November 27, 2007
Many organizations are moving away from the traditional approach of handling occupational safety and health issues through a number of separate safety programs. Instead, they are pushing their OH&S professionals to develop and implement an OH&S management system that is integrated with the other management systems in use within the organization.
How is this approach different?
In the traditional safety program, there are often separate programs for hazard communication, personal protective equipment, equipment lockout/tagout, fire safety, etc. Each of these written programs sets out its own unique requirements – for training, recordkeeping, inspection, etc. Often, these programs are heavily based on restating the requirements set out in applicable OH&S regulations. This can result in a duplication of effort and lack of coordination with other organizational processes (e.g. different training programs, different emergency plans, different recordkeeping approaches, lack of document control, etc.). This approach also promotes the development an occupational health and safety “silo” separate from other business functions. In many cases, safety and health is viewed as being solely the responsibility of the OH&S professionals.
In a management system approach, the emphasis is on developing interrelated processes for managing occupational health and safety hazards and risks throughout all levels and functions of the organization. Everyone is held accountable for all of their individual management system responsibilities – including those related to OH&S. The emphasis is on developing integrated processes for handling common tasks such as managing training, document and record control and tracking corrective and preventive actions. Safety and health becomes part of everyone’s job.
This management system approach is new for many OH&S professionals.
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October 26, 2007
I was struck by the contrast between two news stories that came out in the last week reporting on occupational injuries and illnesses - one in the United States and one in India.
The first was a press release from the American Society of Safety Engineers (ASSE) in which the President of ASSE applauded the apparent drop in workplace injuries and illnesses recently reported by the US Bureau of Labor Statistics. According to the preliminary BLS report, the overall rate of both fatal and non-fatal work injuries in the United States dropped in 2006. Acccording to the BLS press release, there were 153 fatalities from expsoure to harmful substances or environments for all US workplaces in 2006.
The second was a news report from the Indian Express entitled “Ticket to Hell” that reported that 227 sanitary workers employed by the Pune Municipal Corporation died in just the last 30 months. This news report goes on to ask: ”[I]sn’t it incredible that an occupation as horrifying as cleaning the sewers of the city in the most primitive fashion possible should need a newspaper report to ensure something as basic as protective gear and health insurance for those who risk limb and lung every minute of their working life?”
© ENLAR® Compliance Services, Inc. (2007)
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September 27, 2007
Yesterday, the air traffic control system in Memphis went down. At the time, there were over 200 planes in the air space controlled by the Memphis center.
There were no plane crashes – no one died. Why?
A report on ABC Evening News last night highlighted two key reasons – pre-planning and the availability of an alternate means of communication.
The FAA has a contingency plan in place to address the loss of air traffic control at a particular location by diverting control to other centers – pre-planning. Individual air traffic controllers used their personal cell phones to contact other air traffic control locations – an alternate means of communication.
Within one hour, planes were diverted around the Memphis air space creating what one commentator described as “a black hole in the sky.”
In a previous blog, I discussed the importance of emergency preparedness in an occupational safety and health management system. Having procedures in place so you are prepared when things go wrong (including telecommunication and computer failures) is a key requirement of OHSAS 18001. More importantly, it saves lives.
For the last year and a half, I have been working with the local emergency planning committee (LEPC) conducting workshops for local businesses and emergency responders to assist them with business continuity planning in regional disasters. We have focused our outreach to organizations that handle significant quantities of hazardous materials.
During these workshops, two critical needs keep coming up.
Know what they are?
Adequate pre-planning (being prepared) and a functioning communication system.
As one attendee in our workshops put it, “As long as you have a plan and can talk, you can figure the rest out.”
© ENLAR® Compliance Services, Inc. (2007)
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September 19, 2007
When safety is at issue, responsibility is important - but so is accountability.
Security contractor Blackwater is once again under scrutiny because of concerns about a lack of accountability for its actions in Iraq. According to a Congressional Research Service report cited in CNN.com, concerns have been raised because of “the apparent lack of a practical means to hold contractors accountable…” Similar accountability issues have been raised in the wrongful death lawsuits filed against Blackwater as a result of the killing of 4 men working for Blackwater in Iraq in 2004. According to Frontline, those lawsuits charge that Blackwater “knowingly and intentionally” sent the men out “without the needed and promised protections” such as equipment, personnel and maps.
Although most organizations do not have the high profile of Blackwater, clearly defined occupational safety & health responsibilities and accountabilities are important to every organization.
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September 11, 2007
Last week, I attended a meeting of The Auditing Roundtable in Philadelphia. The keynote speaker was Glen Hiemstra - a Futurist. In his presentation he focused on the 9 future trends and forces that he believes will impact environmental, health and safety audit programs.
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September 4, 2007
Emergency Preparedness is an integral part of an occupational health and safety management system. OHSAS 18001:2007 requires that procedures be put in place to both identify and respond to potential emergency situations.
What is an emergency?
According to the dictionary - it is an unexpected occurence requiring immediate action.
One of the critical parts of being prepared for emergencies is the anticipation of the unexpected. One way of accomplishing this “anticipation” is to include it as an explicit part of your hazard identification and risk assessment processes. As you are identifying hazards, ask - “What if ….” The answer may surprise you.
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August 28, 2007
Inadequate emergency planning has claimed more victims at the World Trade Center site in New York City.
According to reports in The New York Times and Forbes, two firefighters were killed in a fire and two were injured in a separate construction accident last week at the Deutsche Bank building near Ground Zero. This building has been empty, and undergoing demolition, since it was damaged during the 9/11 terrorist attack six years ago.
These incidents highlight the importance of having a functioning OH&S management system - even for construction and demolition projects.
What were the obvious management system failures?
- Lack of appropriate risk assessment / inspection processes. Apparently, the fire department was not inspecting the building because of concerns about exposure to toxic materials.
- Lack of emergency preparedness procedures. No plans were in place for fighting a fire in the building.
- Failure to take effective corrective and preventive actions. This demolition project had apparently been plagued by accidents and the primary contractor has been cited for dozens of safety violations.
According to The New York Times article, Scott Stinger, the Manhattan Borough president, summed up the situation as follows:
“[W]e sent 100 firefighters in with little water, not enough oxygen and no plan….They have got to shut this down pending a safety review. I don’t understand why that is so difficult.”
It’s too bad a “safety review” wasn’t done before more people died. Even better - make sure an effective OH&S management system is put in place.
© ENLAR® Compliance Services, Inc. (2007)
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August 24, 2007
According to discussions surrounding the survey currently being circulated by the Technical Management Board (TMB) of ISO, one of the important factors in determining whether ISO moves forward with an occupational health and safety management standard (OHSMS) is whether ISO should defer to the International Labor Organization (ILO). ILO has published its own guidance document on OH&S management systems -ILO-OSH 2001 Guidelines on occupational safety and health management systems.
Setting aside for the moment whether ISO is the appropriate forum for setting social standards, this raises an equally interesting question:
Should Organized Labor “Own” Occupational Health & Safety?
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August 21, 2007
The International Organization for Standardization (ISO) is once again considering whether or not it should develop an OH&S Management System Standard (For information about ISO standard-setting activities go to http://www.iso.ch/iso/en/ISOOnline.frontpage)
The Technical Management Board (TMB) of ISO recently sent a survey form to the ISO member bodies (the various national standard-setting organizations from each country) asking for direction on whether to proceed in developing an OHSMS standard and, if so, what kind of standard.
Developing an ISO OHSMS standard has been an area of considerable controversy. Some labor and industry groups have been vehemently opposed to such an ISO standard. Other interested parties believe that, given the proliferation of different OHSMS standards and increased usage of OHSAS 18001, the time has come for the development of an international consensus standard that supports third-party accreditation of occupational health and safety management systems. (See my prior post on the plethora of OH&S standards that have been developed at http://ohsas18001expert.com/2007/05/15/a-plethora-of-ohs-standards/)
What do you think?
Opinion Polls & Market Research
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August 16, 2007
In reviewing my last two blogs, it struck me that I had started in the middle and really needed to go back to the beginning in discussing the five requirements set out in the first paragraph of Section 4.1 of OHSAS 18001:2007.
This paragraph reads:
The organization shall establish, document, implement, maintain and continually improve an OH&S management system in accordance with the requirements of this OHSAS standard and determine how it will fulfill these requirements.
So how does an organization establish an OH&S management system?
The dictionary defines establish as a verb meaning to “bring into being,” “set up” or “lay the groundwork for.” (http://dictionary.reference.com/browse/establish)
Since most organizations already have at least some existing OH&S processes and programs in place, establishing an OH&S management system is usually more like remodeling a kitchen than building a new house. It is often more difficult and expensive than you think it is going to be, you have to be careful about messing with existing structures and systems (”I can’t move this wall?”), and you can’t put everything on hold until you are done (”Just where am I going to cook breakfast?”).
Like any other “remodeling” project, you need to complete four tasks if your OH&S implementation is going to be successful:
- Determine your goals
- Decide on your scope
- Investigate what you already have
- Develop a plan to get where you want
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