In reviewing this document, I noted that one of the intents of this document is to list general principles of sustainability.  To accomplish this goal, the document lists principles associated with several topics from environmental labeling and sustainable buildings to risk management and social responsibility.  

In reviewing these lists of principles for other areas, I realized that I was not aware of a comparable list of worker health and safety principles.  As I discussed this with other OH&S professionals, they were not aware of any generally-recognized list of worker health and safety principles either.  

I thought about it and came up with the following list of seven principles (modeled after the list of Quality Principles set out in ISO 9000).

 Worker Health and Safety Principles

 1.       Health and Safety Focus

Worker health and well-being is an important organizational resource to be protected through the prevention of injury and ill health.

 2.       Leadership Commitment

Top management needs to provide the leadership and resources necessary for effective management of OH&S issues

 3.       Worker Engagement

Workers need to have the information, opportunities and accountability necessary for them to actively participate in ensuring their own safety

 4.       Factual Approach to Decision Making

Decisions and actions related to evaluating and controlling OH&S risks should, to the extent feasible, be based on the analysis of factual information

 5.       Prioritization of Controls

Hazards should be controlled using process, equipment and facility controls before administrative controls and personal protective equipment are utilized

 6.       Prevention Instead of Reaction

Establishing systematic processes to identify and address OH&S risks is more effective than waiting until after an incident has occurred to react

 7.        Supply Chain Accountability

Organizations need to act ethically when transferring OH&S risks to others in their supply chain

 What do you think?  Let me know by posting a comment to this blog post – or sending me an e-mail at tdunmire@enlar.com.

© ENLAR Compliance Services, Inc. (2012)

I found something truly amazing – at least to me.  A mainstream business book, a best-seller in fact, that had an entire chapter developed to worker safety!

Why was I amazed? 

Lately, it seems the only mention of worker safety is in the context of reducing OSHA regulations in order to unburden business.  Safety is typically demonized as a business burden not touted as a benefit.

Yet here was a book that made the convincing argument that focusing on worker safety was the “keystone habit” that drove the economic turnaround of a multi-billion dollar company.  Wow.

This book – The Power of Habit by Charles Duhigg – focuses on explaining why habits exist, why they are so powerful and how they can be changed.  It provides advice that can be used for changing personal habits – such as overeating chocolate chip cookies.  But it has more. What elevates it above a typical self-help book is that it also discusses the importance of organizational habits – the routines that underlay most business performance. 

As I read this book, I was struck by the similarities and synergies between organizational habits and management systems.  The routines that are the basic building blocks of habits are equivalent to the procedures (i.e. specified ways of conducting activities) that are the basic building blocks of management systems.  It struck me that the reason some organizations get great benefits from implementing management systems and others do not is the extent to which management systems are used to create and promote habits of success.

Are you interested in developing an OHSMS that creates positive cultural change?  Read this book.

© ENLAR Compliance Services, Inc. (2012)

Occupational safety and health is taking a hit from the politicians. 

One of the constant refrains from the Republican presidential hopefuls is that safety and health regulations are strangling business.  Or, as UK Prime Minister David Cameron put it in a recent speech - “the excessive culture of safety and health that is dragging down business like a heavy wooden yoke.”  

Are safety regulations burdensome to business?

Of course they are.

They limit what businesses can do.  Fundamentally, they transfer the costs and risks associated with being hurt on the job back to the businesses that benefit from the labor of the individuals who have been – or at risk of – being injured.

The question isn’t whether occupational injuries and illnesses have costs.  They do.

The fundamental issue is who should pay and, more importantly, when and how the costs should be incurred. 

The real question is – “Should there be costs to businesses associated with prevention of injuries and illnesses (i.e. regulatory schemes) or should the costs be incurred by the employees who are injured or killed?”

It seems that many businesses and political leaders believe there should be no prevention and workers should bear the full cost of their injuries – not employers. 

Their view – Forget about prevention; forget about compensation. 

Like the mantra of “buyer beware” for consumers, they seem prefer a culture of “worker beware” when it comes to safety.  In their view, workers should bear the risks of injury; businesses and society should not.  David Cameron put it this way – safety culture is “nothing more than a straitjacket on personal initiative and responsibility.” (For more on his rant against safety regulations click here.)

Never mind the point that many employees have little meaningful way of actually preventing workplace injuries.

To David Cameron’s real point (setting aside the rhetoric) – “Are there safety regulations that are too burdensome?”

Again, of course.

Every safety professional has his or her own list of silly regulations – requirements that do not meaningfully contribute to improving safety (i.e. reducing the risk of injury). 

HOWEVER – hyperbole is not helpful – except perhaps for politicians who want to get elected or solidify their power base.

What would be helpful is a collaborative effort to eliminate “stupid rules” AND to put in place meaningful ones.

 What’s needed are rules that save lives, prevent diseases, and, just as importantly, provide the transparency needed to actually evaluate whether companies are preventing injuries and ill health or simply transferring the costs and risks to workers, their families and society at large.

© ENLAR Compliance Services, Inc. (2012)

This interest seems to be driven by two organizational concerns – transparency and risk.  In particular, it appears to be driven by the risks associated with transparency.

I attended the ISO 9000 Conference earlier this week. 

One of the keynote speakers – Bennie Fowler from Ford Motor Company – discussed how Ford has refocused on its core principles in order to achieve a financial turn-around.  This includes a re-emphasis on the principle – “Quality is Job #1.”  At Ford, quality is now an integral part of executive strategy discussions.

One of the main drivers for this renewed emphasis on quality is transparency. 

Due to the “open communication” nature of the intranet, companies can no longer hide their quality problems. 

Today, delivering a quality product every time is key to survival.  If a company does not, its quality issues are likely to be reported on the intranet for all to see.

Other speakers discussed the on-going shift in focus from product quality to organizational quality.  According to surveys, consumers often buy products because of their perception of the company rather than because of any objective evaluation of the quality of a particular product. 

This means that organizational risks become marketing risks. 

This customer focus on organizational quality is one of the drivers in the increase in corporate sustainability reporting.  Customers are interested in whether a company is a good corporate citizen.  They want to make sure their brand loyalty is justified.

These sustainability reports often include an occupational safety and health component.  This usually consists of “some numbers” associated with injury rates. 

But are these numbers true?

If the studies that have been conducted on the accuracy of injury reporting are to be believed, maybe not. (Click here to go to a previous blog post about injury and illness reporting issues.)

Why?

There is no global standardization, no accountability (as in a third-party review of the data or processes used to develop the data) and definitely no transparency for injury and illness metrics.   There is no easy way to check the numbers being reported, nor is the information available to do so.  Right now, we simply have to take the company’s word for it that these “metrics” are accurate.

Quality is being driven by the risks of transparency; safety is not.

© ENLAR Compliance Services, Inc. (2012)

It is clear that integrated management systems represent the future.

This is evident from directives coming from the ISO Technical Management Board (TMB) that require the ISO technical committees to use a standardized structure and definitions for all ISO management system standards.  (Click here to read more about this MSS initiative.)

It is also evident in non-ISO management system standards – such as the Responsible Recycling (R2) Practices standard. 

The R2 Practices is a certification standard developed to help address the improper handling of electronics waste (E-waste).  This “E-Waste Problem” being the health and environmental impacts that result from the improper handling of E-waste – particularly in developing countries.  The R2 Practices standard is made up of 13 Practices that include quality, environmental and OH&S management system requirements – as well as mandatory supply chain management and a demonstration of financial responsibility.

Next Monday, February 27, 2012, I am giving a presentation about this standard at the ISO 9000 Conference in Orlando Florida.  My presentation is entitled Responsible Recycling:  Using Integrated Management Systems for Handling Electronics Waste.  This presentation is part of a conference track entitled Making Integrated Management Systems Work.

In order to provide additional information to conference attendees (there being only so much one can include in a 35 minute presentation), I have launched a new website.  This website focuses specifically on understanding the R2 Practices and implementing the management system processes necessary in order to become certified. 

Interested in how to use a management system to improve management of electronics waste?

Go to www.R2expert.com to learn more.

p.s. – My presentation isn’t just for “recyclers.”  It outlines five steps that any organization can take to better manage its used electronics.

Clause 4.4.5 of OHSAS 18001 is known as “document control”; clause 4.5.2 is known as “CAPA” (corrective action and preventive action).

Similarly, clause 4.4.1 is often referred to as roles & responsibilities or “R2A2” – roles, responsibilities, authorities, and accountabilities.

What is left out?  The first R – RESOURCES.

OHSAS 18001 requires that the organization [a.k.a. “top management”] “ensure the availability of resources essential to establish, implement, maintain and improve the OH&S management system.”  These resources include human resources and specialized skills, organizational infrastructure, technology and financial resources.

Although there is a great deal of focus these days on reducing cost, the truth is management systems cost money.   An organization can strive to achieve the best value for the money spent; however, spending money is not optional.

One of the mistakes I often see organizations make is attempting to implement an OHSMS “on the cheap” – often by piling additional work onto already overworked staff and by attempting to “repurpose” existing infrastructure, such as data management software.    Although I am all about being cost effective, there is more to an OHSMS then creating documentation using a global search on someone else’s procedures to replace your organization’s name for theirs.  Similarly, the human resources needs of an occupational health and safety management system include individuals with a certain level of competence, specialized skills, and AVAILABLE TIME.  Attempting to save money by using jerry-rigged databases often causes user frustration and results in incomplete and/or meaningless data being collected for analysis.

Nor is an OHSMS a one time purchase. The resource needs of an OHSMS continue and change over time.

As OHSAS 18002 points out (in section 4.4.1) – “Resources and their allocation should be reviewed periodically, via management review, to ensure they are sufficient to carry out OH&S programmes and activities ….the adequacy of resources can be at least partially evaluated by comparing the planned achievement of OH&S objectives with actual results.”

Have you evaluated your OHSMS resource needs?

© ENLAR Compliance Services, Inc. (2012)

What this provision requires is that an organization have processes are in place to “circle back” at some later point in time to verify that the corrective actions taken actually worked.

What does this “effectiveness review” need to include?

At a minimum, two determinations are needed –

1. Was the proposed corrective action done?
2. Was the action taken “effective”?

First, was it done – was some action actually taken, was the action that was completed what was proposed and has it been sustained?

It is not uncommon to find that the proposed action was never done.  Sometimes, people get “busy” and taking the specified corrective action is constantly “put off until tomorrow” as other priorities take precedence.  In other cases, the action actually undertaken is NOT the action that was initially proposed.  Perhaps the proposed action didn’t actually work when it comes to actually implementing it.  Then there are the situations where changes are made initially but the organization quickly reverts to doing things the old way.

Second, was the action taken “effective” in fixing the issue identified as the nonconformity?

It is not uncommon to find that the action actually taken as corrective action bears little, or no, relationship to “the problem” identified as the nonconformity in the first place.  In the process of evaluating what actions should be taken, it is easy to get sidetracked by other interests and priorities and end up “fixing” something else entirely.  (“Gee, this is a great opportunity to justify getting the new training software we have always wanted.”)

The other difficulty with determining the effectiveness of the action taken is that “effective” is not a defined term and is a very subjective standard.

What qualifies as “effective”?

The dictionary defines “effective” as “adequate to accomplish a purpose” – not very much help. 

The key to this effectiveness determination is deciding whether or not the action taken will prevent “the problem” identified from recurring again in the future.  This determination needs to be based on an objective (i.e. unbiased) review of factual evidence.  Click here to access an interesting article on verifying the effectiveness of corrective action – including common questions to ask about the actions taken.  As the author of this article, Craig Cochran, puts it – “Verification isn’t an act of suspicion; it’s a necessary part of problem solving.”

© ENLAR Compliance Services, Inc. (2012)

They have lots of ideas, but no direction.  Plenty of concepts, but few plans.

The same can often be said of many OH&S management system implementation projects.

This editorial goes on to discuss a New Year’s Eve gathering at the Occupy Tampa location -

They discussed how to greet the new year.  They discussed if a toast was appropriate and what the toast should be.  And who should offer it.

Eventually someone began a countdown.

They had eight seconds to spare.

This reminded me of how some organizations approach OHSAS 18001 certification.

Lots of meetings and conference calls.  Lots of discussion of what should be done – particularly by someone else.

Little “rolling up the sleeves” for taking concrete action. More importantly, little completion – until the countdown for registration starts and there are “eight seconds to spare.”

As with the Occupy movement, too many ideas by too many players and too much accommodation of every perspective leads to a scattered and disjointed approach to an OHSMS. 

At some point, decisions and focus and action are needed. 

In the end, it is better to be done than it is to be perfect. 

After all, there is always next year.

PS – Want help in figuring out your plan for implementing an OHSAS 18001 management system?   Click here to request your copy of ENLAR’s EHSMS Implementation Checklist.

© ENLAR Compliance Services, Inc. (2012)

At the end of the year, our attention often focuses on planning – the setting of goals and objectives for the coming year.  This can be exciting - plans for launching new projects or products – or it can be depressing - setting aside time to organize old files.

Planning is a key component of an OH&S management system.  The planning section of OHSAS 18001 consists of 3 elements –

• Identifying hazards and risks (4.3.1)
• Identifying legal and other requirements (4.3.2)
• Establishing objectives and programs (4.3.3)

Many organizations put a great deal of time and attention into identifying both their hazards and risks and their legal and other requirements. Often, less attention is paid to establishing objectives and programs.

This lack of attention to objectives and programs may be due, in part, to a lack of clarity about how “objectives” actually fit into a management system.  This lack of clarity about objectives, and their interrelationship with risk management, has been an issue of much heated discussion.  It has lead to a lack of consensus in ISO’s attempt to develop consistent definitions across all of its management system standards (see discussion of ISO’s MSS initiative).

One of the areas of confusion relates to the ownership of OH&S objectives.  Although individuals need to be assigned responsibility and authority for achieving OH&S objectives, OH&S objectives are organizational – not personal.  This is clear from the definition of OH&S objective in section 3.14 of OHSAS 18001.  An objective is a goal that an organization sets itself to achieve.   Therefore, OH&S objectives need to be set from an organizational perspective – not as individual performance targets.  This is a critical distinction.  It is the organization itself that is ultimately responsible for setting and achieving its objectives.  This responsibility cannot be shifted onto the backs of individual employees – such as the facility Safety Manager.

A second area of confusion relates to the use of the words “objective” and “risk” in two different contexts within the ISO management system standards and OHSAS 18001. 

The “top-level” meaning – used in defining both what a “management system” is and the meaning of the word “risk.” 

A management system is defined as a “set of interrelated or interacting elements to establish policy and objectives and to achieve those objectives” (ISO 9000, Section 3.2.1 & 3.2.2).  Risk is defined as “the effect of uncertainty on objectives” (ISO 31000, Section 2.1). Both of these definitions are focused on the strategic, organization-wide level of objectives.

This means that the overall “strategic level” objective of an OHSAS 18001 management system must be controlling (managing) OH&S risks in order to prevent injury and ill health to persons working under the control of the organization.  All other OH&S objectives flow from, and must be consistent with, this strategic-level objective.

The “functional level” meaning – used at a project, process or departmental level of an organization. 

This is the level at which most organizational objectives are set and managed.  Financial profitability and sales targets.  Product quality metrics.  Safety performance targets.  Waste reduction goals. 

The functional-level definition of an “OH&S objective”, as set out in section 3.14 of OHSAS 18001, is an “OH&S goal, in terms of OH&S performance, that an organization sets itself to achieve” (OHSAS 18001, Section 3.14).

Functional-level objectives are important.  They are where “the rubber hits the road” so to speak.  However, when evaluating OH&S performance and assessing overall risk management, the objective that must be kept foremost in mind is the strategic, top-level one.

At the end of the day, the question that must be answered is “Are we, as an organization, controlling our OH&S risks in a manner that prevents injury and ill health to those working for our organization?”

© ENLAR Compliance Services, Inc.(2011)

Once I started developing and implementing management systems, I could not resist applying management system theory to this event.  I developed a Christmas Party Checklist.  This checklist sets out the various tasks that need to be done and has blanks for assigning responsibilities and checking off each task when it is done.

Why do I use a checklist?

One year, I found the strawberries for the appetizer course still in the refrigerator when I put the leftovers away.  Another year, I had to scramble to find the meat platter while the guests watched from the table.

This checklist helps the party go smoothly and, more importantly, it helps me relax and actually enjoy the party because I know I am not going to forget anything important.

The morning after the party I make notes and additions to the checklist and file it away for the following year.

So what does this have to do with OHSAS 18001?

Checklists are an important part of a management system.  As with our Christmas party, they prevent you from missing important tasks.  They also help make your job more manageable and enjoyable – that is, if they are done right.

Want to learn more about creating effective checklists?

Click here to check out my previous blog and sign up for my mini-course (starting January 16, 2012) focused on checklist creation.

p.s.  It was a great webinar Tuesday on ISO 19011:2011 – The Impact on Management System Auditing. Thank you to those of you who participated and submitted questions for the Q&A.  Come back here next week for a link you can use to view this presentation.

© ENLAR Compliance Services, Inc. (2011)