Tag: risk assessment
The death of Georgian luger Nodar Kumaritashvili at the beginning the 2010 Olympic Games was tragic.
Even though most workplaces are clearly not the same as an Olympic sports facility, there are “lessons to be learned” from this tragedy for occupational health and safety professionals.
- Arguing whether the individual hurt was at fault is not productive. As the Georgian President Mikheil Saakashvili stated – “…no sports mistake is supposed to lead to a death.” When individuals die as a result of workplace incidents, the sentiment is the same. Blaming the worker is just as counterproductive as blaming an athlete.
- Consideration of “human factors” is both critical to preventing injury and more difficult and complex than it initially seems.
What are those complexities?
OHSAS 18001 requires that your organization’s procedure for hazard identification and risk assessment take into account “human behavior, capabilities and other human factors”.
Many organizations partially address this requirement by establishing an ergonomics program in order to address physical human factors. Only a few organizations explicitly address mental human factors as a part of their hazard identification and risk assessment.
Yet, mental human factors are very real and can be just as important as physical human factors. In some cases, they are even more important.
I recently had the following question e-mailed to me – “What is the “Hierarchy of Controls” [referenced in section 4.3.1 of OHSAS 18001:2007] and how do I address it in the hazard control & risk assessment procedure?”
The “hierarchy of controls” is a protocol that you use when deciding what kind of control measures you are going to use to address a particular OH&S hazard. The rationale underlying the “hierarchy of controls” is that an organization should use more reliable control measures rather than measures that are more likely to fail.
One of the requirements of OHSAS 18001 is to identify all of your workplace hazards, including those that may cause “ill health”. This includes illnesses that are made worse by a work activity. This analysis also needs to be extended to individuals beyond the borders of the traditional workplace.
ABC News reported on just such a situation last night. It included a segment on the health implications of driving a school bus and the steps Broward County, Florida has taken to address them.
What did the Broward County School Board do?
In a previous post, I discussed that there is no single, fill-in-the-blank, process for conducting an OHS hazard identification and risk assessment. Instead, what is needed is an assembly of individual processes that, when taken together, result in a comprehensive OHSMS risk management strategy.
It is equivalent to assembling a meal from an a la carte menu.
So what are your a la carte choices?
They are numerous and varied and include –
- Checklists and questionnaires
- Consequence / likelihood matrices
- Failure modes and effects analysis (FMEA)
- Hazard and operability studies (HAZOP)
- Exposure assessment strategies
- Bayesian analysis
- Ergonomic evaluations
- Computer modeling programs
Just as the key to healthy eating is making wise menu choices, the key to a sound OH&S risk management strategy is choosing the hazard identification and risk assessment tools that are appropriate for your organization.
© ENLAR® Compliance Services, Inc. (2008)
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)
Although it is often used as a term of art in the safety field, “management of change” is not a defined term in OHSAS 18001:2007. It is, however; vital to an effective OH&S management system.
Explicit requirements for management of change were added into section 4.3.1 of OHSAS 18001 in the 2007 revision of the standard. This addition was an explicit request of the American Industrial Hygiene Association for purposes of aligning OHSAS 18001 with the U.S. Occupational Health and Safety Management System standard — ANSI/AIHA Z10-2005. In addition, management of change is also an explicit requirement for safety management systems implemented to comply with the Seveso II Directive (see Annex III of EU Council Directive 96/82/EC).
The following requirements related to management of change were added in section 4.3.1:
The procedures for hazard identification and risk assessment shall take into account:
g) changes or proposed changes in the organization, its activities or materials; h) modifications to the OH&S management system, including temporary changes, and their impacts on operations, processes and activities;…. For the management of change, the organization shall identify the OH&S hazards and risks associated with changes in the organization, the OH&S management system or its activities, prior to the introduction of such changes.
These new requirements cover four important concepts:
- Identification of the hazards associated with “change”
- Assessment of the risks associated with “change”
- Consideration of OH&S hazards and risks prior to the introduction of the “change”
- Implementation of the controls needed to address the hazards and risks associated with the “change”
For purposes of management of change within an OH&S management system, the changes that need to be addressed include:
- Organizational changes (e.g. personnel or staffing changes)
- Activity changes (e.g. changes to processes, equipment, infrastructure, software)
- Material changes (e.g. new chemicals, packaging)
- Changes to the OH&S management system (e.g. procedures)
Why is management of change so important?
Ineffective management of change is one of the leading causes of serious incidents. To quote the U.S. Chemical Safety and Hazard Investigation Board (CSB), “In industry, as elsewhere, change often brings progress. But it can also increase risks that, if not properly managed, create conditions that may lead to injuries, property damage or even death.” (from CSB press release announcing its 8/28/2001 Safety Bulletin concerning “Management of Change”) Ineffective management of change is one of the major contributing factors in many of the incident investigations conducted by the CSB. To check it out, go to the CSB web site at http://www.csb.gov and enter “management of change” as your search term at the link “Search this Site.”
© ENLAR® Compliance Services, Inc. (2007)