Recent Posts
Control of Documented Information
In a previous blog, I discussed the new High Level Structure and identical text requirements that has been proposed for all ISO management system standards. One of the proposed changes is to eliminate the document control and record control elements and replace them with a new provision requiring control of “documented information”. Documented information is somewhat vaguely defined in this new scheme as “the information required to be controlled and maintained by an organization”.
Although this may be seen as progressive by those who developed this new management system structure, it is likely to create confusion on the part of users of the standards who are not information management experts.
There are important reasons for distinguishing between the documents that need to be controlled in a management system and record retention requirements. Even though both document control and record control are control of documented information, their purpose and use is very different.
I2P2 & Employee Engagement
Last week I gave a presentation to an industry group on OSHA’s proposed Injury and Illness Prevention Program (I2P2) rule. In my presentation, I focused on the requirements for worker participation within an OHSMS.
One of the questions OSHA raised in its original I2P2 proposal was –
What mechanisms have been found to be effective for enabling employees to participate in safety and health in the workplace?
Worker participation is one of the areas where there are significant differences between OHSAS 18001 and both ANSI Z10 and OSHA VPP.
OSHA VPP and ANSI Z10 focus on employee participation, as defined by the technicality of labor law. OHSAS 18001 focuses instead on worker participation, as defined by the extent of the organization’s control over the work being performed.
High Level Structure for MS Standards
An initiative has been underway within ISO that is likely to have a significant long-term impact on all management systems within an organization – including occupational health and safety management systems.
This is the development of a document that sets out a common High Level Structure and core definitions to be used in all ISO management system standards. This document was developed by an ISO Joint Technical Coordination Group (JTCG) tasked by the ISO Technical Management Board (TMB). It was published as JTCG N44 in December 2010.
Ownership of an OHSMS
I received the following question about the OHSAS 18001 requirements from a reader –
Would you kindly let me know which department should take ownership/responsibility in a manufacturing unit for OHSAS activities implementation, like Lock out –Tag out and etc.
- Health and Safety Dept.
- Maintenance Dept.
- Admin Dept.
- Others?
This is the answer I provided –
Safety Matters?
A blog on the website The Hill caught my eye this morning. It is entitled “More than 70 percent of Congressional offices violate OSHA worker safety standards.” This is an alarming finding.
What was even more disturbing is that the blog went on to say that this result – 70% of office areas in violation of OSHA standards – was seen as an improvement because the number of violations found during previous inspections was even higher.
Wow!
Having piqued my interest, I headed over to the website for the Office of Compliance to take a look at the report myself.
What I found was the Biennial Report on Occupational Safety and Health Inspections dated June 2009.
There are some interesting things in this report –
Olympic Death – Lessons for an OHSMS
The death of Georgian luger Nodar Kumaritashvili at the beginning the 2010 Olympic Games was tragic.
Even though most workplaces are clearly not the same as an Olympic sports facility, there are “lessons to be learned” from this tragedy for occupational health and safety professionals.
- Arguing whether the individual hurt was at fault is not productive. As the Georgian President Mikheil Saakashvili stated – “…no sports mistake is supposed to lead to a death.” When individuals die as a result of workplace incidents, the sentiment is the same. Blaming the worker is just as counterproductive as blaming an athlete.
- Consideration of ”human factors” is both critical to preventing injury and more difficult and complex than it initially seems.
What are those complexities?
“HELP – I’m out of RAM”
OHSAS 18001 requires that your organization’s procedure for hazard identification and risk assessment take into account “human behavior, capabilities and other human factors”.
Many organizations partially address this requirement by establishing an ergonomics program in order to address physical human factors. Only a few organizations explicitly address mental human factors as a part of their hazard identification and risk assessment.
Yet, mental human factors are very real and can be just as important as physical human factors. In some cases, they are even more important.
Strategy vs. Implementation – Which is Important?
I have been working for over a year with a project team developing a strategy for improving a management system process that is of great importance to that organization. It was a major effort that culminated in a presentation to the executive management team.
They loved it.
That should be great – right?
Well… The problem with an “approved strategy” is that now someone has to implement it.
Lessons from Haiti
The on-going crisis in Haiti is a stark reminder of the importance of disaster preparedness. Both OHSAS 18001 and ISO 14001 require that an organization establish, implement and maintain procedures to ”identify the potential for emergency situations” in order to be ready and prepared to respond to these situations when they arise (section 4.4.7).
I have been working for several years with the Tampa Bay Regional Planning Council to help local businesses prepare for disasters. In our area, the Florida west coast, the disaster we fear is a major hurricane. As part of these efforts, we developed and presented a series of interactive workshops covering emergency planning, risk assessment and disaster preparedness.
If you want to be prepared, the following points are key -
Out with the Old – In with the New
The start of the New Year is good time to pause, reflect and clean out.
Many organizations use the start of the year as a time to review their OH&S management system objectives and set new ones. If their OH&S programs are lagging in their implementation, new approaches or new assignments are considered.
This is also a good time to address all that PAPER – either physical paper or electronic paper. This includes all those completed hazard evaluation forms, inspection checklists, excel spreadsheets, meeting notices and minutes, e-mails with various interested parties, incident investigations, corrective action reports,….
When I help develop record control processes and procedures for an organization, one of the concepts I try to incorporate is the inclusion of record schedules with record breaks and scheduled clean-out days.
