IMPLEMENTING AN OCCUPATIONAL HEALTH & SAFETY MANAGEMENT SYSTEM

Ann W. Phillips
Vice President, Management Systems
Omni Tech International, Ltd.

256-883-3554 / Eddie Phillips
Manager – Occupational Medicine and Environmental Health
AJT & Associates, Inc.

256-544-5737

SUMMARY:

For decades, the focus of occupational health and safety programs has been centered on compliance with regulatory and statutory requirements. Metrics are typically based on “after the fact” data such as recordable or lost-time injuries or illnesses. During the past decade, however, the acceptance of management system standards in the quality and environmental arenas has enabled many organizations to move beyond compliance with specifications and regulatory requirements to developing management systems that foster continual improvement. In the same vein, organizations are beginning to look toward the development of OH&S management systems as a means of improving overall health and safety performance.

IMPLEMENTING AN OH&S MANAGEMENT SYSTEM:

The drivers to implement an effective OH&S system are changing. OSHA is no longer the primary driver. The odds of an organization being subjected to an OSHA audit are relatively small unless an incident has occurred resulting in loss of limb or loss of life. The primary drivers have become litigation risks and workman’s comp costs as well as the moral and ethical obligation to send employees home in the same condition in which they arrived at work.

Though liability is somewhat limited for employees (depending on state workman’s comp laws), liabilities for contractors are not limited in most cases. As companies downsize in a rough economy, they use more contracted services and are thus faced with increased liability issues.

To address these issues, organizations may have varying degrees of occupational health and safety programs in place. Programs may include Take Two, STOP, Behavior Safety programs, Management of Change, etc. A program typically operates as an entity unto itself and is rarely integrated with the business management system. They typically do not have formal processes for feedback and evaluation based on new processes or changing circumstances. Programs are more focused on compliance with regulatory requirements than continual improvement of processes and performance measures.

Conversely, a systems approach focuses on improvement of the occupational health and safety system as a mechanism to improve safety performance. Without losing site of the importance of regulatory compliance, the health and safety management system encourages the integration health and safety processes into the organization’s business management system. Integrating the health and safety system into the overall business diminishes the idea that safety is somehow a separate entity from the business. Health and safety becomes a WAY that business is performed.

As systems for quality (ISO 9001) and environmental (ISO 14001) management were being adopted in the 90’s by industries throughout the world, the demand for an international, externally verifiable OH&S management system standard began to build. As a result, numerous regulatory bodies and professional societies have written and published their own standards or specifications for OH&S management. Examples include the Voluntary Protection Program (OSHA), Responsible Care (CMA), the OHSMS Guidance Document (AIHA), BS 8800 (BSI), and the Proposed Health and Safety Program Rule (OSHA).

Each of these documents contains similar requirements. Most address to some degree:

  • Management commitment to the OH&S system
  • Provision of adequate resources to ensure the effective implementation of the OH&S system
  • Employee participation
  • OH&S policy, goals and objectives
  • Hazard assessment and risk analysis
  • OH&S documentation
  • Employee training
  • Emergency preparedness and response procedures
  • Corrective and preventive action
  • Document and record management
  • Communication system/employee feedback mechanisms
  • OH&S monitoring requirements
  • System evaluation including internal auditing, root-cause analysis and corrective action
  • Continual improvement of the effectiveness of the OH&S management system
  • Management review of defined goals and objectives

Though each of these documents establishes a systemic approach to managing OH&S issues, none were established to be used in a third-party certification scheme. An effectively implemented OH&S management system can reap benefits for an organization by minimizing risk of employee injury, illness, or fatality and reducing the associated costs. Certification of that system provides the additional benefit of showing employees, customers, communities and regulatory agencies the organization’s commitment to providing a safe workplace. But certification alone cannot be the ultimate objective. If the certificate is the primary goal, the company may miss the opportunity to maximize OH&S benefits for their employees. The ultimate goal is continual improvement of the OH&S system. The certification scheme is a tool to reach that goal.

A single, internationally recognized OH&S standard to which an organization can be certified does not yet exist. The International Organization for Standardization (ISO) voted in 1997 and again in October of 2000 against their developing such an international standard. Though the board’s vote in October 2000 was 29 in favor of such a standard and 20 against, a two-thirds majority is required to establish a new technical committee. Support is building within ISO for an OH&S standard, but it may well be several years away.

To fill the void, the British Standards Institute, with input from several other European standards and certification organizations, published and issued the Occupational Health & Safety Assessment Series (OHSAS) 18001 specification in 1999. OHSAS 18001:1999 is designed for use in a certification scheme. It has been well received throughout the world and many believe that it will one day be the basis for an ISO international standard for occupational health and safety.

OHSAS 18001:1999 defines those management system elements critical to an effective health and safety system, but does not specify how those elements are to be implemented. It requires the organization to demonstrate that its OH&S system not only complies with all applicable legal and regulatory requirements, but also proactively seeks to minimize risk to employees and contractors with a commitment to continual improvement of OH&S performance.

To facilitate the development of an integrated management system, OHSAS 18001:1999 was designed to be compatible with the ISO 14001 Environmental Management System Standard and the ISO 9001 Quality Management System Standard. The common structure of the standards allows organizations to integrate the health and safety system requirements into existing systems if the organization chooses to do so. If existing management procedures have been written, they could be modified or cross-referenced to include OH&S requirements. Such an approach would reduce the time and investment required to develop and implement the OH&S system.

Developing an OHSAS 18001-based OH&S management system that can be integrated with existing quality and environmental systems is an effective way to move OH&S from being a “program” to being a natural part of the business.

Other advantages include:

  • Health and safety policy, objectives and goals are well defined and clearly communicated. Employees become more aware of their responsibilities and authorities in achieving OH&S goals and objectives.
  • The policy, objectives and goals can be aligned with business objectives and may be incorporated into job performance standards.
  • Potential hazards are identified and risks are assessed as appropriate throughout the organization. Reasonable controls are implemented to manage and mitigate risks as required.
  • Appropriate training is conducted to ensure that employees are aware of potential risks and hazards and understand their responsibility in mitigating those risks.
  • Appropriate procedures are documented, implemented and controlled to ensure that processes are performed in a standard and consistent manner. Using documented procedures to train new employees will also ensure that processes are performed in a consistent manner over time.
  • A framework is established for continual improvement. Management not only establishes goals and objectives, but also develops a specific program to achieve those objectives and reviews the objectives at appropriate intervals to ensure compliance and identify opportunities for improvement.
  • A formal corrective and preventive action process is established to track and monitor identified action items and to ensure their timely and effective completion.

Though other OH&S management system documents contain similar requirements, OHSAS 18001 was specifically designed to be an externally verifiable standard that is consistent with management systems that may already be in place. Thus, OHSAS 18001 is an excellent basis for an organization wishing to improve their health and safety performance through certification of their OH&S management system.

REFERENCES:

  • Integrating Quality, Environmental and Safety Systems by Mary McDonald, Terry Mors, Ann W. Phillips, and Eddie Phillips. Government Institutes, 2001.