Category: Upcoming Events
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)
Many companies are increasing including some type of “injury and illness data” in their sustainability reports. It is one of the metrics included in the GRI reporting scheme. It is used both internally and externally to determine financial bonuses. It is also used by a number of companies and governmental agencies to select qualified contractors. There is a great deal of pressure to report low numbers.
The question is – “How accurate is this data?”
There are many who believe it isn’t very accurate at all.
As I discussed in a previous blog, there are strong incentives for under-reporting and, very often, little or no independent verification of the numbers. This is even the case for many of the processes and web-based tools used by major companies to select contractors.
Safety professionals may want to re-assess the risks associated with the creation and external reporting of injury and illness data.
Companies may want to re-assess their reliance on data that has no independent verification.
Because, given the results of a recent court case, inaccurate reporting can be considered fraud and those involved can go to jail.
In early November 2012, a jury convicted a safety manager for The Shaw Group of eight counts of major fraud against the United States. They found that he had provided false and misleading information about injuries associated with work at TVA (Tennessee Valley Authority) facilities. This false injury data was used by his company to collect safety bonuses worth over $2.5 million. (Note – According to the DOJ press release, The Shaw Group entered into a civil agreement in 2008 with the United States and paid back twice the amount of the safety bonus they collected.)
What to know more about verifying injury and illness data?
© ENLAR Compliance Services, Inc. (2012)
It is clear that integrated management systems represent the future.
This is evident from directives coming from the ISO Technical Management Board (TMB) that require the ISO technical committees to use a standardized structure and definitions for all ISO management system standards. (Click here to read more about this MSS initiative.)
It is also evident in non-ISO management system standards – such as the Responsible Recycling (R2) Practices standard.
The R2 Practices is a certification standard developed to help address the improper handling of electronics waste (E-waste). This “E-Waste Problem” being the health and environmental impacts that result from the improper handling of E-waste – particularly in developing countries. The R2 Practices standard is made up of 13 Practices that include quality, environmental and OH&S management system requirements – as well as mandatory supply chain management and a demonstration of financial responsibility.
Next Monday, February 27, 2012, I am giving a presentation about this standard at the ISO 9000 Conference in Orlando Florida. My presentation is entitled Responsible Recycling: Using Integrated Management Systems for Handling Electronics Waste. This presentation is part of a conference track entitled Making Integrated Management Systems Work.
In order to provide additional information to conference attendees (there being only so much one can include in a 35 minute presentation), I have launched a new website. This website focuses specifically on understanding the R2 Practices and implementing the management system processes necessary in order to become certified.
Interested in how to use a management system to improve management of electronics waste?
Go to www.R2expert.com to learn more.
p.s. – My presentation isn’t just for “recyclers.” It outlines five steps that any organization can take to better manage its used electronics.