Recent Posts
What is PDCA?
If you are exploring the web looking for information about implementing management systems, pretty soon you will come across the acronym PDCA. You will quickly discover that PDCA stands for plan-do-check-act but it may not be clear to you what this actually means.
This page provides access to a FREE mini-course that provides clear and concise answers to the following questions -
- What is a Management System?
- What is PDCA and what does it mean?
- Why is PDCA important?
- How can I determine if an OHSMS standard is based on PDCA or not?
This course is about 15 minutes long. Since it is a flash presentation located on a separate web page, you may need modify your browser settings to allow pop-ups in order to access the course. Also, in order to hear the audio, you will need speakers on your computer. When you are ready to begin, just click on the link below.
Click here to open – Plan-Do-Check-Act – An Introduction to PDCA
Have comments or questions about this course?
You can type your questions or comments into the comment box below (you may need to click on the more button if you are on the home page) or send me an e-mail at ecsi2008@ENLAR.c0m.
Did you enjoy this course?
Check out my Introduction to OHSAS 18001 Course.
This course provides insight into interpreting the OHSAS 18001:2007 requirements as well as expert guidance in implementing an OHSMS for purposes of third-party certification.
© ENLAR® Compliance Services, Inc. (2011)
Launching an OHSMS
Last Monday, I watched as Atlantis lifted off from the Kennedy Space Center. Living in Florida, I heard the sonic boom as it returned early Thursday morning. I watched on TV as it landed for the last time.
I am saddened by the end of shuttle program and the associated loss of jobs. Some of those impacted are fellow safety and health professionals. They are friends of mine who have participated in my training programs and helped me by providing references when I have asked.
As I watched the launch, I was struck by the discipline imposed by the formalized processes NASA uses to ensure safety. The launch was momentarily paused – with only 31 seconds to go – to double check that the GOX Vent Arm had properly retracted and latched. This was confirmed visually using a closed circuit camera while those watching the launch waited in suspense.
This is what an occupational health and safety management system is all about. It is putting processes in place, and using them, to ensure safety. Many organizations write procedures and checklists. World-class organizations use them – even when the whole world is watching.
Want help in launching your own management system? Click here to go the webpage where you can request your copy of ENLAR’s EHSMS Implementation Checklist.
As a special tribute to the NASA Shuttle Program, I am making it available for FREE for the next month.
© ENLAR® Compliance Services, Inc. (2011)
Irrational Decisions Impact OHSMS Implementation
Last May, I gave a presentation on auditing occupational health and safety management systems at the American Industrial Hygiene Conference (click here to access my blog post about that presentation). I was followed by a speaker who talked about behavioral considerations in implementing an OH&S management system. The focus of her presentation was on helping people make rational decisions about safety.
The problem is that individuals do NOT make rational decisions – particularly when it comes to safety and health.
- They refuse to wash their hands and come to work sick – even though these are the best strategies to prevent a potential epidemic.
- They talk and text on their cell phones while driving – even though it is as dangerous as drinking and driving.
- They wear their safety glasses on the top of their head rather than as protection for their eyes – as seen over and over again on HGTV shows. (I keep meaning to write a letter to HGTV pointing out the poor example they are setting for all of the DIYers in the audience.)
Why do people act irrationally?
My favorite book on this topic is Predictably Irrational (click on the link below to order from Amazon). In this book, Dan Ariely explores the reasons why individuals appear to act irrationally – this includes overvaluing our possessions, letting options distract us from our real objectives, and following established social norms in the workplace. As he puts it – “we consistently overpay, underestimate and procrastinate.”
Process NOT Perfection
I received the following question from a reader last week –
When it comes time for our company to be audited on the OHSAS 18001 system, our auditor usually says, “Your Company has not identified ALL the hazards at your facility.”
… I don’t believe that every potential hazard needs to be identified in order to be compliant. I always explain this to the auditor, and address what it states in 4.3.1:
“The organization shall establish, implement and maintain a procedure(s) for the ongoing hazard identification, risk assessment, and determination of necessary controls.”
… I don’t feel our auditor is correct in saying we are not compliant because we have not identified all potential hazards.
I really would appreciate your thoughts on this matter.
You are correct in your analysis of the requirement in Section 4.3.1 of OHSAS 18001. What is required – and what auditors should be looking for – is a process NOT perfection.
This is an important distinction and a fundamental principle underlying all of the ISO management system standards and OHSAS 18001. It is one of the 14 Points for Management that Deming emphasized in his 1982 book, Out of the Crisis
To illustrate the difference, consider how one goes about controlling a manufacturing line making widgets. There are 2 different approaches that can be used to ensure quality widgets – an inspection approach and a management system approach.
Identifying Legal and Other Requirements in an OHSMS
I received a follow-up e-mail from a reader asking for additional clarification about the requirements for identifying legal and other requirements in OHSAS 18001. Her organization has tasked her with updating their existing ISO 14001 matrix to include “OH&S requirements, aspects and categories”. She asked whether she was wasting her time given my response to a reader’s question I posted in a previous blog about identifying legal and other requirements.
There are similarities between the requirements in the ISO 14001 and OHSAS 18001 standards. Section 4.3.2 of OHSAS 18001 – like Section 4.3.2 in ISO 14001 – requires that an organization establish a procedure to identify its applicable legal and other requirements. (It is important to keep in mind that a procedure is defined as a specified way of doing some activity.)
The majority of companies use some sort of matrix – often a Word table or Excel spreadsheet – to document the results of their determination of which legal and other requirements are applicable to them. This is often called a Legal Register. This matrix or Legal Register provides the answer to the question – “What are the legal and other requirements we must comply with?” (Although creation of a Legal Register is a common practice, it is NOT required. What is required is that you follow whatever your procedure says you are going to do to identify your applicable legal and other requirements.)
Nature vs. Nuture in Safety
Nature vs. Nurture is an on-going debate in many discussions of individual action. Do we act the way we do because of our genes or our upbringing? Are we who we are as the result of our inherent nature or the behavior of those around us?
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 –
Identifying Applicable Legal Requirements
Last week, I received the following question from a reader about the OHSAS 18001 requirements related to the identification of applicable legal and other requirements –
We are an OHSAS 18001 certified company…. Our Hazard Identification and Risk assessment (HIRA) first page tells about the legal requirement clause and the legal statements for complying with the HIRA. Our external auditor (certifying body) insists we insert a column in the HIRA chart to identify what legal requirement clause comes against the control of each identified risk.
1. Is my auditor correct?
2. Does the OHSAS 18001 Standards say that?
My answer –
That is NOT an OHSAS 18001 requirement. I believe your external auditor is confusing the ISO 14001 and OHSAS 18001 requirements.
Section 4.3.2 of ISO 14001 requires that an organization determine how its applicable environmental legal and other requirements apply to its environmental aspects. This is often done as your external auditor suggests, although it does NOT have to be done that way. You can use whatever method is appropriate for your organization.
Section 4.3.2 of OHSAS 18001 does NOT have the same requirement as ISO 14001. It requires that an organization “take into account” its applicable legal other requirements in its OHSMS. No column, chart, matrix is required. Nor does it require identifying requirements by individual risk. This requirement was specifically rejected when OHSAS 18001 was revised in 2007.
© ENLAR® Compliance Services, Inc. (2011)
Safety Bingo – Buyer Beware
OHSAS 18001 requires that organizations establish procedures to encourage worker participation in the OHSMS. In some companies, worker participation is equated to establishing some sort of incentive program such as safety bingo. The premise of many of these programs is as follows –
As long as there aren’t any reported injuries, participants in the safety incentive program have an opportunity to win a case prize. However, if an injury is reported, the game stops and the cash prize is either eliminated or substantially reduced for everyone.
Supposedly, these incentive programs build safety awareness. Critics contend that they simply impact reporting of injuries without any underlying improvement in safety. In other words, they drive safety reporting underground. Interesting, based on the results of a poll conducted in June 2010 by SafetyNewsAlert, this is the view of over 60% of the safety professionals who responded.
In his keynote presentation at the AIHce earlier this month, the head of OSHA, Dr. Michaels, re-iterated OSHA’s strong disapproval of safety incentive programs that discourage injury reporting. He went on to point out that they are also potential violations of Section 11 of the Occupational Safety and Health Act. (Click here for a related article from National Safety Council Safety+Health Magazine)
What does this mean for organizations establishing procedures to meet the participation requirements of section 4.4.3 of OHSAS 18001?
Forget gimmicks. Put processes in place for real worker participation in the OHSMS.
© ENLAR® Compliance Services, Inc. (2011)
Auditing Integrated Management Systems – The Impact of ISO 19011
Last week at the American Industrial Hygiene Conference in Portland, I was one of the speakers on a roundtable panel tasked with discussing the topic Integrated Solutions in Sustainable Occupational Health and Safety Management Systems. My presentation was on Auditing Integrated Management Systems – The Impact of ISO 19011.
Other presenters talked about what the requirements are for a management system and how to establish a management system within an organization. I discussed management system auditing.
In particular, I outlined five ways that ISO 19011 impacts management system auditing –
ANSI Z10, OHSAS 18001 & Sustainability
This week, in addition to attending the AIHCE in Portland, I will be participating in a meeting of the ANSI Z10 Committee. We will be discussing the revision of Z10 that was undertaken last year and is scheduled to be completed later this year (Fall 2011).
ANSI Z10:2005 is the American National Standard for Occupational Health and Safety Management Systems. As such, it is part of a large family of standards addressing this topic. The dominate sibling in this family is, of course, OHSAS 18001:2007. According to the 2009 Standards and Certificates Survey conducted by the OSHAS Project Group, over 50,000 organizations have obtained certification to OHSAS 18001.
The goal of this revision of Z10 is to continue to provide guidance helpful to organizations in the United States that want to implement an OH&S management system. Another use of Z10 is as a reference document for OSHA’s initiative for development of a standard requiring that employers establish an Injury and Illness Prevention Program (I2P2 Initiative). Finally, there is a desire to ensure that Z10 continues to have relevance to OH&S in the future.
One of the interesting inputs impacting this revision of Z10 is the increasing focus on sustainability initiatives and corporate sustainability reporting. Many OH&S professionals have expressed concern about the lack of attention given to worker safety within the sustainability movement. One of the initiatives ASSE and AIHA are working on together is the development of appropriate metrics for measuring OH&S performance for the next revision of the GRI sustainability reporting guidelines.
© ENLAR® Compliance Services, Inc. (2011)
