Recent Posts
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.
© ENLAR® Compliance Services, Inc. (2009)
Is a “Model” Safety Program the Right Goal?
There seems to be a “disconnect” between current economic realities and the metrics often suggested for evaluating OH&S programs and management systems.
Many organizations are facing a level of financial hardship not seen since the Great Depression. As a result, cutbacks, downsizing and belt-tightening are the new normal. “Do more with less” has become the mantra of business. This translates – for many EHS professionals – into being asked to get by with fewer people and no new resources.
On the other hand, many organizations seem unwilling to match their OH&S goals and expectations to the reality of fewer resources. Managers still insist on setting “continual improvement” metrics based on achieving “best-in-class” management system performance. This is often expressed in the form of a performance rating scheme based on some sort of numeric scoring of the “performance” achieved by particular S&H programs or management system elements (typically on a 1 to 4 or 1 to 5 scale). Examples of this abound. There is one set out in an article I just finished on SH&E Strategic Planning in the October 2009 Professional Safety Magazine.
Implicit in many of these of rating schemes is the assumption that there is “unused capacity” that can be utilized to achieve the performance improvement desired.
Get real.
The Alarm Just Went Off…Now What?
There seems to be a renewed interest in metrics, measuring and monitoring within OH&S management systems. Given the advances in continuous monitoring technology, this interest often translates into the installation of a host of different monitoring devices with alarms – fire detection alarms, security alarms, gas detection alarms, motion sensor alarms, electrical current alarms, high level alarms, low level alarms, entry alarms, exit alarms, etc.
One of the challenges associated with all of these alarms – “What are you supposed to do when the alarm goes off?”
Since my husband is at the top of the call list when an alarm goes off at his facility, I am only too familiar with this question – particularly since the “alarm alert” often occurs in the wee hours of the morning (as it did this morning). I can tell you attempting to answer the “now what?” question at 4 am is no fun.
Creating OHSMS Documentation
A reader recently asked –
Why is that OH&S management system manuals so often repeat the language of the OHSAS 18001 standard – isn’t that redundant?
Yes and No.
Challenges & Opportunities in Developing OHSMS Standards
This week I had the opportunity to attend and give a presentation at the NIOSH NORA Health Care and Social Assistance Sector Council Meeting in Washington DC. It was the first NIOSH NORA meeting I have attended and I found the discussion both very enlightening and somewhat scary.
At this meeting I gave a presentation – Challenges & Opportunities in Developing OHSMS Standards – that outlined five common barriers to implementing Occupational Health and Safety Management Systems. Also giving presentations on this topic were Mike Seymour from OSHA and Barbara Braun from The Joint Commission. Mike Seymour discussed the OHSMS guidance document that OSHA is currently in the process of developing and Barbara Braun discussed how the Joint Commission standards also include worker safety requirements. As several of the attendees pointed out, there is a clear and obvious link between patient safety and worker safety.
The purpose of these presentations was to assist the HCSA Sector Council in developing implementation plans for the new National Occupational Research Agenda for this sector (currently out for public comment until the end of October 2009). A key strategic goal in this agenda is promoting the use of OH&S management systems and improving safety culture in healthcare organizations.
The scary part of the meeting…
The critical issues that need to be addressed to protect health care workers – particularly as it relates to the H1N1 pandemic. There was a great deal of discussion concerning the precautions that need to be taken related to providing proper respiratory protection - NOT JUST SURGICAL MASKS – and the current lack of hospital preparedness. The importance of this topic was emphasized by the advisory issued by the Institute of Medicine yesterday that urges health care workers to use N95 respirators instead of surgical masks for protection.
© ENLAR® Compliance Services, Inc. (2009)
