Tag: Management Review
It is common for the clauses of the management system standards – including OHSAS 18001 – to be known by “shorthand” names.
Clause 4.4.5 of OHSAS 18001 is known as “document control”; clause 4.5.2 is known as “CAPA” (corrective action and preventive action).
Similarly, clause 4.4.1 is often referred to as roles & responsibilities or “R2A2” – roles, responsibilities, authorities, and accountabilities.
OHSAS 18001 requires that the organization [a.k.a. “top management”] “ensure the availability of resources essential to establish, implement, maintain and improve the OH&S management system.” These resources include human resources and specialized skills, organizational infrastructure, technology and financial resources.
Although there is a great deal of focus these days on reducing cost, the truth is management systems cost money. An organization can strive to achieve the best value for the money spent; however, spending money is not optional.
One of the mistakes I often see organizations make is attempting to implement an OHSMS “on the cheap” – often by piling additional work onto already overworked staff and by attempting to “repurpose” existing infrastructure, such as data management software. Although I am all about being cost effective, there is more to an OHSMS then creating documentation using a global search on someone else’s procedures to replace your organization’s name for theirs. Similarly, the human resources needs of an occupational health and safety management system include individuals with a certain level of competence, specialized skills, and AVAILABLE TIME. Attempting to save money by using jerry-rigged databases often causes user frustration and results in incomplete and/or meaningless data being collected for analysis.
Nor is an OHSMS a one time purchase. The resource needs of an OHSMS continue and change over time.
As OHSAS 18002 points out (in section 4.4.1) – “Resources and their allocation should be reviewed periodically, via management review, to ensure they are sufficient to carry out OH&S programmes and activities ….the adequacy of resources can be at least partially evaluated by comparing the planned achievement of OH&S objectives with actual results.”
Have you evaluated your OHSMS resource needs?
© ENLAR Compliance Services, Inc. (2012)
In last week’s post, I discussed the two types of sustainability audits required by OHSAS 18001. In this week’s post, I am going to focus on the objectives necessary for an effective OHSMS internal audit program.
Just as there are different types of sustainability audits, there are different types of objectives required for management system audits. Importantly, an organization needs both audit program objectives and specific objectives to guide the conduct of each individual audit. Although the audit program objectives and individual audit objectives are related, they are not necessarily identical.
It is important to remember that an audit and an audit program are not the same thing. An audit is a “systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which audit criteria are fulfilled”. An audit program is “set of one or more audits planned for a specific time frame and directed toward a specific purpose”. (Definitions from ISO 19011:2002)
OHSAS 18001 requires that an audit program be established.
An audit program involves more than just doing audits every once and a while. It requires audit planning and it requires the creation of audit procedures. As set out in the note to the definition in ISO 19011 – an audit program includes “all activities necessary for planning, organizing and conducting the audits”.
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)