Tag: OHSAS 18002
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)
One of the requests I commonly get from organizations seeking to integrate occupational health and safety into an existing environmental management system is –
“Can you provide a generic risk assessment process I can just plug into my aspect/impact procedure?”
The short answer to this request is “No.”
This is the fundamental difference between the OHSAS 18001 and the ISO 14001 standards. To conform to ISO 14001, many organizations have a single aspect/impact evaluation process. It may be complex and involve several factors and complicated calculations but it is typically one process. This is not the case for OHSAS 18001 hazard identification and risk assessment.
To quote from the OHSAS 18002 guidance –
Hazard identification and risk assessment methodologies vary greatly across industries, ranging from simple assessment to complex quantitative analyses with extensive documentation. Individual hazards may require that different methods be used, e.g. an assessment of long term exposure to chemicals may need a different method than that taken for equipment safety or for assessing an office workstation. Each organization should choose approaches that are appropriate to its scope, nature and size, and which meet its needs in terms of detail, complexity, time, cost and availability of reliable data. Taken together, the chosen approaches should result in a comprehensive methodology for the ongoing evaluation of the organization’s risk.
In other words – there is no simplistic answer or cookie-cutter methodology. It is not one process but several that, when taken together, make up a comprehensive risk management strategy.
© ENLAR® Compliance Services, Inc. (2008)