I don’t like risk matrices.
I have written blog posts, given speeches, and written comments on several draft consensus standards pointing out the flaws in using risk matrices in EHS decision-making. I continue to be frustrated by the insistence some registration auditors place on having them – even though there is no requirement in either ISO 14001 or OHSAS 18001 mandating their use.
Just last month, a registration auditor expressed his disapproval of a client’s aspect evaluation procedure because, as he put it,
“Where are the ranking numbers?”
So I was quite pleased when I stumbled upon the following YouTube video that set out in an explicit and graphic way why the majority of risk matrices are flawed.
There are three common problems associated with using a risk matrix –
1. As set out in this video, most numeric-based risk ranking tables are not based on a valid statistical approach and result in a biased analysis of the potential risks associated with the items being analyzed. Many times, the results do not even pass a “common sense” test when they are reviewed after the number-crunching is complete (i.e. “Does this result make sense based on what we know about our operation?”).
2. There is the temptation to use a risk matrix simply because there is insufficient information to do “a real analysis.” Rather that developing real data, numbers are simply assigned to educated guesses. The inevitable result is GIGO (Garbage In = Garbage Out).
3. Risk ranking tables are used to compare items that can’t be directly compared.
So, can a risk matrix ever be used?
Sometimes, if certain conditions are met.
Want to find out more, click here to read what they are in the latest EHS Management System Update Newsletter – Apples or Oranges – Which is Better?
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© ENLAR Compliance Services, Inc. (2013)
Yesterday, I received a copy of the ISO New Work Item Proposal (NWIP) for a new requirements standard for occupational health and safety management systems. ANSI has requested that comments on this NWIP be sent to ANSI by April 26, 2013, so ANSI can decide how it will vote on this proposal.
There are several interesting aspects to this NWIP –
1. This is a proposal for a Project Committee (PC), not a Technical Committee (TC).
The distinction is that a Project Committee is authorized to develop a single standard. This is the approach that was used for the development of ISO 50001:2011 – the ISO Energy Management System standard. An ISO PC can be converted into a TC in the future but, at least initially, the standard development authority of this ISO committee will be limited solely to the development of the one standard being proposed – an OHSMS requirements document.
2. Given the past controversy that has surrounded the development of an ISO OHSMS standard, this NWIP includes two additional letters.
The first is a letter from the Rob Steele, the ISO Secretary General, addressing the right and ability of ISO to deal with the subject area. The second is a letter from the International Labour Organization (ILO) expressing its concerns with ISO’s decision to proceed with this standard development effort.
3. Any ISO OHSMS standard will be required to meet the requirements for management system standards that are set out in Annex SL of the ISO Directives.
What this means is that an ISO OHSMS will not be based on any of the existing OHSMS standards – including OHSAS 18001 or ANSI Z10. These standards can serve as reference documents but many of the important requirements of an ISO OHSMS will be determined solely by the high-level structure and core common text that are set out in Annex SL.
ANSI is in the process of circulating this proposal to stakeholder groups in the United States. I am confident there will be a great deal of discussion of this NWIP. It is likely that there will be continued disagreement concerning the appropriate venue for developing OH&S standards.
As set out in BSI’s justication document, the world is markedly different today from what it was when an ISO OHSMS standard was last proposed.
Today, protection of workers is as much driven by a complex web of supply chain relationships and sustainability initiatives as it is by governmental decrees and enforcement actions. As show by the success of the certification initiatives that have developed around the handling of electronics waste, publicity and supply chain initiatives can have a greater impact in protecting worker health than governmental rulemaking.
In addition, given the increased use of outsourcing arrangements, many individuals performing work on an organization’s behalf are no longer employees in the traditional labor law sense. By extension, worker safety is no longer solely an employment issue. As explicitly set out in OHSAS 18001, and recognized in several OSHA standards, an organization’s obligation to protect workers extends beyond employees to individuals who are performing work on an organization’s behalf. This can include a range of parties – including contract workers, employees of contractors, volunteers, visitors to the workplace and employees.
Worker safety is no longer simply a labor issue to be addressed through governmental action.
Want to know more?
If you want to know more about Annex SL and the revision of ISO 14001, check out my previous blog post – New Year – New Standards.
If you want to review the ISO NWIP for an OHSMS standard click here (note – this document does not include the Justification Study and other attachments to the NWIP but does include copies of the letters discussed above).
© ENLAR Compliance Services, Inc. (2013)