Welcome to OHSAS 18001 Expert Blog.
This blog is intended to be a forum for sharing ideas, and opinions, on developing,
implementing and maintaining occupational health and safety management systems.
The focus is on OHSAS 18001, but other related management system standards will be discussed as well.
I look forward to your input and participation.
One of the difficult questions that OH&S managers face is – “Do we need a written procedure for [some process]?” The dilemma is that although written procedures are a necessary part of an occupational safety and health management system – if you create too many formal procedures your OHSMS becomes complex, cumbersome and unwieldy.
I just got done reading an article in the October 2009 Quality Progress Magazine that sets out a nifty tool for making this decision – a 2 x 2 matrix for deciding whether or not to standardize a process. Although the example given in this article – Building a Consensus – is for a quality system process, it can be easily adapted to making standardization decisions in an OH&S management system.
Try it out for your OH&S management system and let me know – “Did it work?” - by posting your comments below.
One of the signfiicant tasks associated with implementing any management system is managing information – typically lots of information. Usually, way too much information. As I discussed in a previous post – Data Sprawl – Not Just an IT Problem, the fact that we are now managing “virtual information” leads us to believe that the more information we have the better.
Not true.
As this video points out, at some point more information simply makes us stupid.
This is an important point to remember as you are establishing, implementing and maintaining your OH&S management system. As you are developing your procedures, programs, forms, inspection sheets, training programs, meeting minutes, e-mail updates…… remember that the human brain only has so much capacity.
There seems to be a “disconnect” between current economic realities and the metrics often suggested for evaluating OH&S programs and management systems.
Many organizations are facing a level of financial hardship not seen since the Great Depression. As a result, cutbacks, downsizing and belt-tightening are the new normal. “Do more with less” has become the mantra of business. This translates – for many EHS professionals – into being asked to get by with fewer people and no new resources.
On the other hand, many organizations seem unwilling to match their OH&S goals and expectations to the reality of fewer resources. Managers still insist on setting “continual improvement” metrics based on achieving “best-in-class” management system performance. This is often expressed in the form of a performance rating scheme based on some sort of numeric scoring of the “performance” achieved by particular S&H programs or management system elements (typically on a 1 to 4 or 1 to 5 scale). Examples of this abound. There is one set out in an article I just finished on SH&E Strategic Planningin the October 2009 Professional Safety Magazine.
Implicit in many of these of rating schemes is the assumption that there is “unused capacity” that can be utilized to achieve the performance improvement desired.
There seems to be a renewed interest in metrics, measuring and monitoring within OH&S management systems. Given the advances in continuous monitoring technology, this interest often translates into the installation of a host of different monitoring devices with alarms – fire detection alarms, security alarms, gas detection alarms, motion sensor alarms, electrical current alarms, high level alarms, low level alarms, entry alarms, exit alarms, etc.
One of the challenges associated with all of these alarms – “What are you supposed to do when the alarm goes off?”
Since my husband is at the top of the call list when an alarm goes off at his facility, I am only too familiar with this question – particularly since the “alarm alert” often occurs in the wee hours of the morning (as it did this morning). I can tell you attempting to answer the “now what?” question at 4 am is no fun.
This week I had the opportunity to attend and give a presentation at the NIOSH NORA Health Care and Social Assistance Sector Council Meeting in Washington DC. It was the first NIOSH NORA meeting I have attended and I found the discussion both very enlightening and somewhat scary.
At this meeting I gave a presentation – Challenges & Opportunities in Developing OHSMS Standards – that outlined five common barriers to implementing Occupational Health and Safety Management Systems. Also giving presentations on this topic were Mike Seymour from OSHA and Barbara Braun from The Joint Commission. Mike Seymour discussed the OHSMS guidance document that OSHA is currently in the process of developing and Barbara Braun discussed how the Joint Commission standards also include worker safety requirements. As several of the attendees pointed out, there is a clear and obvious link between patient safety and worker safety.
The purpose of these presentations was to assist the HCSA Sector Council in developing implementation plans for the new National Occupational Research Agenda for this sector (currently out for public comment until the end of October 2009). A key strategic goal in this agenda is promoting the use of OH&S management systems and improving safety culture in healthcare organizations.
The scary part of the meeting…
The critical issues that need to be addressed to protect health care workers – particularly as it relates to the H1N1 pandemic. There was a great deal of discussion concerning the precautions that need to be taken related to providing proper respiratory protection - NOT JUST SURGICAL MASKS – and the current lack of hospital preparedness. The importance of this topic was emphasized by the advisory issued by the Institute of Medicine yesterday that urges health care workers to use N95 respirators instead of surgical masks for protection.
In last week’s post, I discussed the relative importance of management system standards versus company culture, particularly the presence of trust or distrust, on OH&S performance. This discussion was based on the paper entitled The Limits of Management Based Regulation by Neil Gunningham and Darren Sinclair.
In this paper, the authors conclude – “A lack of organizational trust was certainly one of the most important problems, for without trust, our evidence shows the effectiveness of management based regulation may be severely and sometimes fatally compromised.”
There are a lot of books – and consultants – offering advice on improving safety culture. “Safety culture” even has its own Wikipedia entry. Many of these resources do not; however, spend much time discussing trust.
If trust is critical to OH&S performance, what is it and how do you get it?
Although I usually refer to www.dictionary.com for my definitions, in this case I prefer the definition Steven Covey gives in his book – Nothing is as Fast as the Speed of Trust. He defines trust as confidence and he defines distrust as suspicion. He then goes on to discuss why trust is important – to individuals and society – and how to develop personal trustworthiness as well as trust in relationships and organizations.
In his chapter on organizational trust, Steven Covey sets out four questions to ask to determine whether your organization has a high-trust environment.
Does your organization have integrity – a culture of honesty and ethical behavior?
Does your organization have good intent – a culture of caring?
Does your organization have the right people to deliver value?
Does your organization deliver on its promises?
Want to improve your OH&S performance?
Consider how you can use your OH&S management system to build or support trust rather than tear it down.
In this paper, the authors sought to answer the following question –
Do management-based OH&S initiatives work?
This is an excellent article. It is well-researched, well-written and, most importantly, actually supported by independent research.
It also challenged my beliefs about the effectiveness of management system standards. That was uncomfortable, to say the least.
This paper concludes with the following paragraph:
These findings have important implications for regulatory theory, and suggest that the claim that management based regulation – or meta-regulation more broadly – can overcome many of the traditional challenges of regulating complex organizations is overstated….in [the mining] industry at least, management based regulation is substantially constrained by low organizational trust, minimal mine site commitment and divided loyalties.
The hazard identification/risk assessment section of OHSAS 18001 (Section 4.3.1) requires that your procedures take into account “human behavior, capabilities and other human factors.”
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.
One of the requirements of OHSAS 18001 is that procedures must be established to make workers aware of the following –
The occupational health and safety (OH&S) consequences of their work activities and behaviors
Their roles and responsibilities for following OH&S policies and procedures
The consequences of not following these policies and procedures
As anyone who has put together communication and training programs will tell you, trying to raise awareness can be a difficult undertaking.
Therefore, I was struck by an article in the August 2009 ABA Journal that discussed how a New York City ordinance for “raising awareness” to prevent obesity ended up the subject of a lawsuit. Read the rest of this entry »
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