This week, in addition to attending the AIHCE in Portland, I will be participating in a meeting of the ANSI Z10 Committee. We will be discussing the revision of Z10 that was undertaken last year and is scheduled to be completed later this year (Fall 2011).
ANSI Z10:2005 is the American National Standard for Occupational Health and Safety Management Systems. As such, it is part of a large family of standards addressing this topic. The dominate sibling in this family is, of course, OHSAS 18001:2007. According to the 2009 Standards and Certificates Survey conducted by the OSHAS Project Group, over 50,000 organizations have obtained certification to OHSAS 18001.
The goal of this revision of Z10 is to continue to provide guidance helpful to organizations in the United States that want to implement an OH&S management system. Another use of Z10 is as a reference document for OSHA’s initiative for development of a standard requiring that employers establish an Injury and Illness Prevention Program (I2P2 Initiative). Finally, there is a desire to ensure that Z10 continues to have relevance to OH&S in the future.
One of the interesting inputs impacting this revision of Z10 is the increasing focus on sustainability initiatives and corporate sustainability reporting. Many OH&S professionals have expressed concern about the lack of attention given to worker safety within the sustainability movement. One of the initiatives ASSE and AIHA are working on together is the development of appropriate metrics for measuring OH&S performance for the next revision of the GRI sustainability reporting guidelines.
© ENLAR® Compliance Services, Inc. (2011)
Last week I gave a presentation to an industry group on OSHA’s proposed Injury and Illness Prevention Program (I2P2) rule. In my presentation, I focused on the requirements for worker participation within an OHSMS.
One of the questions OSHA raised in its original I2P2 proposal was –
What mechanisms have been found to be effective for enabling employees to participate in safety and health in the workplace?
Worker participation is one of the areas where there are significant differences between OHSAS 18001 and both ANSI Z10 and OSHA VPP.
OSHA VPP and ANSI Z10 focus on employee participation, as defined by the technicality of labor law. OHSAS 18001 focuses instead on worker participation, as defined by the extent of the organization’s control over the work being performed.
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)