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“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.
Ban the Blame
One of the key requirements of the OHSAS 18001 standard is establishing a procedure for taking corrective and preventive action (section 4.5.3.2). Both corrective and preventive action need to include identifying the underlying causes – often called root causes – of whatever it is that is or went wrong.
This is not easy. Often, the root cause investigation ends with a determination along the lines of “Joe screwed up.” We play the blame game.
Why?
OHSAS 18001 “Governing Body”
A reader recently posted the following question –
I am dealing with an organization that claims it is certified to OHSAS 18001… Does anyone know if there is an accreditation board or other governing body which administrates OHSAS 18001 who would be responsible for auditing conformance with these practices? Or does this system rely solely on internal audits only? (click here to read the entire comment)
There is no one OHSAS 18001 governing body or accreditation board.
As a voluntary international standard, OHSAS 18001 is utilized by organizations in several different ways.
“Timely” Incident Investigation
Section 4.5.3.1 of OHSAS 18001 requires that OH&S incident investigations “be performed in a timely manner”.
So – What is Timely?
Neither OHSAS 18002 nor the dictionary (my primary sources for interpreting the OHSAS 18001 requirements) provides much help.
OHSAS 18002 does not explicitly discuss this particular requirement of the OHSAS 18001 standard.
The dictionary isn’t particularly helpful either. It defines timely as – “well-timed, in time, occurring at a suitable time, opportunely“. The legal dictionary definition is “falling within a prescribed or reasonable time.”
Trust – but Verify
In previous posts, I discussed the relative importance of management system standards and company culture on OH&S performance. This discussion was based on the paper entitled The Limits of Management Based Regulation by Neil Gunningham and Darren Sinclair.
One of the conclusions set out in this paper is that the “accountability mechanisms” common to management system standards can have a negative impact on OH&S performance.
The authors suggest that many of the fundamental requirements of management system standards – establishing accountability, performance tracking and internal auditing – are “antithetical to measures that our findings suggested had a positive impact on OHS.” They go on to discuss social science research that finds that accountability mechanisms can decrease trust and, as a result, negatively impact performance.
What does this mean for OHSMS internal audit programs?
First, it is important to recognize that internal audit programs have a purpose. That purpose is best summed up by the phrase – “Trust – but Verify.” That is why OHSAS 18001 includes an internal audit program requirement.
Should I Write a Procedure?
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.
© ENLAR® Compliance Services, Inc. (2009)
Information Overload
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.
Use it wisely.
