July 31, 2009
What do the National Mall, my homeowner’s association and your OH&S management system have in common?
The need to pay for preventive maintenance.
When we moved to Florida, we purposely choose to live in a neighborhood that did NOT have a golf course, community center or jointly owned “common areas.” Instead, we choose a neighborhood that had a voluntary homeowners association – not a mandatory one. A couple of years ago, a few neighbors wanted to “beautify” the neighborhood by putting up signs and installing landscaping. They did so. Then, because the plantings they put in were dying and you could not see the new signs at night, they wanted to add irrigation and lighting. They did so. Needless to say, once they realized that these things were costing money, there was an attempt to impose mandatory fees to pay for the on-going expense. It didn’t happen. These neighbors became upset when the rest of the neighborhood was not interested in paying for their neighborhood beautification efforts.
According to last Friday’s paper, the National Mall is slipping into a state of neglect. Apparently, ducks died last year of avian botulism because the water in a mall pool was so foul, the Jefferson Memorial is sinking into the mud and the soil is so compacted in places that grass can’t grow. Yet, Congress has refused to provide funding to pay for the necessary upkeep.
What do these stories have in common?
The failure to recognize that – “If you build it, you’ve got to maintain it.”
This is an important warning to keep in mind as you develop your OH&S management system.
Whatever systems you put in place must be maintained –
- Documents need to be reviewed and revised
- Software needs to be maintained and updated
- Controls need to be inspected and maintained
All of this costs money.
Make sure you consider the long-term preventive maintenance costs before you put systems, software and controls in place. If you can’t maintain them, you may only make things worse.
© ENLAR® Compliance Services, Inc. (2009)
Posted in OHSMS Implementation 
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July 22, 2009
Bottom line – an effective occupational health and safety management system costs money.
There are those that argue that safety – like quality – is free (in line with the classic book by Philip Crosby – Quality is Free). The premise being that, in the long run, effective safety programs save money and add business value. Unfortunately, this premise is difficult to prove. This argument strikes me as similar to the “free market” argument that financial markets don’t need to be regulated because they will regulate themselves. Perhaps that is true in textbooks, but rarely – if ever – in practice.
OHSAS 18001 specifically requires that top management determine the need for and ensure the availability of the resources essential to maintain the established OH&S management system and prevent workplace injuries and ill health (Section 4.4.1 of OHSAS 18002). Read the rest of this entry »
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July 16, 2009
I have been following with interest the nomination hearings of Sonia Sotomayor. I find the focus on substance (i.e. what she believes) as opposed to process (i.e. how decisions are reached) fascinating.
When we were at Disney earlier this month, we visited the re-opening of the Hall of Presidents featuring Obama as the newest President of the United States. As I sat through the presentation, I contemplated which of the Presidents has had, or will have, the greatest impact on American life.
Interestingly, one of Presidents with a direct and on-going impact is William Howard Taft. Not because of what he accomplished as President but because of what he did after serving as President. Taft is the only President to go on to serve as Chief Justice of the Supreme Court. He considered this the highest point of his career. While at the Supreme Court, he was instrumental in establishing the processes for how legal cases are handled – processes that are still in place today.
In many legal cases, process determines outcome. This can occur in a variety of ways. Process can determine whether a matter is heard in the first place. Process may make a case too expensive to litigate – or continue litigating. Process may prevent any further appeal of an unfavorable lower court decision. In all of these circumstances, process can be more important than substance.
The same thing can occur in occupational health and safety management systems. The processes you put in place will have a direct impact on your ability to prevent injury and ill health. If your work instructions do not include safety precautions, safe work practices will not be used. If your safety SOPs are complex and unwieldy, they will be ignored. If employees are criticized for using safe work practices because it impacts production, employees will be less likely to work safely next time. In all of these cases, “processes” can have direct health and safety consequences.
Remember, to have good outcomes you need good processes.
© ENLAR® Compliance Services, Inc. (2009)
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July 7, 2009
I spent the 4th of July at Disney. It was the first time I have been to Disney in several years. The fireworks display was truly impressive. After the fireworks were over, we made our way back to our hotel using Disney’s transit system. I was once again struck by Disney’s ability to efficiently manage large crowds of people.
Disney Fireworks
Unfortunately, early Sunday morning tragedy struck Disney’s transit system when two monorail trains collided – killing one of the train operators. According to news reports, the Occupational Safety and Health Administration (OSHA) is currently conducting an investigation into this accident.
I was contemplating this accident – and the resulting negative publicity for Disney – as I reviewed the latest draft of ISO 31000 – ISO’s newly developed Risk Management standard.
One of the weaknesses of many risk management programs is failing to fully evaluate the risks associated with events that are rare (low likelihood) but with the potential for severe (highly negative) consequences. In Section 5.5.2, ISO 31000 suggests that such events may warrant risk treatment even when it appears that action may not be justifiable on strictly economic grounds. The typical assumption being that the event will never happen; therefore, the time and money expended to evaluate and address the risk will be wasted.
This monorail accident appears to be this type of an event.
It was clearly rare. According to Disney, this is the first fatal crash in the 38-year history of the monorail’s operation.
Yet, the consequences of this accident are likely to be severe –
- death of an employee
- reduced confidence in – and utilization of – the transit system by guests
- the costs incurred associated with an OSHA fatality investigation – even if no fines are imposed
- negative publicity for a company that is very concerned about maintaining a positive public image
Take ISO 31000’s advice to heart in your own risk management programs – including the risk assessments conducted to meet the requirements of OHSAS 18001. Be sure that your low likelihood risks are evaluated - including those associated with abnormal or unusual activities. As the accident at Disney proved, just because an event hasn’t happened yet, that doesn’t mean it may not happen tomorrow.
© ENLAR® Compliance Services, Inc. (2009)
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July 1, 2009
I was recently asked to review the safety issues related to a particular task that necessitated the handling of a flammable liquid. This is not the first such operation I have reviewed. In fact, the proper handling of flammable liquids is a topic that has come up over and over again during my career as a occupational health and safety professional. In conjunction with this evaluation, I reviewed the safety training currently being used for training the operators who perform this task.
In this case, like many, many others, the training being provided was an on-line generic training video developed by an outside safety training company that had been turned into “web-based” training. What struck me in reviewing this training was the complete and total disconnect between the operation being performed at the facility and the safety training being provided to the employees performing the work.
They had almost nothing in common.
For example -
- The facility using the flammable liquid was a clean room / laboratory operation; the training film was set in a “heavy industry” machine shop.
- The task involved handling of relatively small quantities of flammable liquids in glass beakers; the training video showed the handling of large quantities of flammable liquids in 55-gallon drums.
- No bonding and grounding is used during dispensing operations; the training video emphasized the importance of bonding and grounding.
- Employees used little PPE; the training video showed employees using respirators and face shields for protection.
Because I am currently in the process of developing several e-learning programs, I have been reviewing information on instructional design as it relates to creating web-based training programs. One of the experts in this area is M. David Merrill, a professor of instructional technology at Utah State University. One of the points he emphasizes is – simply providing information is NOT instruction. Instead, when developing training, he suggests that you start by developing a task-centered instructional design strategy.
Start with one of the tasks being performed and build training that is appropriate to performing that task. Eliminate information that is irrelevant or misleading. Focus on what is important and useful to the specific task. Apply the information to case study situations that are consistent with the content being taught. Ask students to apply the knowledge being taught to a scenario that is similar to their real-world experience. Build your training by repeating each of these steps for any other relevant tasks.
Want more information?
Go to M. David Merrill’s web site and download his paper that discusses using the use of these principles in developing an on-line first aid course in Australia. It is really cool.
© ENLAR® Compliance Services, Inc. (2009)
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June 23, 2009
The effectiveness of occupational health and safety programs is in the news.
On June 18, 2009, OSHA issued a press release announcing that it will conduct a comprehensive evaluation of its Voluntary Protection Programs (VPP) and Alliance programs to determine their effectiveness. This is OSHA’s response to a new GAO report that identified problems with OSHA’s VPP program and recommended improved oversight and additional controls.
So, how does one go about determining the effectiveness of an OHS program – or a management system?
This is not just a philosophical question.
An important requirement of OHSAS 18001:2007 is that top management review the “continuing suitability, adequacy and effectiveness” of the organization’s OH&S management system (Section 4.6 Management Review).
The meaning of this phrase was the topic of an extended discussion during the drafting meetings for OHSAS 18002:2008 (the guidance document for OHSAS 18001). The following conclusion was reached and added to Section 4.6 of OHSAS 18002:
Management Review should focus on the overall performance of the OH&S management system with regard to:
- suitability - ”Is the system appropriate to the organization, dependent on its size, the nature of its risks, etc.?”
- adequacy – “Does the system fully address the organization’s OH&S policy and objectives?”
- effectiveness- “Is it accomplishing the desired results?”
The OHSAS 18002 guidance is consistent with the dictionary definition of “effective” – “adequate to accomplish a purpose; producing the intended or expected result.”
Therefore, if one wants to determine whether a program is effective (as opposed to whether it is suitable or adequate) one needs to evaluate whether the desired results are being accomplished. It is not sufficient to focus simply on whether there are programs (i.e. “paperwork”) in place. Unfortunately, the focus of many management system reviews is on adequacy – have all the checklist boxes been checked – rather than effectiveness.
Effectiveness review is more difficult than adequacy review. In order to conduct an effectiveness review, you must answer the following questions –
- “What exactly are the specific results we are trying to achieve?”
- “How will we know whether or not we have achieved them (i.e. are the desired results measurable)?”
- “If the desired results are not easily or reliably measured, are there other metrics that need to be routinely monitored instead?”
An important caveat – for purposes of OH&S programs, the determination of effectiveness should not be limited to “counting dead bodies.” Particularly when it comes to occupational diseases, it is inappropriate to count the number of sick and/or dying employees to measure the effectiveness of our OH&S program.
© ENLAR® Compliance Services, Inc. (2009)
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April 2, 2009
Apparently the Automotive Industry Action Group (AIAG) issued a position statement in March 2009 stating that although they support the integration of health and safety programs into existing management systems, they will not “specifically mandate OHSAS 18001 certification.” A recent blog post asked “Is it politics once again?”
According to the AIAG statement they firmly believe that “the use of formal management systems are necessary for effective management of health safety and environmental programs.”
AIAG’s concern appears to be that the OHSAS 18001 standard was developed by an independent group – the OHSAS Project Group chaired by BSI – rather than ISO.
This is where the “politics” comes in. Despite intensive lobbying by the OHSAS Project Group, ISO appears unwilling to develop an OHS management system standard.
Why?
The International Labor Organization (ILO) has raised objections and several member countries – including the U.S. – have consistently voted against it. An OHSMS standard seems to be the exception to the rule that any proposed ISO standard-setting activity is guaranteed to be approved.
© ENLAR® Compliance Services, Inc. (2009)
Posted in OHSAS 18001:2007 Revisions, Standards & Certification 0 Comments » Trackback This Post
March 23, 2009
I recently had the following question e-mailed to me – “What is the “Hierarchy of Controls” [referenced in section 4.3.1 of OHSAS 18001:2007] and how do I address it in the hazard control & risk assessment procedure?”
The “hierarchy of controls” is a protocol that you use when deciding what kind of control measures you are going to use to address a particular OH&S hazard. The rationale underlying the “hierarchy of controls” is that an organization should use more reliable control measures rather than measures that are more likely to fail.
Read the rest of this entry »
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March 11, 2009
I am pleased to announce that ENLAR has launched a new blog – www.managementsystemexpert.com.
The purpose of this blog is to provide real-world practical advice to assist you in establishing, documenting, implementing and maintaining an integrated management system.
This website provides information and resources to help you understand the requirements of the various management system standards - ISO 9001, ISO 14001, OHSAS 18001, etc. In addition, it provides an opportunity for you to post your questions and comments on a variety of management system topics.
An integral part of this blog is the monthly FREE teleseminar that ENLAR will be hosting. These monthly ”conversations with experts” will provide a unique opportunity for you to BOTH listen to experts on a variety of management system topics AND ask questions for them to answer in their calls.
Click here to check out this new blog. While you are there, check out the upcoming teleseminars on -
- Revision of ISO 19011 – The Challenge of Drafting a Generic Auditing Standard
- Five Steps for Achieving Employee Engagement
Thanks! I hope you like this new site.
© ENLAR® Compliance Services, Inc. (2009)
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March 5, 2009
One of the requirements of OHSAS 18001 is to identify all of your workplace hazards, including those that may cause “ill health”. This includes illnesses that are made worse by a work activity. This analysis also needs to be extended to individuals beyond the borders of the traditional workplace.
ABC News reported on just such a situation last night. It included a segment on the health implications of driving a school bus and the steps Broward County, Florida has taken to address them.
What did the Broward County School Board do? Read the rest of this entry »
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