Category: Standards & Certification

Should Organized Labor “Own” Occupational Health & Safety?

According to discussions surrounding the survey currently being circulated by the Technical Management Board (TMB) of ISO, one of the important factors in determining whether ISO moves forward with an occupational health and safety management standard (OHSMS) is whether ISO should defer to the International Labor Organization (ILO).  ILO has published its own guidance document on OH&S management systems — ILO-OSH 2001 Guidelines on occupational safety and health management systems.

Setting aside for the moment whether ISO is the appropriate forum for setting social standards, this raises an equally interesting question:

Should Organized Labor “Own” Occupational Health & Safety?

Should ISO Develop an OH&S Management System Standard?

The International Organization for Standardization (ISO) is once again considering whether or not it should develop an OH&S Management System Standard (For information about ISO standard-setting activities go to http://www.iso.ch/iso/en/ISOOnline.frontpage)

The Technical Management Board (TMB) of ISO recently sent a survey form to the ISO member bodies (the various national standard-setting organizations from each country) asking for direction on whether to proceed in developing an OHSMS standard and, if so, what kind of standard.

Developing an ISO OHSMS standard has been an area of considerable controversy. Some labor and industry groups have been vehemently opposed to such an ISO standard.  Other interested parties believe that, given the proliferation of different OHSMS standards and increased usage of OHSAS 18001, the time has come for the development of an international consensus standard that supports third-party accreditation of occupational health and safety management systems. (See my prior post on the plethora of OH&S standards that have been developed at http://ohsas18001expert.com/2007/05/15/a-plethora-of-ohs-standards/)

What do you think?

Opinion Polls & Market Research

Occupational Health & Social Responsibility

I attended the meeting of the U.S. Technical Advisory Group for ISO TC 207 this week (TC 207 is the ISO technical committee that develops international environmental management system standards).  It was held at the same venue where the U.S. delegates to the ISO Working Group on Social Responsibility were having their meeting.  According to my discussions with a colleague who attended that meeting, progress on the ISO Social Responsibility standard is slow.

It reminded me of my thoughts after attending the American Industrial Hygiene Conference in Philadelphia this year.  One of the “hot” topics at the conference was the setting of occupational exposure limits (OELs).  With the European Union’s REACH legislation coming into force, determining appropriate occupational exposure limits has become an important concern for many companies.

It is not; however, really a new issue.

Recently, when I was reviewing some old files, I came across a World Health Organization (WHO) Technical Report published in 1977.  The title of the publication — Methods used in establishing permissible levels in occupational exposure to harmful agents.

This report is a summary of the conclusions of a WHO Expert Committee that met in August of 1976 for the purposes of reviewing the information available on methods used to establish permissible limits, providing advice to developing countries on appropriate approaches and identifying gaps in knowledge.

What did I find interesting in this report, almost 30 years later?

The Recommendations.

I found the following particularly poignant:

“Industrial nations should ensure that multinational corporations and national aid programmes fulfill their ethical responsibility to consider occupational health needs.  Industrial development should be planned to prevent and not repeat the lamentable mistakes of the past that caused serious occupational health problems.  Multinational companies have a responsibility to ensure that permissible levels accepted by these companies in developed nations are not ignored in developing nations…”

Unfortunately, this recommendation is as relevant today as it was in 1977.

© ENLAR^® Compliance Services, Inc. (2007)

International Standards – Building On Each Other

When you get involved in developing international standards, you quickly discover that they build one upon another.  The definitions used in OHSAS 18001 are from ISO 14001 — those definitions came from ISO 9000 which, in turn, came from other standards before it.  Similarly, standards are now being developed using OHSAS 18001 as a model.  If you are interested in standard-setting — or you want to have input into the standards that may impact you as a safety professional — you should check out the standard currently being developed by the European Committee for Standardization (CEN).

CEN, in conjunction with other key stakeholders, is drafting a Laboratory Biorisk Management Standard.  This standard, based in part on the language in OHSAS 18001:2007, is being developed to set the requirements necessary to control the risks associated with activities in laboratories where biological agents are handled and to enable organizations to seek certification by external third parties.  It is a management system standard, based on plan-do-check-act, that is intended to be compatible with ISO 9001, ISO 14001 and OHSAS 18001.

The draft standard is out for public comment until September 25, 2007.  A copy of the draft standard is available at http://www.cen.eu/cenorm/businessdomains/technicalcommitteesworkshops/workshops/ws31.asp

© ENLAR^® Compliance Services, Inc. (2007)

What is Occupational Safety & Health?

In a previous blog, I noted that five significant changes were made in the 2007 revision of OHSAS 18001.

One of these changes is in the intended coverage of OHSAS 18001.  As noted in the Scope section of the revised standard, OHSAS 18001 is “intended to address occupational health and safety, and is not intended to address other health and safety issues such as employee wellbeing/wellness programmes, product safety, property damage or environmental impacts.”

Several changes were made to the standard to clarify the intended scope of coverage – most notably in the revision and/or addition of several key definitions.

First, the definition of hazard no longer includes “damage to property or damage to the workplace environment.”  It was concluded that these types of damage are part of the field of asset management – not part of occupational safety and health.  For purposes of OHSAS 18001, hazards are limited to sources, situations or acts with the potential for harm in terms of human injury or ill health.  The focus is on harm to humans not property.

New definitions were added to the standard for “ill health” and “workplace.”  Neither of these terms were defined in the 1999 standard.  Ill health is defined as “identifiable, adverse physical or mental condition arising from and/or made worse by a work activity or work-related situation.”  The addition of this definition reflects an increased emphasis on health within OHSAS 18001.  Workplace is defined as “any physical location in which work-related activities are performed under the control of the organization.”  This definition is consistent with changes made throughout the standard that tie the OH&S responsibilities of the organization to areas and persons “under its control.”

Occupational health and safety (OH&S) is defined in OHSAS 18001 as “conditions and factors that affect, or could affect, the health and safety of employees, temporary workers, contractor personnel, visitors or any other person in the workplace.”  A note has been added to this definition that states “organizations may have a legal requirement for the health and safety of persons beyond the immediate workplace or who are exposed to workplace activities.”  Organizations may need to take such legal obligations into account in developing their OH&S management system.

Organizations seeking certification to OHSAS 18001:2007 need to determine and document the scope their OH&S management systems (a new requirement in section 4.1 of the standard).  This will mean careful consideration of exactly which workplaces and what individuals are covered.  For some organizations, this may mean more attention to issues such as the visitor safety and evaluation of hazards to workers working at off-site locations (e.g. transit drivers).

© ENLAR^® Compliance Services, Inc. (2007)

Coming Soon – OHSAS 18001:2007

A revision of OHSAS 18001, Occupational health and safety management system – Requirements, is scheduled to be published in early July 2007.

When OHSAS 18001 was initially drafted in 1999, it was specifically written to be consistent with ISO 14001:1996, the environmental management system standard developed by the International Organization for Standardization (ISO).  When ISO 14001 was revised in 2004, some of the alignment between the standards was lost.

In 2005, the OHSAS Working Group decided to revise the OHSAS 18001 standard to again align it with ISO 14001 and to improve it based on the experience of the standard’s users since it was first published in 1999.

This revision is the culmination of over a year of work.  An initial draft of the revised OHSAS 18001 standard was circulated in February 2006 for public comment.  Approximately 500 comments from 36 commentators were recieved and reviewed in an initial meeting of the OHSAS Working Group in Madrid, Spain in October 2006.  Because a number of significant changes were being proposed, a second draft of the revised standard was circulated for comment in November of 2006.  Again, many groups and individuals provided comments (approximately 540 comments from 46 commentators in 24 countries).  These comments were reviewed during a second meeting of the OHSAS Working Group in Shanghai, China in March 2007 and a final draft was agreed upon.  As a participant in these meetings, I can attest that they were exhausting!

In addition to alignment with ISO 14001, another major factor taken into consideration during the revision process was alignment with other occupational safety and health management system standards such as the ILO and the ANSI/AIHA Z10 standards.

Based on these inputs, a number of significant changes have been made to the OHSAS 18001:

• Improved alignment with ISO 14001:2004
• Changes in the areas covered by the standard
• New requirements related to hazard identification, risk assessment and the selection of controls
• New requirements for external consultation and worker participation
• Clarification of the role of incident investigation

These changes will be discussed in more detail in future blogs.

© ENLAR Compliance Services (2007)

ANSI/AIHA Z10 — The United States OHSMS Standard

In 1999, the American National Standards Institute (ANSI) initiated a standard-setting activity to establish a United States occupational health and safety management system (OHSMS) standard.  This activity was concluded in 2005 with the publication of ANSI/AIHA Z10 Occupational Health and Safety Management Systems.

A number of stakeholders participated in this standard-setting process including representatives from the U.S. Occupational Safety and Health Association (OSHA), organized labor, industry and OH&S professional associations.  In all, over 40 organizations had representatives on the committee.

ANSI/AIHA Z10 was developed to be compatible with other management systems such as ISO 9001 and ISO 14001 and is based on the management system concept of Plan-Do-Check-Act. As stated in the introduction to the standard, the purpose of the standard is “to provide organizations an effective tool for continual improvement of their occupational health and safety performance.”

This standard is formatted differently then an ISO standard.  It is structured into two columns.  The requirements (“shall” clauses) are set out in the left column; recommendations & explanations (“should” clauses) are set out in the right column.

A copy of the standard can be obtained from the American Industrial Hygiene Association at http://iweb.aiha.org/iweb/Purchase/ProductDetail.aspx?Product_code=SMAA05-698

A “Plethora” of OH&S Standards

The Random House Unabridged Dictionary defines “plethora” as an “overabundance or excess.”  That certainly describes the situation when it comes to OH&S standards, particularly OH&S management system standards.

There are international OH&S standards, there are national OH&S standards and there are state and local OH&S standards.  In addition, there are standards developed by individual organizations and government agencies and there are “standards” developed and promoted by individuals who believe they have “a better idea” when it comes to safety management.

Nor is there any lack of OH&S management system standards.  In their 2005 survey of OH&S management system standard usage, the OHSAS 18001 Working Group identified over 40 different OH&S management system standards that were in use in various places around the world.

For the following reasons, coming up with a definitive list of OH&S management system standards is nearly an impossible task:

1. Individuals differ in their view on the criteria that establishes a document as a “standard.”  For example, some individuals view OHSAS 18001 as a standard; others vehemently argue that it is not because it was developed by an independent group.

2. There is disagreement on what is included – or is not included — within the scope of occupational safety and health and therefore what qualifies as an OH&S standard as opposed to an environmental standard, a general safety standard or a property protection standard.  For example, what are fire prevention standards?

3. Finally, even if there is agreement on the first two points, there can be disagreement on whether a particular document states requirements for a “management system.”  Does a standard contain manditory “shall” clauses or does it simply provide “good advice” that you can accept — or simply ignore.  Does it matter?

Some of the OH&S management system standards currently available include the following:

• OHSAS 18001:1999 — developed by an independent group of national standards organizations and certification bodies.

• ANSI/AIHA Z10:2005 — U.S. national standard

• CSA Z1000-06 — Canadian national standard

• AS/NZS 4801:2001 — Australia / New Zealand national standard

• ILO-OSH 2001 – standard developed by the International Labor Organization