Disney Fireworks

Unfortunately, early Sunday morning tragedy struck Disney’s transit system when two monorail trains collided - killing one of the train operators.  According to news reports, the Occupational Safety and Health Administration (OSHA) is currently conducting an investigation into this accident. 

I was contemplating this accident – and the resulting negative publicity for Disney – as I reviewed the latest draft of ISO 31000 – ISO’s newly developed Risk Management standard.

One of the weaknesses of many risk management programs is failing to fully evaluate the risks associated with events that are rare (low likelihood) but with the potential for severe (highly negative) consequences.  In Section 5.5.2, ISO 31000 suggests that such events may warrant risk treatment even when it appears that action may not be justifiable on strictly economic grounds.  The typical assumption being that the event will never happen; therefore, the time and money expended to evaluate and address the risk will be wasted.

This monorail accident appears to be this type of an event. 

It was clearly rare.  According to Disney, this is the first fatal crash in the 38-year history of the monorail’s operation.   

Yet, the consequences of this accident are likely to be severe –

• death of an employee
• reduced confidence in – and utilization of – the transit system by guests
• the costs incurred associated with an OSHA fatality investigation – even if no fines are imposed
• negative publicity for a company that is very concerned about maintaining a positive public image

Take ISO 31000’s advice to heart in your own risk management programs – including the risk assessments conducted to meet the requirements of OHSAS 18001.  Be sure that your low likelihood risks are evaluated - including those associated with abnormal or unusual activities.  As the accident at Disney proved, just because an event hasn’t happened yet, that doesn’t mean it may not happen tomorrow.

© ENLAR^® Compliance Services, Inc. (2009)

In this case, like many, many others, the training being provided was an on-line generic training video developed by an outside safety training company that had been turned into “web-based” training.  What struck me in reviewing this training was the complete and total disconnect between the operation being performed at the facility and the safety training being provided to the employees performing the work. 

They had almost nothing in common. 

For example -

• The facility using the flammable liquid was a clean room / laboratory operation; the training film was set in a “heavy industry” machine shop.
• The task involved handling of relatively small quantities of flammable liquids in glass beakers; the training video showed the handling of large quantities of flammable liquids in 55-gallon drums.
• No bonding and grounding is used during dispensing operations; the training video emphasized the importance of bonding and grounding.
• Employees used little PPE; the training video showed employees using respirators and face shields for protection.

Because I am currently in the process of developing several e-learning programs, I have been reviewing information on instructional design as it relates to creating web-based training programs.  One of the experts in this area is M. David Merrill, a professor of instructional technology at Utah State University.  One of the points he emphasizes is - simply providing information is NOT instruction.  Instead, when developing training, he suggests that you start by developing a task-centered instructional design strategy. 

Start with one of the tasks being performed and build training that is appropriate to performing that task.  Eliminate information that is irrelevant or misleading.  Focus on what is important and useful to the specific task.  Apply the information to case study situations that are consistent with the content being taught.  Ask students to apply the knowledge being taught to a scenario that is similar to their real-world experience.  Build your training by repeating each of these steps for any other relevant tasks.

Want more information? 

Go to M. David Merrill’s web site and download his paper that discusses using the use of these principles in developing an on-line first aid course in Australia.  It is really cool.

© ENLAR^® Compliance Services, Inc. (2009)

 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 our OH&S program.

© ENLAR^® Compliance Services, Inc. (2009)

According to the AIAG statement they firmly believe that “the use of formal management systems are necessary for effective management of health safety and environmental programs.” 

AIAG’s concern appears to be that the OHSAS 18001 standard was developed by an independent group - the OHSAS Project Group chaired by BSI - rather than ISO. 

This is where the “politics” comes in.  Despite intensive lobbying by the OHSAS Project Group, ISO appears unwilling to develop an OHS management system standard. 

Why? 

 The International Labor Organization (ILO) has raised objections and several member countries - including the U.S. - have consistently voted against it.  An OHSMS standard seems to be the exception to the rule that any proposed ISO standard-setting activity is guaranteed to be approved.

© ENLAR^® Compliance Services, Inc. (2009)

Elimination is considered the most relable control measure because, if a hazard is eliminated, it no longer poses a risk.  On the other hand, control measures that rely on individuals behaving in a certain way are considered less reliable. The wearing of personal protective equipment (PPE) is considered a less reliable control because it is dependent on individuals using the right PPE and wearing it correctly.

For example, lets say the “hazard” one wants to control is exposure to a chemical used in cleaning a manufacturing area that is likely to cause ill health at a certain level of exposure. 

To use the “hierarchy of controls” protocol – you would take the following steps –

1. Explore whether the use of the chemical can be eliminated
2. If the use of the chemical cannot be eliminated – then you would explore whether there is a substitute chemical that can be used that does not have the same potential to cause ill health
3. If the use of the chemical cannot be eliminated and there is no suitable less toxic substitute – then one explores whether there is an appropriate engineering control  - such installation of a ventilation system that reduces the exposure
4. If an engineering control cannot be used (or until it can be installed), then other “adiminstrative controls” such as warning signs, PPE, etc. would  need to be put in place to reduce the hazard

The use of hierarchy of controls is a reiterative process – as individual control measures are put in place, you need to go back and re-evaluate the risk to see if it has reached an acceptable level or if additional controls are still needed.

For any particular hazard, more than one control measure may be needed to address the risk.  For example, controlling the risk of exposure to a toxic chemical may require the installation of a ventilation system AND establishing a preventive maintenance program for the ventilation system AND the use of warning signs AND the use of PPE. 

© ENLAR^® Compliance Services, Inc. (2009)

The purpose of this blog is to provide real-world practical advice to assist you in establishing, documenting, implementing and maintaining an integrated management system.

This website provides information and resources to help you understand the requirements of the various management system standards - ISO 9001, ISO 14001, OHSAS 18001, etc.  In addition, it provides an opportunity for you to post your questions and comments on a variety of management system topics.

An integral part of this blog is the monthly FREE teleseminar that ENLAR will be hosting.  These monthly ”conversations with experts” will provide a unique opportunity for you to BOTH listen to experts on a variety of management system topics AND ask questions for them to answer in their calls.

Click here to check out this new blog.  While you are there, check out the upcoming teleseminars on -

• Revision of ISO 19011 - The Challenge of Drafting a Generic Auditing Standard
• Five Steps for Achieving Employee Engagement

 Thanks!  I hope you like this new site.

© ENLAR^® Compliance Services, Inc. (2009)

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?

They initiated an employee wellness program focused on improving the overall health of their bus drivers.  This included offering incentives for drivers to participate in a regular exercise program.   

Why does driving a bus pose a health hazard?  

Driving a bus is a sedentary activity.  Bus drivers, like other drivers of commercial vehicles, may spend hours sitting in one spot - even if that “spot” happens to be moving.  As a result, drivers often gain weight and develop other health conditions such as high blood pressure and/or diabetes.  This is on top of other hazards, such the risk of injury due to accidents and exposure to diesel fumes.

Why did the school board act?

In addition to the desire for healthy drivers, the school district was concerned about cost.  According to the school board wellness coordinator - “Those types of health conditions (high blood pressure and high cholesterol) translate into high claims.  The school board wants to save lives and reduce claims.”

So when you are doing your hazard identification - be sure to ”think outside the box.”  Don’t limit your investigation to only the inside of your facility.  Make sure you look outside as well.  Include workers such as bus drivers, outside sales staff, repair technicians, and mobile workers - their health is important as well.

© ENLAR^® Compliance Services, Inc. (2009)

That is the wrong message and the wrong goal. 

To quote Peter Drucker – “There is nothing so useless as doing efficiently what should not be done at all.” 

The goal should not be to do more with less – it should be to do less.

What many OHS programs really need is a good pruning.  It is common for occupational health and safety management systems – particularly those driven by corporate mandates – to be filled with procedural “deadwood” and nonsensical “undergrowth”.

Want to start cutting back?  Try the following –

1.  Re-examine your Assumptions

Often OH&S programs are put in place because of so-called “good practice”.  These “good practices” are often characterized as requirements so the needed resources can be justified. 

Review your programs and procedures. For each program, procedure and form, re-examine the assumption that “we must do it this way”.   Do you need to do it at all?  Is there a more effective way?

2. Push Back on Busywork

It is a fact of life.  People like to tell other people how to do things. 

Evaluate the “busywork” quotient of your processes and procedures.  Avoid creating unnecessary work for others and “push back” when others attempt to do the same to you. 

• Don’t create a twenty page procedure if a one page form will do. 
• Don’t take on activities simply because they are “a nice idea” (often defined as something mentioned in a meeting by someone in senior management).
• Don’t add multiple layers of redundancy when it is not needed – especially if it is only to please some auditor.

3.  Keep Your Focus on Performance

Make sure you truly understand your OHSMS requirements – your OH&S risks and your legal obligations.  Focus your efforts on addressing these first - in as an efficient a manner as possible.  Say “NO” to suggestions that are not focused on improving your OHS performance.

4.  Be a Tortoise not a Hare

Focus each day on consistently moving forward.  It is easy to get discouraged when progress is slow and results are not readily apparent. Keep at it. 

Remain vigilant.  Resist the temptation to take on more than you have the resources to reasonably accomplish. If you have a plan and keep focused on doing what is important – rather than adding in additional activities that are new and exciting – you can accomplish your goals. 

Pruning is not easy. 

The status quo is often comfortable.  Change often meets with resistance. 

 You are very likely to hear - “We have always done it this way.  Why do we have to change?”

The answer – to survive when resources are scarce.

Need additional help? 

Check out the following –

• Abandoning the Obsolete and Unproductive - Column on Human Resources IQ website discussing why organizations need to prune their efforts.
• The Power of a Positive No by William Ury - Book offering concrete advice for saying No.

© ENLAR^® Compliance Services, Inc. (2009)

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)

To paraphrase a line from the last presidential election - “It’s the System, Stupid.”

Right now, there is a lot of finger-pointing and plenty of blame to spread around.  This mess is not, however, the fault of a single individual, a single institution or, even, a single political party.  Instead, it is the system that is flawed. 

A great deal of our current financial system has been created by the successive imposition of “free-market” reforms. The underlying premise has been that if one removes market controls - privatize public services, cut business regulation, reduce social spending, remove trade barriers and allow businesses more freedom to exploit resources - the resulting capitalist transformation will make all of our lives better.  Unfortunately, this has, instead, been a recipe for disaster.

Just like a financial system, an occupational safety and health management system cannot function without controls.  You cannot simply rely on people “doing the right thing” when it comes to safety - even if they are the ones who may be injured or killed.  They ignore risks, take short-cuts and assume “it won’t happen to them.”  Therefore, occupational safety and health professionals spend their time guarding equipment and installing interlocks, enforcing the use of safe work practices and personal protective equipment, establishing permissible exposure limits and monitoring worker exposure. 

That is why OHSAS 18001:2007 has placed an increased emphasis on controls.  First, section 4.3.2, requires that appropriate controls be identified - taking into account the hierarchy of controls.  Then, section 4.4.6 requires that the identified controls be implemented.  Finally, section 4.5.1 requires monitoring of “the effectiveness of controls.”

To avoid disaster, appropriate controls must be put in place, and more importantly, they must be used and monitoring to ensure they are effective.

© ENLAR^® Compliance Services, Inc. (2008)