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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 an OH&S program.
© ENLAR® Compliance Services, Inc. (2009)
In a previous blog, I discussed the difference between competency and awareness in an occupational health and safety management system (OHSMS). In that blog, I used the ISO 9000:2000 definition of competence as “demonstrated ability to apply knowledge and skills” since OHSAS 18001:2007 does not include a definition.
It seems that the appropriate definition of competence is now subject of some debate within ISO and may be subject to being “re-defined.”
Competency is a significant component of at least four standards currently under development within ISO –
- ISO 10018 – Quality management: Guidelines on people involvement and competencies
- ISO 14066 – Greenhouse Gases – Competency requirements for greenhouse gas validators and verifiers
- ISO 17021 Part B – Conformity assessment – Requirements for third-party certification auditing of management systems
- ISO 19011 (revision) – Guidelines for management system auditing
Interestingly, each of these standards has apparently rejected the dictionary definition, as well as the ISO 9000 definition, and each ISO Technical Committee appears to be in the process of developing its own concept of competence.
ISO 10018 is apparently focusing on how “human factors” impact the effective functioning of management systems with the definition of competency being passed to a subcommittee. ISO 14066 is structured to set out detailed lists of the skills and knowledge that must be possessed by GHG verification and validation teams – with the focus on team rather than individual competency. The initial committee draft of ISO 17021 defined competence as “personal attributes and ability to apply knowledge and skills” with a heavy focus on personal attributes and generic audit skills but essentially no guidance as to the needed discipline-specific knowledge (e.g. quality, environmental, OH&S). The revision of ISO 19011 has just begun; however, the issue of auditor competency has already been identified as one of the “hot-button issues” associated with revision of this standard.
A review of the various standards and other reference materials appear to set out three different, and distinct, attributes that underlie competency:
- Attitude and personality traits –who you are
- Knowledge – what you know
- Skills – what you can do
Where the ISO standards seem to diverge is in the relative importance to be given to each attribute (personality vs. knowledge vs. skill) as well as in the specifics of what is actually required and how it should be demonstrated.
What do you think? What is competency?
© ENLAR® Compliance Services, Inc. (2008)