In this article, I will update some of my earlier discussions on the management systems approach to occupational health and safety. I will also report on an interesting development in Europe and comment on whether a management system approach can work in the small- to-medium-size enterprise (SME).
I will not dwell on the mundane background to this subject; but rather jump right in the fray because I believe most of you are already familiar with the issues surrounding ISO-like management systems.
Why Is It Needed?
There is a global trend in the slowing of reductions of workplace illnesses and injuries, not to mention a slower rate of improvement in the developed world. Our statistics in the United States clearly demonstrate this. The questions then become: "What is needed to reinvigorate the significant progress that has been achieved over the last 50 years? Do we simply accept a certain injury and illness rate as an artifact of doing business?"
I know that most, if not all, of you are not willing to accept the proposal that illness and injury are just necessary evils of doing business. We need, then, to try some new approaches to get to the next level of performance. Although the management systems approach is not entirely new (it has roots in systems safety), it is a different approach to the development and self-regulation of a safety program.
Before we go on, we should clear the air on a couple of the most common complaints concerning these systems. First, there is the issue of bureaucracy. As one exasperated senior manager once told me, "The product of the management system approach is paper -- more and more paper!" Many of you who have been involved in the development of ISO-like quality systems or the newer environmental management or occupational health and safety management systems might fully agree. I also share some of the same sentiments. The documentation requirements for the management system approach are definitely paper-intensive. Nevertheless, so are existing approaches with their need for inspections, safe work permits, reports, etc.
This approach can become an exercise in paper shuffling if one were just to be concerned with evaluating the paper system and not the underlying actions taken. Yet, it is important to remember that performance improvement over the existing approach is the objective and the driving force for trying a management systems approach. If the only performance improvement is in the volume of paper consumed per unit of time, this approach should simply be abandoned. However, the development and organization of our written programs and policies is what gives us a true appreciation for what the program is really all about. Additionally, there are a number of studies showing companies with written programs, especially SME, have a better safety record than those without written programs.
The other major criticism is the issue of third-party audits. Some have suggested that this is an evil plot by those in this business who are trying to match the recent stock market performance: "A gold mine for consultants and a waste of money for us," as one detractor commented recently.
It is true that there has been a flurry of activity in the consulting community over the advent of ISO 9000 and ISO 14000. However, competitive pressures also have increased, lowering costs for most consulting services in these areas. For companies starting from scratch, it can be quite an effort to get up and running. For most companies that already have a quality system, it requires a much more modest effort.
Moreover, what I am proposing is a system where third-party certification is optional. I will provide an example later in this article, where third-party auditing has been made optional later in this article. Let us now address where the management system scheme fits in the traditional system.
Traditional Safety Program
The traditional approach to safety in many "old line" organizations has been reactive. That is, they develop policies and procedures based on new regulatory requirements or adverse incidents. Hence, the "safety manual" continues to grow and becomes a larger and larger collection of programs and policies that only the gifted fully understand. In fact, a good test for safety programs with this type of historical development is to try to flow-chart them to see how they fit into a process or system. Trying to find the logic and organization to such a program can be a very interesting and revealing exercise. Traditional approaches can work, even when based on responding to the latest issue or crisis. There are excellent company programs that are based on this approach. However, this usually occurs when there is some overarching policy that ties in all of the disparate parts (a management system of sorts). It is the tying together of safety practices and policies with the framework for the implementation of these practices that gives the management system its appeal.
This does not mean that a management system approach will reduce the volume of written documents or will solve all potential problems for a poorly developed program. The key to the management system philosophy is that it is a voluntary program to ensure that the policies and procedures you develop for the company are followed. Like quality, the management system alone does not ensure effective occupational health and safety. It does provide a level of comfort that there is an approach in place that will increase the likelihood that what is proposed is done.
As suggested above, there are a number of us who would echo the old adage, "Say it, do it and document it." In other words, prove that you did it. We also would recognize that a system of making sure you are doing what you say you are going to do is important when the organization is large and disperse. However, what if the organization is relatively small and centralized? Is the management systems approach the most effective and efficient way to enhance safety at the SME?
Europeans seem to feel that the management systems approach can be quite beneficial for the SME. The German state of Bavaria recently published a voluntary program, Occupational Health and Risk Management System (OHRIS). Bavaria developed this management systems approach because it believes it to be effective and because of the strong likelihood that the European Community will soon develop a management systems guidance document for safety and health.
The OHRIS contains 10 essential elements:
- Tasks and responsibilities of top management. These include development of an occupational health and safety strategy, specifications for the organizational structures, assessment of the system, internal and external communications and resource allocation for the management system.
- A management system. This element includes the establishment of the management system, internal committees and working groups, employee participation, programs, operation of the management system and documentation. Combining of management systems (ISO 9000 and 14000) is also addressed in this section.
- Requirements. This includes legal, industry standards and company requirements
- Prevention. This element includes identification and description of activities, management of change, safety processes, the general safety plan, identification of dangers and hazards, risk identification and assessment, hazard controls, medical surveillance and action programs.
- Review, surveillance and corrective actions. This section deals with the review of findings from the previous section and corrective actions. It includes special-emphasis programs such as the use of personal protective equipment and behavioral safety. It includes documentation requirements.
- Arrangements for breakdowns and emergencies. This section is devoted to deviations from normal practices and procedures and includes contingency planning.
- Purchasing. This section details programs for purchasing to including the selection and use of contractors.
- Control of records. Like most other management systems approaches, this section deals with the control of records.
- Personnel and resources. This section includes the rights, duties and competence of employees and their training.
- Audits. This element is common to all management systems approaches and emphasizes internal audits. This program approach does not require outside (third-party) audits and specifies a minimum interval of every three years for audits.
The OHRIS Experience?
The German research has shown that companies using this approach have had three times the performance improvement of those using other approaches (less than 10 accidents per 1,000 full-time workers vs. an average of 30 accidents per 1,000 full-time workers).
While the management system approach may not be the "answer" for everyone, it does offer a fresh approach to an age-old problem. It can be applied to the SME as well as the large multinational. Because of this, I am sure that you will see an increasing momentum toward use of this approach in this country as well as the world. It is an approach that is coming of age.
Contributing Editor Zack Mansdorf, Ph.D., CIH, CSP, QEP, has more than 25 years of technical and strategic experience in safety and health management. He is a past president of the American Industrial Hygiene Association and a director of the Board of Certified Safety Professionals. He can be reached via e-mail at [email protected]