Over the last several years, there has been a great deal of controversy over development of a standardized approach to management systems for occupational safety and health (OSH). It appears that the International Standards Organization (ISO) will not proceed with an effort in this area, based on the April 19 international vote by ISO-member countries. That vote narrowly defeated a proposal by the British Standards Institute for an OSH management systems standard.
National voluntary standardization efforts, however, will continue on a country-by-country basis, including in the United States. This outcome might be viewed as predictable, given the politics involved. Yet, it leads to the very problem that ISO was created to resolve: widely varying approaches and requirements from country to country.
The International Labour Organization (ILO) has recognized this problem and the potential advantages of a management systems approach. ILO's leaders believe it is the ideal organization -- representing government, management and labor -- to develop a model management system that members can use to develop their own national systems.
ILO considers safety culture and a management systems approach to be essential elements for the improvement of performance. Consequently, it has recently developed a draft "Guideline on Occupational Safety and Health Management Systems (OSHMS)."
In this column, I will provide a primer on ILO, discuss the development of the draft, summarize some interesting aspects of the guidelines and discuss the probable future of this initiative.
Development of the Draft Guidance Document
The current draft OSHMS was initiated through a study performed by the International Occupational Hygiene Association for ILO. It compared various existing draft or final national and voluntary OSHMS approaches and included recommendations for what might constitute a model system. It was published approximately two years ago (available through ILO's Web site).
From this framework, a group of ILO experts crafted the draft OSHMS document. ILO member bodies will review this draft over the next year. A meeting of experts has been scheduled in April for "discussion and approval as general requirements regarding the development of both favorable national conditions and appropriate occupational safety and health management frameworks at enterprise levels."
Current Draft Guideline
The early draft is for review and not an approved document of ILO (and, hence, should not be quoted or referenced as such). Nevertheless, it is of interest to those following ongoing developments in this area. The draft is divided into seven major headings, 18 sections and eight annexes. A few sections are not complete and still under development.
The seven major headings are introduction, general, policy, organization, planning, measuring performance and evaluation. The annexes include assessment of hazards and risks, responsibilities of employers, duties and rights of workers, performance measurement, surveillance of the working environment, training and information system, risk assessment and worker's health surveillance. While much of the document is somewhat standard to an OSH management systems approach, there are some aspects that are novel or will generate substantial discussion.
Management Systems Approach
The essence of the ILO management system approach is described within the scope section:
"An OSH management system concept prescribes 'what' should be covered and according to what criteria. 'How' remains the prerogative of the organization."
The draft document states that the main objective is to provide guidance to motivate managerial staff and workers in applying management systems aimed at increased OSH performance and higher productivity and to promote an improved framework and organization for OSH. It also states:
"The model guidelines on OSH management system of this code should be considered as internationally accepted requirements with a view to: a) be adapted to national conditions and practice; and b) be used for the establishment of a national framework for OSH management systems, preferably prescribed by national laws and regulations."
This statement is sure to endear laissez faire proponents.
The scope section goes on to state, "[the code would] apply to all branches and sizes of organizations and all workers regardless of their status of employment."
Management systems are applicable to, and benefit from, not only large organizations but also small- and medium-sized enterprises in the view of ILO and many others. This section goes on to state that guidelines would be minimal requirements and that more-stringent national regulations would have priority.
Addressing Potential Critics
The scope section also addresses one of the more common criticisms of a management systems approach, that it adds a burdensome layer of paperwork and attendant costs. It suggests that the developed systems approach "avoid additional bureaucracy, heavy administration and unjustified costs, and mandatory external audits and certifications."
Even with this caution, most of us would recognize the bureaucratic nature of documentation required of any management system. The central issue is the balance between necessary documentation of programs and activities and benefits realized from this documentation.
Another common criticism of national and international voluntary standards for OSH is that they do not account for differences within and between countries on a societal and economic basis. This issue is addressed under the policy section of the draft. It notes that not all sections of the guidance document may be applicable. It also states, in part:
"Tailored OSH management concepts should be designed in accordance with national conditions and practice and correspond to the specialties of organizations or groups of organizations, in particular with regard to: a) their size and infrastructure; b) the risk levels; and c) other specific conditions."
This issue is addressed further in another section of the draft and in several other places where it discusses a "national competent authority." Under a section titled "Policy and Principles at the National Level," the draft states:
"Each government should nominate a competent authority or authorities, as appropriate, which should, in the light of national conditions and practice and in consultation with the most representative organizations or employers and workers and other organizations and authorities, formulate, implement and periodically review a coherent policy and principles on the organization and implementation of occupational safety and health management systems in organizations."
This would be a means to set the "standard" for practice and management systems within each country. I would assume this could be a consensus standards-setting body (e.g., ANSI), a professional organization or a government or quasi-government body.
Some Key Elements
There is a section on worker participation in the policy section of the document. It simply states that workers or their representatives be consulted and actively participate in all elements of the OSH management system.
Other requirements are relatively straightforward and common to the recognized importance of workers' participation in their own safety and health. The duties and rights of workers are covered in an annex. This includes the requirement to comply with prescribed safety and health measures and to cooperate with employers and other workers in meeting duties and responsibilities of the employer for OSH. It also identifies the right to be represented and other labor issues, including the right to appeal to the competent authority.
Key areas of OSH management planning are given under the planning element of the draft document. They include:
- Overall plans and objectives for the implementation of the OSH policy;
- Operational plans to implement arrangements to control risks;
- Contingency plans for emergencies;
- Planning for measuring performance, audits and management reviews; and
- Implementing corrective actions.
There is also consideration given to the consequence of internal changes in this section of the draft. This management-of-change aspect is quite good and important. Experts recognize the downstream effects of change as a common cause of major adverse events and accidents. The draft document stresses results-oriented goals and objectives as another important aspect of effective OSH management. Under a section on goals and objectives, it states:
"Based on and consistent with the OSH policy of the organization, the employer and top management, following consultation with the workers or their representatives, should establish clear results-oriented and, preferably, quantifiable goals and objectives for the implementation of the OSH policy and improved worker safety and health protection."
This concept is further developed later in the draft in the measuring performance element. There is an appropriate emphasis placed on "active" vs. "reactive" monitoring. Examples of active monitoring given in the document include:
- The systematic inspection of work systems, regulatory compliance, premises, plant and equipment by supervisors, maintenance staff, management safety representatives or other employees to ensure the continued effective operation of workplace precautions;
- Surveillance of the working environment and workers' health surveillance to check the effectiveness of health control measures and to detect early signs of harm to health;
- The operation of audit systems; and
- Consideration of regular reports on health and safety performance by the employer and top management.
These suggestions are in addition to collection and trend analyses of the more traditional "reactive" measures such as injury and illness rates, incidents and hazardous occurrences.
Contractor safety and health is also covered in the document. This is an important area for emphasis because it is common to outsource construction work and high-risk tasks and operations. This section addresses the procurement issues (incorporation of safety and health requirements into purchasing specifications) and monitoring of contractor safety and health. For example, it requires that the employer and top management establish and maintain procedures for controlling safety and health aspects of contractor work.
Management review of the OSH management system, auditing, incident investigation and root-cause analysis are also covered in the document. These sections generally follow standard management systems approaches. The auditing section includes a paragraph on the need for auditing personnel who are "competent" and as independent as possible from the activity being audited. The audit methodologies, frequency and scope are left to the organization to determine.
A considerable amount of detailed practices or recommendations are contained in the annexes or in referenced ILO documents. Even with the use of these annexes, the document seems longer than necessary. It also seems likely that it will increase in size during the review process rather than be made more concise. While unfortunate, it is the price of multiparty consensus.
All in all, it is a well-written and comprehensive approach to development of a management systems approach to occupational safety and health. It should provide an excellent starting point for ILO representatives in their respective countries and the forthcoming meeting of experts.
The controversy over an international voluntary standard for occupational safety and health management systems is far from over. It would not surprise me to see this issue arise again under the ISO umbrella. In the meantime, more companies will register under what was originally published as a nonauditable standard (BS 8800) and available in an auditable version (OHSMS, 18001, 1999). At the same time, the work at ILO will continue, as will the progress to national voluntary standards.
Management systems approaches are not the end all to the "safety problem." But they are a proven tool that I predict will gain acceptance as a good approach for the effective management of occupational safety and health.
Additional information about ILO can be obtained through its Web site at www.ilo.org. Additional information on its management systems initiatives can be found through the ILO Web site under "SafeWork."
Contributing Editor Zack Mansdorf, Ph.D., CIH, CSP, QEP, is the director of safety, occupational health and environmental for L'Oreal and is based in Paris. 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 through e-mail at [email protected]