they develop their processes and procedures for hazard identification.  They focus almost exclusively on looking at sources of hazards – such as those associated with machinery, facilities, physical stressors and chemical agents.  The behavior of people, driven by the psychology of human behavior, is often ignored.

What is being missed?  Here are some examples –

• Individuals will climb over or duck under conveyor belts in order to avoid the long walk around a process line.
• Maintenance workers will not lockout a piece of equipment if they have to climb up and down five flights of stairs in order to do so.
• Workers will not wear safety clothing that is too hot or safety glasses they can’t see out of.

This is one of the major distinctions between an OHSMS risk assessment and an EMS aspect evaluation. 

In many instances, the human element is less important when characterizing environmental impacts.  Most environmental impacts still exist even if there are no people present, but this is not the case with most safety hazards.  This is the reason why isolation can be an appropriate OH&S control measure.  The hazard still exists but not the OH&S risk.

© 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)

Many organizations partially address this requirement by establishing an ergonomics program in order to address physical human factors.  Only a few organizations explicitly address mental human factors as a part of their hazard identification and risk assessment. 

Yet, mental human factors are very real and can be just as important as physical human factors.  In some cases, they are even more important. 

For example, when one is driving a car, factors that reduce mental acuity – such as talking on a cell phone – are typically much more significant than physical capabilities.  The dangers of being distracted while driving is important enough that the first Distracted Driving Summit was held last fall and the U.S. Department of Transportation has set up a Distracted Driving website. 

The human brain has been described as having “a very large hard drive but limited random access memory (RAM).”  As demonstrated by our proficiency at trivia games and success in answering questions on quiz shows like Jeopardy, the human brain is capable of storing a great deal of information.  On the other hand, studies show that most people have difficulty remembering more than 7±2 items at a time in short term memory.  Our mental processes were developed for a very different environment than we find ourselves in today.  In the past, our modes of information delivery moved much, much slower with significantly fewer “inputs per minute.”  

Yet we design work environments as if this mental limitation does not exist. 

We expect individuals to work at full capacity in environments with multiple stimuli.  We set up equipment lines so they are efficient for the machines but terrible environments for the people who have to work there.  We design work processes and work shifts as if mental limitations do not exist.

Unfortunately, when accidents do occur – which they inevitably will – we blame the individuals involved and tell them how “bad” they are. 

I’m not sure if this is silly, sad or tragic but it sure is NOT a sound management system approach.

© ENLAR® Compliance Services, Inc. (2010)

The need for considering “the human element” was brought home to me by the recent flurry of articles and news reports covering the hazards associated with using cell phones when driving.  According to these reports, a study conducted by the National Highway Traffic Safety Administration found that talking on a cell phone while driving is as dangerous as drinking alcohol and driving.

These news reports, and similar ones on the use of tanning beds by teenagers and the lack of hand hygiene in health care, lead me to wonder:

• Why do people use cell phones while they are driving?
• Why do teenagers pay to use tanning beds?
• Why do doctors treat patients without washing their hands?

Why do individuals make such seemingly “irrational” decisions?

I’m not sure I have a satisfactory answer to this question; however, asking this question is an important part of your OH&S management system.

OH&S hazards are not limited to faulty equipment and hazardous materials, they also involve the human element – how people behave and WHY they behave as they do.

OHSAS 18002 suggests that when conducting your hazard identification, you should consider –

• The nature of the job (workplace layout, operator information, work load, physical work, work patterns)
• The environment (heat, lighting, noise, air quality)
• Human behavior (temperament, habits, attitudes)
• Psychological capabilities (cognition, attention)
• Physiological capabilities (biomechanical, anthropometrics/physical variation of people)

Considering these factors – and their interactions – can help you determine why individuals are behaving as they are and what OH&S hazards are being created as a result.  Only if you understand “the human element” will you have the information you need for determining the appropriate OH&S controls to put in place.

© ENLAR^® Compliance Services, Inc. (2009)

Disney Fireworks

Unfortunately, early Sunday morning tragedy struck Disney’s transit system when two monorail trains collided – killing one of the train operators.  According to news reports, the Occupational Safety and Health Administration (OSHA) is currently conducting an investigation into this accident. 

I was contemplating this accident – and the resulting negative publicity for Disney – as I reviewed the latest draft of ISO 31000 – ISO’s newly developed Risk Management standard.

One of the weaknesses of many risk management programs is failing to fully evaluate the risks associated with events that are rare (low likelihood) but with the potential for severe (highly negative) consequences.  In Section 5.5.2, ISO 31000 suggests that such events may warrant risk treatment even when it appears that action may not be justifiable on strictly economic grounds.  The typical assumption being that the event will never happen; therefore, the time and money expended to evaluate and address the risk will be wasted.

This monorail accident appears to be this type of an event. 

It was clearly rare.  According to Disney, this is the first fatal crash in the 38-year history of the monorail’s operation.   

Yet, the consequences of this accident are likely to be severe –

• death of an employee
• reduced confidence in – and utilization of – the transit system by guests
• the costs incurred associated with an OSHA fatality investigation – even if no fines are imposed
• negative publicity for a company that is very concerned about maintaining a positive public image

Take ISO 31000’s advice to heart in your own risk management programs – including the risk assessments conducted to meet the requirements of OHSAS 18001.  Be sure that your low likelihood risks are evaluated - including those associated with abnormal or unusual activities.  As the accident at Disney proved, just because an event hasn’t happened yet, that doesn’t mean it may not happen tomorrow.

© ENLAR^® Compliance Services, Inc. (2009)

Elimination is considered the most relable control measure because, if a hazard is eliminated, it no longer poses a risk.  On the other hand, control measures that rely on individuals behaving in a certain way are considered less reliable. The wearing of personal protective equipment (PPE) is considered a less reliable control because it is dependent on individuals using the right PPE and wearing it correctly.

For example, lets say the “hazard” one wants to control is exposure to a chemical used in cleaning a manufacturing area that is likely to cause ill health at a certain level of exposure. 

To use the “hierarchy of controls” protocol – you would take the following steps –

1. Explore whether the use of the chemical can be eliminated
2. If the use of the chemical cannot be eliminated – then you would explore whether there is a substitute chemical that can be used that does not have the same potential to cause ill health
3. If the use of the chemical cannot be eliminated and there is no suitable less toxic substitute – then one explores whether there is an appropriate engineering control  – such installation of a ventilation system that reduces the exposure
4. If an engineering control cannot be used (or until it can be installed), then other “adiminstrative controls” such as warning signs, PPE, etc. would  need to be put in place to reduce the hazard

The use of hierarchy of controls is a reiterative process – as individual control measures are put in place, you need to go back and re-evaluate the risk to see if it has reached an acceptable level or if additional controls are still needed.

For any particular hazard, more than one control measure may be needed to address the risk.  For example, controlling the risk of exposure to a toxic chemical may require the installation of a ventilation system AND establishing a preventive maintenance program for the ventilation system AND the use of warning signs AND the use of PPE. 

© ENLAR^® Compliance Services, Inc. (2009)

ABC News reported on just such a situation last night.  It included a segment on the health implications of driving a school bus and the steps Broward County, Florida has taken to address them.

What did the Broward County School Board do?

They initiated an employee wellness program focused on improving the overall health of their bus drivers.  This included offering incentives for drivers to participate in a regular exercise program.   

Why does driving a bus pose a health hazard?  

Driving a bus is a sedentary activity.  Bus drivers, like other drivers of commercial vehicles, may spend hours sitting in one spot – even if that “spot” happens to be moving.  As a result, drivers often gain weight and develop other health conditions such as high blood pressure and/or diabetes.  This is on top of other hazards, such the risk of injury due to accidents and exposure to diesel fumes.

Why did the school board act?

In addition to the desire for healthy drivers, the school district was concerned about cost.  According to the school board wellness coordinator – “Those types of health conditions (high blood pressure and high cholesterol) translate into high claims.  The school board wants to save lives and reduce claims.”

So when you are doing your hazard identification – be sure to ”think outside the box.”  Don’t limit your investigation to only the inside of your facility.  Make sure you look outside as well.  Include workers such as bus drivers, outside sales staff, repair technicians, and mobile workers – their health is important as well.

© ENLAR^® Compliance Services, Inc. (2009)

It is equivalent to assembling a meal from an a la carte menu.

So what are your a la carte choices?

They are numerous and varied and include –

• Checklists and questionnaires
• Consequence / likelihood matrices
• Failure modes and effects analysis (FMEA)
• Hazard and operability studies (HAZOP)
• Exposure assessment strategies
• Bayesian analysis
• Ergonomic evaluations
• Computer modeling programs

Just as the key to healthy eating is making wise menu choices, the key to a sound OH&S risk management strategy is choosing the hazard identification and risk assessment tools that are appropriate for your organization.

© ENLAR^® Compliance Services, Inc. (2008)