July 12, 2007
As discussed in a previous Blog, one of the major drivers in the revision of OHSAS 18001 was alignment with ISO 14001:2004. When OHSAS 18001 was originally developed in 1999, it was drafted to be consistent with ISO 14001:1996 in language and structure. When ISO 14001 was revised in 2004, some of the alignment between the standards was lost.
OHSAS 18001:2007 has been aligned in overall structure and numbering with ISO 14001:2004. In addition, many of the core management system elements (document control, record control, internal audit and management review) are aligned in language as well.
A significant change in OHSAS 18001 that is based on alignment with ISO 14001:2004 is the addition of new requirements related to identification and evaluation of compliance with OH&S legal and other requirements (Sections 4.3.2 and 4.5.2). Section 4.3.2 now requires that organizations ensure that applicable legal and other requirements are taken into account in establishing, implementing and maintaining their OH&S management systems. Section 4.5.2, Evaluation of Compliance, is new. As in ISO 14001, organizations will need to establish a procedure to periodically evaluate their compliance with applicable OH&S legal and other requirements. This new requirement is more expansive than the requirement in the 1999 standard that organizations provide proactive measures of performance to monitor applicable legislation and regulatory requirements.
Not all of the language in OHSAS 18001 is aligned with ISO 14001:2004. There are four areas where there are significant differences between the two standards:
- Identification and evaluation of OH&S hazards and risks (as opposed to the aspect/impact analysis provisions of ISO 14001)
- Requirements related to worker participation and consultation with other parties such as contractors
- Selection and implementation of operational controls
- Specific requirements for incident investigation
© ENLAR® Compliance Services, Inc. (2007)
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July 11, 2007
In a previous blog, I noted that five significant changes were made in the 2007 revision of OHSAS 18001.
One of these changes is in the intended coverage of OHSAS 18001. As noted in the Scope section of the revised standard, OHSAS 18001 is “intended to address occupational health and safety, and is not intended to address other health and safety issues such as employee wellbeing/wellness programmes, product safety, property damage or environmental impacts.”
Several changes were made to the standard to clarify the intended scope of coverage - most notably in the revision and/or addition of several key definitions.
First, the definition of hazard no longer includes “damage to property or damage to the workplace environment.” It was concluded that these types of damage are part of the field of asset management - not part of occupational safety and health. For purposes of OHSAS 18001, hazards are limited to sources, situations or acts with the potential for harm in terms of human injury or ill health. The focus is on harm to humans not property.
New definitions were added to the standard for “ill health” and “workplace.” Neither of these terms were defined in the 1999 standard. Ill health is defined as “identifiable, adverse physical or mental condition arising from and/or made worse by a work activity or work-related situation.” The addition of this definition reflects an increased emphasis on health within OHSAS 18001. Workplace is defined as “any physical location in which work-related activities are performed under the control of the organization.” This definition is consistent with changes made throughout the standard that tie the OH&S responsibilities of the organization to areas and persons “under its control.”
Occupational health and safety (OH&S) is defined in OHSAS 18001 as “conditions and factors that affect, or could affect, the health and safety of employees, temporary workers, contractor personnel, visitors or any other person in the workplace.” A note has been added to this definition that states “organizations may have a legal requirement for the health and safety of persons beyond the immediate workplace or who are exposed to workplace activities.” Organizations may need to take such legal obligations into account in developing their OH&S management system.
Organizations seeking certification to OHSAS 18001:2007 need to determine and document the scope their OH&S management systems (a new requirement in section 4.1 of the standard). This will mean careful consideration of exactly which workplaces and what individuals are covered. For some organizations, this may mean more attention to issues such as the visitor safety and evaluation of hazards to workers working at off-site locations (e.g. transit drivers).
© ENLAR® Compliance Services, Inc. (2007)
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June 29, 2007
In yesterday’s blog I discussed eliminating business silos - including those that isolate OH&S from the rest of the organization. One of the key ways identified to destroy silos is to facilitate collaboration.
Therefore, my interest was peaked by an article I read today in the June 25, 2007, issue of InformationWeek entitled Beyond E-Mail.
http://www.informationweek.com/story/showArticle.jhtml?articleID=200000229
This article discusses Procter & Gamble’s efforts to improve employee collaboration.
What did the CEO of Proctor & Gamble describe as the biggest barrier to collaboration?
E-mail.
Why?
The sender of an e-mail controls the agenda.
What is P&G promoting to replace e-mail?
Blogs.
OH&S Professionals take note. Blogging is likely to be in our future.
© ENLAR® Compliance Services, Inc. (2007)
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June 28, 2007
On Tuesday, I walked through the exhibits at the ASSE (American Society of Safety Engineers) Safety 2007 conference. I saw a number of really neat products and came away with new ideas and information that I know I will use. I also can away thinking about “silos.” Not the kind used for storing grain but the kind that exists in many business organizations.
According to an article by Carl Kinsey Groman entitled Tearing Down Business Silos, a survey by the American Management Association showed that 83 percent of executives said that silos existed in their companies and that 97 percent think they have a negative effect (http://www.sideroad.com/Management/business-silos.html). As discussed in this article, when business silos exist, the organization often disintegrates into isolated camps with each department focused on its own individual agenda - often without considering the needs and goals of the rest of the organization.
So why did walking through the exhibits remind me of business silos?
Several of the exhibitors were promoting “safety-only” training and information management solutions. Although these solutions may be great for helping the safety professional do his or her job better, it is not clear that they would improve the integration of safety into the overall organzation.
As executives continue to focus on breaking down the silos within their organizations (”unsiloing”), OH&S professionals will need to find ways to facilitate collaboration with other departments, share resources and improve the alignment of business processes such as training and document management. Increasingly, occupational safety and health will need to be an integral part of the organization — this is where implementing an OH&S management system can help.
© ENLAR® Compliance Services, Inc. (2007)
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June 25, 2007
A revision of OHSAS 18001, Occupational health and safety management system - Requirements, is scheduled to be published in early July 2007.
When OHSAS 18001 was initially drafted in 1999, it was specifically written to be consistent with ISO 14001:1996, the environmental management system standard developed by the International Organization for Standardization (ISO). When ISO 14001 was revised in 2004, some of the alignment between the standards was lost.
In 2005, the OHSAS Working Group decided to revise the OHSAS 18001 standard to again align it with ISO 14001 and to improve it based on the experience of the standard’s users since it was first published in 1999.
This revision is the culmination of over a year of work. An initial draft of the revised OHSAS 18001 standard was circulated in February 2006 for public comment. Approximately 500 comments from 36 commentators were recieved and reviewed in an initial meeting of the OHSAS Working Group in Madrid, Spain in October 2006. Because a number of significant changes were being proposed, a second draft of the revised standard was circulated for comment in November of 2006. Again, many groups and individuals provided comments (approximately 540 comments from 46 commentators in 24 countries). These comments were reviewed during a second meeting of the OHSAS Working Group in Shanghai, China in March 2007 and a final draft was agreed upon. As a participant in these meetings, I can attest that they were exhausting!
In addition to alignment with ISO 14001, another major factor taken into consideration during the revision process was alignment with other occupational safety and health management system standards such as the ILO and the ANSI/AIHA Z10 standards.
Based on these inputs, a number of significant changes have been made to the OHSAS 18001:
- Improved alignment with ISO 14001:2004
- Changes in the areas covered by the standard
- New requirements related to hazard identification, risk assessment and the selection of controls
- New requirements for external consultation and worker participation
- Clarification of the role of incident investigation
These changes will be discussed in more detail in future blogs.
© ENLAR Compliance Services (2007)
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May 17, 2007
In 1999, the American National Standards Institute (ANSI) initiated a standard-setting activity to establish a United States occupational health and safety management system (OHSMS) standard. This activity was concluded in 2005 with the publication of ANSI/AIHA Z10 Occupational Health and Safety Management Systems.
A number of stakeholders participated in this standard-setting process including representatives from the U.S. Occupational Safety and Health Association (OSHA), organized labor, industry and OH&S professional associations. In all, over 40 organizations had representatives on the committee.
ANSI/AIHA Z10 was developed to be compatible with other management systems such as ISO 9001 and ISO 14001 and is based on the management system concept of Plan-Do-Check-Act. As stated in the introduction to the standard, the purpose of the standard is “to provide organizations an effective tool for continual improvement of their occupational health and safety performance.”
This standard is formatted differently then an ISO standard. It is structured into two columns. The requirements (“shall” clauses) are set out in the left column; recommendations & explanations (“should” clauses) are set out in the right column.
A copy of the standard can be obtained from the American Industrial Hygiene Association at http://iweb.aiha.org/iweb/Purchase/ProductDetail.aspx?Product_code=SMAA05-698
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May 15, 2007
The Random House Unabridged Dictionary defines “plethora” as an “overabundance or excess.” That certainly describes the situation when it comes to OH&S standards, particularly OH&S management system standards.
There are international OH&S standards, there are national OH&S standards and there are state and local OH&S standards. In addition, there are standards developed by individual organizations and government agencies and there are “standards” developed and promoted by individuals who believe they have “a better idea” when it comes to safety management.
Nor is there any lack of OH&S management system standards. In their 2005 survey of OH&S management system standard usage, the OHSAS 18001 Working Group identified over 40 different OH&S management system standards that were in use in various places around the world.
For the following reasons, coming up with a definitive list of OH&S management system standards is nearly an impossible task:
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Individuals differ in their view on the criteria that establishes a document as a “standard.” For example, some individuals view OHSAS 18001 as a standard; others vehemently argue that it is not because it was developed by an independent group.
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There is disagreement on what is included – or is not included — within the scope of occupational safety and health and therefore what qualifies as an OH&S standard as opposed to an environmental standard, a general safety standard or a property protection standard. For example, what are fire prevention standards?
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Finally, even if there is agreement on the first two points, there can be disagreement on whether a particular document states requirements for a “management system.” Does a standard contain manditory “shall” clauses or does it simply provide “good advice” that you can accept — or simply ignore. Does it matter?
Some of the OH&S management system standards currently available include the following:
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OHSAS 18001:1999 — developed by an independent group of national standards organizations and certification bodies.
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ANSI/AIHA Z10:2005 — U.S. national standard
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CSA Z1000-06 — Canadian national standard
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AS/NZS 4801:2001 — Australia / New Zealand national standard
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ILO-OSH 2001 – standard developed by the International Labor Organization
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May 9, 2007
Using a different approach, one can seek to determine what a management system is by examining the definitions penned by the individuals who drafted the ISO management system standards.
The ISO Definition of a “Management System”
ANSI/ISO/ASQ ISO Q9000-2000 defines a “management system” as follows – a system (separately defined as a set of interrelated or interacting elements) to establish policy and objectives and to achieve those objectives. A “quality management system” is then defined as a management system to direct and control an organization with regard to quality.
ISO 14001:2004 defines a “management system” as a set of interrelated elements used to establish policy and objectives and to achieve those objectives and an “environmental management system” as follows – part of an organization’s management system used to develop and implement its environmental policy and manage its environmental aspects.
What is interesting about these ISO definitions is their explicit focus on defining a management system in terms of the task of “establishing policy and objectives” (ISO 9000) or “developing and implementing a policy” (ISO 14001). This focus on establishing and implementing policy is not part of any of the dictionary definitions for management.
The OHSAS 18001 Definition
OHSAS 18001:1999 defines an “OH&S management system” as follows – part of the overall management system that facilitates the management of the OH&S risks associated with the business of the organization. With the 2007 revision of OHSAS 18001, the definition of an OH&S management system will be aligned with the ISO 9001 and ISO 14001 definitions to focus on developing and implementing policy.
Is the primary purpose of a management system to develop and implement policy? What do you think?
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May 8, 2007
Since OHSAS 18001 is intended to set a framework for an OH&S management system – like ISO 14001 sets a framework for an environmental management system and ISO 9001 sets a framework for a quality management system – it is probably worthwhile to explore just what a “management system” is.
To enjoy standard-setting is to enjoy defining terms.
There are a variety of ways you can go about deciding what something is. You can ask an expert, you can ask several experts, you can take an opinion survey or you can look it up in a dictionary. Part 1 of this series takes the approach of looking it up in the dictionary (or more accurately — a dictionary of dictionaries — www.dictionary.com).
A Dictionary Definition
If one approaches this as a tautological exercise, one can break the term “management system” into its component parts of “management” and “system,” define each and then combine the two definitions back together again into a single definition for a “management system.”
Using this approach, one can define the word “management” as the act or manner of managing; handling, direction, or control and the word “system” as a group of interacting, interrelated, or interdependent elements forming a complex whole. Combining these definitions, one gets the following definition for a “management system” – the act of managing a group of interacting, interrelated or interdependent elements forming a complex whole. This is a traditional, and predictable, definition.
On the other hand, by combining a different set of definitions for “management” and “system”, one can get the following, entirely different, definition – a social, economic or political organizational form used by corporate power elites who are distinguished primarily by their distance from actual productive work and their chronic failure to manage. For those who appreciate Dilbert cartoons, this may represent a more “real world” definition of a “management system.”
Given the variety of choices set out at www.dictionary.com, which dictionary definition do you prefer?
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May 7, 2007
OHSAS 18001 is a specification document (standard) that sets out requirements for establishing and implementing an occupational health and safety management system.
It was originally developed in 1999 by an independent group of national standards organizations and certification bodies. Although it is not an ISO standard, OHSAS 18001 is structured the same way as ISO 14001, the environmental management system standard, and has essentially the same elements. It was developed specifically for use in third-party certification.
OHSAS 18001 was developed to replace a number of registrar-specific OH&S specification documents and to serve as a model for developing an international standard. Its development was initially driven by the lack of consensus for moving ahead in developing an international standard through the ISO standard-setting process.
More information about OHSAS 18001 can be found on ENLAR’s web site at http://www.enlar.com/ohsas18001.html#OHSAS18001.
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